Text

Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5A and 5B, Cover - Dr 3-76
	ML14164A064
Person / Time
Site:	Dresden
Issue date:	05/30/2014
From:	; Exelon Generation Co
To:	; NRC/FSME, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML14164A053	List: ML14164A054; ML14164A055; ML14164A056; ML14164A058; ML14164A060; ML14164A061; ML14164A062; ML14164A063; ML14164A064; ML14164A065; ML14164A066; ML14164A067; ML14164A068; ML14164A069; ML14164A071; ML14164A073; ML14164A076; ML14164A079; NEI 99-01, Braidwood, Units 1 and 2, Attachment 2, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1001, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 2A, and 2B, Cover Through Pa; NEI 99-01, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3A, 3B, Cover - by 3-74; NEI 99-01, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3B, 3C, by 3-75 - by 3-157; NEI 99-01, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4A and 4B, Cover - Cl 3-73; NEI 99-01, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4B and 4C, Cl 3-74 - Cl 3-151; NEI 99-01, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5A and 5B, Cover - Dr 3-76; NEI 99-01, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5B and 5C, Dr 3-77 - Dr 3-160; NEI 99-01, LaSalle, Units 1 & 3, Attachment 6, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1005, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 6A and 6B, Cover - LS 3-74; NEI 99-01, License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.; RA-14-032, Attachment 10: Discussion of Revision to the Radiological Emergency Plan Annex for Quad Cities Nuclear Power Station, Page QC 3-69 Through End; RA-14-032, Attachment 11: Discussion of Revision to the Radiological Emergency Plan Annex for Three Mile Island Nuclear Station, Page TMI 3-80 Through End; RA-14-032, Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. Cover Through Page LGS 3-69; RA-14-032, Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. LGS 3-70 Page LGS 3-155; RA-14-032, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station, Page Ocgs 3-76 Through End; RA-14-032, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station. Cover Through Page Ocgs 3-75; RA-14-032, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Cover Through Page PBAPS 3-76; RA-14-032, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Page PBAPS 3-77 Through End; RA-14-032, Braidwood, Units 1 and 2, Attachment 2, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1001, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 2A, and 2B, Cover Through Pa; RA-14-032, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3A, 3B, Cover - by 3-74; RA-14-032, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3B, 3C, by 3-75 - by 3-157; RA-14-032, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4A and 4B, Cover - Cl 3-73; RA-14-032, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4B and 4C, Cl 3-74 - Cl 3-151; RA-14-032, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5A and 5B, Cover - Dr 3-76; RA-14-032, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5B and 5C, Dr 3-77 - Dr 3-160; RA-14-032, LaSalle, Units 1 & 3, Attachment 6, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1005, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 6A and 6B, Cover - LS 3-74; RA-14-032, License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.; RS-14-115, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Page PBAPS 3-77 Through End; TMI-14-046, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station, Page Ocgs 3-76 Through End;
References
	NEI 99-01, Rev 6, RA-14-032, RS-14-115, TMI-14-046 EP-AA-1004
	Download: ML14164A064 (144)
	v • d • e

ATTACHMENT 5 DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FOR DRESDEN NUCLEAR POWER STATION EP-AA-1004 Enclosures S 0 S Enclosure 5A -EAL Comparison Matrix Document Enclosure 5B -EAL Red-Line Basis Document Enclosure 5C -EAL Basis Document NEI 99-01 REVISION 6 DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS AIrrACHMENT 5 DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FOR DRESDEN STATION Exelon Generation.

0 0 NEI 99-01 Rev 6 1 Proposed EAL I Justification AGI Initiating Condition -GENERAL EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the General Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dose receptor point)3. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point):* Closed window dose rates greater than 1000 mR/hr expected to continue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than 5000 mrem for one hour of inhalation.

RGI Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mRem TEDE or 5,000 mRem thyroid CDE.Operating Mode Applicability:

1,2,3.4,5,D Emergency Action Level (EAL): Notes: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs >7.90 E+09 uCilsec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 1000 mRem TEDE OR b. > 5000 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >1000 mRihr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.

H: No Change 111 Difference FIDeviation

1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet #3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 11x17 procedure matrix used by the SM.Page 1 of66 0 NEI 99-01 Rev 6 1 Proposed EAL Justification ASI Initiating Condition

-SITE AREA EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the Site Area Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dose receptor point)3. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point):* Closed window dose rates greater than 100 mR/hr expected to continue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than 500 mrem for one hour of inhalation.

RS1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDE or 500 mRem thyroid CDE.Operating Mode Applicability:

1,2,3,4,5,D Emergency Action Level (EAL): Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.I If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+08 uCilsec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 100 mRem TEDE OR b. > 500 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >100 mR/hr are expected to continue for> 60 minutes.OR b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.

No Change FIDifference I-1 Deviation 1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet #3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x17 procedure matrix used by the SM.Page 2 of 66 NEI 99-01 Rev 6 [ Proposed EAL [ Justification AA1 Initiating Condition

-ALERT Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3)Note:* The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown.assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EALt #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site-specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site specific dose receptor point)3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site-specific dose receptor point) for one hour of exposure.4. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point):* Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.

RA1 Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.Operating Mode Applicability:

1, 2, 3,4.5, D Emergency Action Level (EAL): Notes: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+07 uCi/sec for_> 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 10 mRem TEDE OR b. > 50 mRem CDE Thyroid OR 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary a. 10 mRem TEDE for 60 minutes of exposure OR b. 50 mRem CDE Thyroid for 60 minutes of exposure OR 4. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for> 60 minutes.OR b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.

D-- No Change 1-- Difference

[I] Deviation 1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet #3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 11x17 procedure matrix used by the SM.3) A calculation was performed, in accordance with (IAV) guidance provided in NEI 99-01 revision 6 EAL AA1, to determine the effluent monitor response for a radioactive liquid release via the normal site release pathway. The liquid release would contain activity equivalent to provide 10mrem TEDE or 50mrem thyroid CDE at the site boundary.

The calculation determined the effluent monitor response would be >110% of the instrument maximum range and as such, lAW NEI 99-01 Rev 6 guidance, was not included in this EAL.Page 3 of 66 NEI 99-01 Rev 6 [ Proposed EAL Justification AU1 Initiating Condition

-UNUSUAL EVENT Release of gaseous or liquid radioactivity greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3)Note:* The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.* If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer valid for classification purposes.1. Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer: (site-specific monitor list and threshold values corresponding to 2 times the controlling document limits)2. Reading on ANY effluent radiation monitor greater than 2 times the alarm selpoint established by a current radioactivity discharge permit for 60 minutes or longer.3. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent release controlling document limits) for 60 minutes or longer.RU1 Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.Operating Mode Applicability:

1,2.3,4, 5, D Emergency Action Level (EAL): Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.* Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.1. Reading on ANY of the following effluent monitors > 2 times alarm setpoint established by a current radioactive release discharge permit for ? 60 minutes.* Radwaste Effluent Monitor 213-2001-948 OR* Discharge Permit specified monitor OR 2. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 9.02 E+05 uCi/sec for > 60 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.D No Change E Difference

[I] Deviation 1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet #3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 lx17 procedure matrix used by the SM.Page 4 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AG2 RG2 DANo ChangeDifference

--]Deviatton Initiating Condition

-GENERAL EMERGENCY 1 No Change Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.1) EAL not used in accordance with the discussion in Section 1.4, NRC Order Operating Mode Applicability:

All EA-12-051, it is recommended that this EAL be implemented when the enhanced spent fuel pool level instrumentation is available for use. The completion of the Example Emergency Action Levels: enhanced SFP level indicators and need for the inclusion of this EAL is being tracked in accordance with Exelon Generation Company, LLC's Initial Status NOTES: The Emergency Director should declare the General Emergency Report to March 12, 2012 Commission Order Modifying Licenses with Regard for promptly upon determining that 60 minutes has been exceeded, Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated or will likely be exceeded October 25,2012.1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.Page 5 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition

-SITE AREA EMERGENCY No Change Difference Deviation Spent fuel pool level cannot be restored to at least (site-specific Level 3 description)

1) EAL not used in accordance with the discussion in Section 1.4, NRC Order EA-12-051, it is recommended that this EAL be implemented when the enhanced Operating Mode Applicability:

Al spent fuel pool level instrumentation is available for use. The completion of the enhanced SFP level indicators and need for the inclusion of this EAL is being Example Emergency Action Levels: tracked in accordance with Exelon Generation Company, LLC's Initial Status Report to March 12, 2012 Commission Order Modifying Licenses with Regard for 1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated description)

October 25,2012.Page 6 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AA2RA Initiating Condition

-ALERT gRA2 F No Change Difference Deviation Significant lowering of water level above, or damage to, irradiated fuel. Significant lowering of water level above, or damage to, irradiated fuel. 1) Listed site-specific monitors and Threshold values t0 ensure timely classification.

Operating Mode Applicability:

Ail Operating Mode Applicability:

2) EAL #3 not used in accordance with the discussion in Section 1.4, NRC Order 1, 2, 3, 4, 5, D EA-1 2-051, it is recommended that this EAL be implemented when the enhanced Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Level (EAL): spent fuel pool level instrumentation is available for use. The completion of the enhanced SFP level indicators and need for the inclusion of this EAL is being 1. Uncovery of irradiated fuel in the REFUELING PATHWAY. 1. Uncovery of irradiated fuel in the REFUELING PATHWAY. tracked in accordance with Exelon Generation Company, LLC's Initial Status OR Report to March 12, 2012 Commission Order Modifying Licenses with Regard for 2. Damage to irradiated fuel resulting in a release of radioactivity from the Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated fuel as indicated by ANY of the following radiation monitors:

2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel October 25,2012.as indicated by ANY Table R1 Radiation Monitor reading >1000 mRemlhr.(site-specific listing of radiation monitors, and the associated readings, Table RI setpoints and/or alarms) Fuel Handling Incident Radiation Monitors 3. Lowering of spent fuel pool level to (site-specific Level 2 value).

Refuel Floor High Range ARM Station #2(4).Fuel Pool Radiation Monitor Page 7 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AU2 Initiating Condition:

UNUSUAL EVENT UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:

All Example Emergency Action Levels: 1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following: (site-specific level indications).

AND b. UNPLANNED rise in area radiation levels as indicated by ANY of the following radiation monitors.(site-specific list of area radiation monitors)RU2 Initiating Condition:

UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): 1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following: " Refueling Cavity water level < 466 in. (Refuel Outage Reactor Vessel and Cavity Level Instrument LI 2(3)-263-114)

OR" Spent Fuel Pool water level < 19 ft. above the fuel (< 33 ft. 9 in.indicated level).OR" Indication or report of a drop in water level in the REFUELING PATHWAY.AND b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R1.E No Change [: Difference

[: Deviation 1) Listed site specific level indication and monitors to ensure timely classification.

Table RI Fuel Handling Incident Radiation Monitors I* Refuel Floor High Range ARM Station #2(4).Fuel Pool Radiation MonitorI Page 8 of 66 NEI 99-01 Rev 6 1 Proposed EAL [ Justification AA3 Initiating Condition

-ALERT Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2)Note: If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted 1. Dose rate greater than 15 mR/hr in ANY of the following areas:* Control Room* Central Alarm Station* (other site-specific areas/rooms)

2. An UNPLANNED event results in radiation levels that prevent or significantly impede access to any of the following plant rooms or areas: (site-specific list of plant rooms or areas with entry-related mode applicability identified)

RA3 Initiating Condition:

Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

1,2, 3, 4, 5,D Emergency Action Level (EAL): Note: If the equipment in the room or area listed in Table R3 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.

1. Dose rate> 15 mR/hr in ANY of the following Table R2 areas: E No Change D:1 Difference 1 Deviation 1) Listed site specific plant rooms and areas with identified mode applicability to ensure timely classification.

Table R2 Areas Requiring Continuous Occupancy" Main Control Room (Unit 2 ARM Station #22)" Central Alarm Station -(by survey)OR 2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the following Table R3 plant rooms or areas: Table R3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*

Modes 3, 4, and 5*Areas required to establish shutdown cooling Page 9 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU3RU3 I-- No Change Difference U Deviation Initiating Condition:

UNUSUAL EVENT Initiating Condition:

Reactor coolant activity greater than Technical Specification allowable limits. Reactor coolant activity greater than Technical Specification allowable limits. 1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

2) Listed this system category EAL in the radiological category EAL section to Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 maintain consistency with current and previous revisions of Exelon EALs. This will Example Emergency Action Levels: Emergency Action Level (EAL): ensure a timely classification since the threshold values are more aligned with the radiological category vice system category.1. (Site-specific radiation monitor) reading greater than (site-specific value). 1. Offgas system radiation monitor HI-HI alarm.OR OR 2. Sample analysis indicates that a reactor coolant activity value is greater than 2. Specific coolant activity > 4.0 uCilgm Dose equivalent 1-131.an allowable limit specified in Technical Specifications.

Page 10 of 66 0 0 0 NEI 99-01 rev 6 Fission Product Barrier Matrix_________________

Prdc Barrier________

Mari Hot__________

Ma FGI Loss of any two barriers AND Loss or Potential Loss of third barrier.1,2,3 FSI Loss or Potential Loss of ANY two barriers.1,2,3 FAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 1.2,3 FC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category Loss Potential Loss Loss Potential Losa Loss Potential Loss 1. RCS Activity / A. UNPLANNED rapid drop in primary A. Primary containment pressure greater 1.imar RCS (Sie scontainment pressure following than (site-specific value)Containment A. Primary containment Pressure primary containment pressure rise OR Pressure / reator coolant activity is greater None greater than (site-specific value) None OR B. (site-specific explosive mixture) exists than 300 uCilgm dose equivalent due to RCS leakage. inside primary containment Prmr -3)B. Primary containment pressure isd rmr otimn Containment response not consistent with LOCA OR Conditions conditions.

C. HCTL exceeded.A. RPV water level cannot be restored A. RPV water level cannot be A. Primary containment flooding and maintained above (site-specific restored and maintained above 2. RPV Water required.

RPV water level corresponding to (site-specific RPV water level None None A. Primary containment flooding required.Level top of active fuel) or cannot be corresponding to the top of active determined.

fuel) or cannot be determined.

A. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal OR A. UNISOLABLE primary system leakage A. UNISOLABLE break in any of the that results in exceeding EITHER of .Intentional primary containment 3.RCS Leak Rate/ following: ( site-specific systems with the following:

venting per EOPs Primary None None potential for high-energy line breas) 1. Max Normal Operating OR None Containment OR Temperature C. UNISOLABLE primary system Isolation Failure B. Emergency RPV DepressuizationOR leakage that results in exceeding 2. Max Normal Operating Area EITHER of the following:

Radiation Level. 1. Max Safe Operating Temperature.

OR 2. Max Safe Operating Area Radiation Level.4.Primary A. Primary Containment Radiation A. Primary Containment Radiation A. Primary Containment Radiation Monitor Containment Monitor reading greater than None Monitor reading greater than (site- None None reading greater than (site-specific Radiation (site-specific value), specific value). value).A. Any Condition in the opinion of A Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the 5. Emergency the Emergency Director that Emergency Director that indicates Emergency Director that indicates Loss Emergency Director the iniofte A.rAny Coedton in at indicates Loss Emergency Director that indicates Potential Director Judgment indicates Loss of the Fuel Clad Potential Loss of the Fuel Clad Barrier. of the RCS Barrier. Potential Loss of the RCS Barrier. of the Containment Barrier. Loss of the Containment Barrier.Barrier.Page 11 of 66 Proposed Fission Product Barrier Matrix Fission~~

ProducBarrirMatixHotMatri FGI Loss of any two barriers AND Loss or Potential Loss of third barrier.(1[]91A I FSS Loss or Potential Loss of ANY two barriers.E1IgA I PAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 19]9 FC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Categery Loss Potential Loss Loss Potential Lose Loss Potential Loss Coolant activity 300 uCligm Dose None None I RCS Activity Equivalent 1-131. None None None 2. RPV water level cannot be restored and 1. RPV water level cannot be restored and 1. Primary containment flooding is maintained , .143 inches (TAF) maintained

> -143 Inches (TAF) Prmary containment flooding is required.2. RPV Waler required OR OR None None eve 3. RPV water level cannot be determined.

2. RPV water level cannot be determined.

3. Drywell pressure _ 62 pslg and nsing.OR 1. Drywell pressure >2.0 psig. 1. UNPLANNED rapid drop in Drywell 4. a. Drywall or tows hydrogen concentration

3. Primary AND pressure following Drywell pressure rise ý 6%.Contaiment NnD OR AND on tainment None None 2. Drywall pressure rise is due to RCS None 2. Drywall pressure response not consistent

b. Drywell or tows oxygen concentration Prssure/Conditions leakage with LOCA conditions.

_5%.OR 5. Heat Capacity Limit (DEOP 200-1, Fig.M)exceeded.3. UNISOLABLE primary system leakage that 1. UNISOLABLE Main Steam Line results in EITHER of the following: (MSL),Isolation Condenser, HPCI. a. Secondary Containment area Feedweter, or RWCU line break. temperature 0 DEOP 300-1 Maximum 4.RCS Leak Rate None None OR Normal operating levels. Nose None ORRS eNonateNneNoeoRneO

2. Emergency RPV Depressuedzaon is b. Secondary Containment radiation level required.

> DEOP 300-1 Maximum Normal operating level.5,Primary Drywell radiation monitor reading Drywell radiation monitor reading Drywell radiation monitor reading Containment 0 6.70 E+02 R/hr (670 RIhr). None > 100R/hr (>1.00 E+02 R/hr). None None > 1.60 E+03 R/hr (1600 R/hr)Radiation 1. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal.OR 2. Intentional Primary Containment venting/purging per EOPs or SAGs due to accident conditions.

OR C. Primary 3. UNISOLABLE primary system leakage that Cnanet None None Nose None UNSLEENone sontainmen results in EITHER of the following:

ation Failure a. Secondary Containment area temperature s DEOP 300-1, Maximum Safe operating levels.OR b. Secondary Containment area radiation level s DEOP 300-1, Maximum Safe operating levels.7. Emergency A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. ANY Condition in the opinion of the A. Any Condition in the opinion of the A Any Condition in the opinion of the A. Any Condition in the opinion of the Emergency 7.Eergen Emergency Director that indicates Loss Emergency Director that indicates Potential Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss of the Director that indicates Potential Loss of the Director Judgment of the Fuel Clad Barrier. Loss of the Fuel Clad Barrier. the RCS Barrer. Loss of the RCS Barrier. Containment Barrier. Containment Banrer.Page 12 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FCi Category:

Fuel Clad BarrierC No Change Diffence Deviation RCS Activity RCS Activity 1 ) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. (Site specific indications that reactor coolant activity is greater than 300 uCi/gm Coolant activity > 300 uCllgm Dose Equivalent 1-131.dose equivalent 1-131)Page 13 of 66 NEI 99-01 Rev 6 Proposed EAL Justification FC2 Category:

Fuel Clad Barrier RPV Water Level Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Loss A. Primary containment flooding required.Potential Loss A. RPV water level cannot be restored and maintained above (site-specific RPV water level corresponding to top of active fuel) or cannot be determined.

Category:

Fuel Clad Barrier RCS Activity Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

Loss 1. Plant conditions indicate Primary Containment flooding is required.Potential Loss 2. RPV water level cannot be restored and maintained

> -143 inches (TAF)OR 4. RPV water level cannot be determined.

FC2[fl No Change 1 Difference 1 Deviation 1) Listed site-specific threshold value to ensure timely classification.

Page 14 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC4 Category:

Fuel Clad Barrier FC5 E No Change Difference Deviation Primary Containment Radiation Primary Containment Radiation

1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Primary Containment Radiation Monitor reading greater than (site-specific Drywell radiation monitor reading > 6.70 E+02 RWhr (670 R/hr).value).Page 15 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC6 Category:

Fuel Clad Barrier FC7 No Change Differene

[ Deviation Emergency Director Judgment Emergency Director Judgment Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier. the Fuel Clad Barrier.Poteritial Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential

2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier. Loss of the Fuel Clad Barrier.Page 16 of 66 NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01Rev 6 Proposed EAL Justification i RCI Category:

Reactor Coolant System Barrier Primary Containment Pressure Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Loss A. Primary containment pressure greater than (site-specific value) due to RCS leakage.RC3 Category:

Reactor Coolant System Barrier Primary Containment Pressure/Conditions Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

Loss 1. Drywell pressure >2.0 psig.AND 2. Drywell pressure rise is due to RCS leakage.E No Change 1 Difference 1 Deviation 1) Listed site-specific threshold value to ensure timely classification.

Page 17 of 66 NEI 99-01 Rev 6 RC2 Category:

Reactor Coolant System Barrier RPV Water Level Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Loss A. RPV water level cannot be restored and maintained above (site-specific RPV level corresponding to the top of active fuel) or cannot be determined.

Proposed EAL Justification RC2 Category:

Reactor Coolant System Barrier RPV Water Level Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

Loss 1. RPV water level cannot be restored and maintained

> -143 inches (TAF).OR 2. RPV water level cannot be determined.

No Change --' Difference 1 Deviation 1) Listed site-specific threshold value to ensure timely classification.

Page 18 of 66 NEI 99-01 Rev 6 Proposed EAL Justification RC R4l-Xi- NO Change II Difference II Deviation Category:

Reactor Coolant System Barrier Category:

Reactor Coolant System Barrier LECD.ei RCS Leak Rate RCS Leak Rate 1) Listed site-specific systems and threshold values to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. UNISOLABLE break in any of the following: ( site-specific systems with potential

1. UNISOLABLE Main Steam Line (MSL), Isolation Condenser, HPCI, Feedwater, for high-energy line breas) or RWCU line break.OR OR B. Emergency RPV Depressurization

2. Emergency RPV Depressurization is required.Potential Loss A. UNISOLABLE primary system leakage that results in exceeding EITHER of the Potential Loss following:

1. Max Normal Operating Temperature.

3. UNISOLABLE primary system leakage that results in EITHER of the following:

OR a. Secondary Containment area temperature

> DEOP 300-1 Maximum 2. Max Normal Operating Area Radiation Level. Normal operating levels.OR b. Secondary Containment area radiation level > DEOP 300-1 Maximum Normal operating levels.Page 19 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC4 Category:

Reactor Coolant System Barrier RC5 E No Change Difference Deviation Primary Containment Radiation Primary Containment Radiation 1 ) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Primary Containment Radiation Monitor reading greater than (site-specific Drywell radiation monitor reading > 100 R/hr (>1.00E+02 R/hr).value).Page 20 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC6 Category:

Reactor Coolant System Barrier RC7 No Change Difference Deviation Emergency Director Judgment Emergency director Judgment Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. ANY Condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier. the RCS Barrier.Potential Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier. 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Page 21 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CTI Category:

Containment BarrierC No Change Difference Deviation Primary Containment Conditions Primary Containment Pressure/Conditions 1 ) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

2) The words "and rising" were added to account for the momentary spike in Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 pressure where pressure is now lowering, the risk of a potential loss of containment is no longer present, this wording is also consistent with present EAL Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold, wording.Loss Loss C. UNPLANNED rapid drop in primary containment pressure following primary 1. UNPLANNED rapid drop in Drywell pressure following Drywell pressure rise.containment pressure rise OR OR 2. Drywell pressure response no._t consistent with LOCA conditions.

B. Primary containment pressure response not consistent with LOCA conditions.

Potential Loss Potential Loss D. Primary containment pressure greater than (site-specific value)OR 3. Containment pressure > 62 pslg and rising.E. (site-specific explosive mixture) exists inside primary containment OR OR 4. a. Drywell or torus Hydrogen concentration

> 6%.3. HCTL exceeded.

AND b. Drywell or torus Oxygen concentration

> 5%.OR 5. Heat Capacity Limit (DEOP 200-1, Fig. M) exceeded.Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT2 Category:

Containment Barrier CT2 No Change Difference

[-1 Deviation RPV Water Level RPV Water Level Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1 2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Potential Loss Potential Loss A. Primary containment flooding required.

Plant conditions indicate Primary Ccontainment flooding is required.Page 23 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CT3 CTS IN hne [ ifeec eito Category:

Containment Barrier Category:

Containment Barrier C No Change Difference Deviation Primary Containment Isolation Failure Primary Containment Isolation Failure 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. UNISOLABLE direct downstream pathway to the environment exists after 1. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal primary containment isolation signal.OR OR B. Intentional primary containment venting per EOPs 2. Intentional Primary Containment venting/purging per EOPs or SAMGs due to OR accident conditions.

C. UNISOLABLE primary system leakage that results in exceeding EITHER of the OR following:

3. UNISOLABLE primary system leakage that results in EITHER of the following:

1. Max Safe Operating Temperature.

a. Secondary Containment area temperature

> DEOP 300-1, Maximum OR Safe operating levels.2. Max Safe Operating Area Radiation Level. OR b. Secondary Containment area radiation level > DEOP 300-1, Maximum Safe operating levels.Page 24 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT4 Category:

Containment Barrier CT5 E No Change Difference Deviation Primary Containment Radiation Primary Containment Radiation

1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Potential Loss Potential Loss A. Primary Containment Radiation Monitor reading greater than (site-specific value). Drywall radiation monitor reading > 1.60 E+03 R/hr (1600 R/hr).Page 25 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CTS Category:

Containment Barrier CT7 No Change Difference

[] Deviation Emergency director Judgment Emergency Director Judgment Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier. the Containment Barrier.Potential Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier. 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Page 26 of 66 NEI 99-01 Rev 6 Proposed EAL Justification 301 MG1 l Initiating Condition:

GENERAL EMERGENCY Initiating Condition:

[Gj No Change LJ Difference

[j Deviation Prolonged loss of all offsite and all onsite AC power to emergency buses. Prolonged loss of all offsite and all onsite AC power to emergency buses.1) Listed site specific equipment, site specific time based on station blackout Operating Mode Applicability:

Operating Mode Applicability:

coping analysis, and site specific indication to ensure timely classification.

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Example Emergency Action Levels: Emergency Action Level (EAL): Note: The Emergency Director should declare the General Emergency promptly upon determining that (site-specific hours) has been exceeded, or will Note: likely be exceeded.

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses).1 Loss of ALL offsite AC power to unit ECCS buses.AND AND 2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel b. EITHER of the following:

generators to supply power to unit ECCS buses.AND" Restoration of at least one emergency bus in less than (site-specific hours) is not likely. 3. EITHER of the following:

a. Restoration of at least one unit ECCS bus in < 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not likely." (Site-specific indication of an inability to adequately OR remove heat from the core)b. RPV water level cannot be restored and maintained

> -164 inches.Page 27 of 66 0 NE199-01 Rev 6 Proposed EAL [Justification Initiating Condition:

SITE AREA EMERGENCY Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.MS1 Initiating Condition:

Loss of all offsite and onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC Power to unit ECCS buses.AND 2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators to supply power to unit ECCS buses.AND 3. Failure to restore power to at least one ECCS bus in < 15 minutes from the time of loss of both offsite and onsite AC power.M No Change FIDifference 1 Deviation 1) Listed site specific equipment to ensure timely classification.

Page 28 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification SA1I Initiating Condition:

ALERT Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Alert promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.1. a. AC power capability to (site-specific emergency buses) is reduced to a single power source for 15 minutes or longer.AND b. Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS.MA1I Initiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit ECCS buses reduced to only one of the following power sources for > 15 minutes.* Reserve auxiliary Transformer TR-22 (TR-32)* Unit auxiliary transformer TR-21 (TRý31)* Unit Emergency Diesel Generator DG 2(3)* Shared Emergency Diesel Generator DG 2/3* Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakers AND 2. ANY additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.M No Change ] Difference FIDeviation

1) Listed site specific equipment to ensure timely classification.

Page 29 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification Su1 Initiating Condition:

UNUSUAL EVENT Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15 minutes or longer MUl Initiating Condition:

Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to unit ECCS buses for > 15 minutes.F No Change -Difference 7 Deviation 1) Listed site specific equipment to ensure timely classification.

Page 30 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SG8 Initiating Condition:

GENERAL EMERGENCY Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the General Emergency promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses) for 15 minutes or longer.AND Indicated voltage is less than (site-specific bus voltage value) on ALL (site-specific vital DC buses) for 15 minutes or longer.MG2 Initiating Condition:

Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to unit ECCS buses.AND 2. Failure of DG 2(3), shared DG 2(3) and SBO DG 2(3) emergency diesel generators to supply power to vital buses.AND 3. Voltage is < 105 VDC on 125 VDC battery buses #2 and #3.AND 4. ALL AC and Vital DC power sources have been lost for> 15 minutes.1 '1 No Change M Difference 1-- Deviation 1) Listed site specific equipment to ensure timely classification.

2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.Page 31 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SS8 Initiating Condition:

SITE AREA EMERGENCY Loss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.Indicated voltage is less than (site-specific bus voltage value) on ALL Vital DC buses for 15 minutes or longer.MS2 Initiating Condition:

Loss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:

1,2,3 D] No Change F Difference FIDeviation

1) Listed site specific equipment and site specific value to ensure timely classification.

2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on 125 VDC battery buses #2 and #3 for >15 minutes.Page 32 of 66 NEI 99-01 Rev 6 [ Proposed EAL I Justification SS5 Initiating Condition:

SITE AREA EMERGENCY Inability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPV water level [BWR]) or RCS heat removal.Operating Mode Applicability:

Power Operation Example Emergency Action Levels: 1. a. An automatic (trip [PVVRj / scram [BVVR]) did not shutdown the reactor.AND b. All manual actions to shutdown the reactor have been unsuccessful.

AND c. EITHER of the following conditions exist: 1. (Site-specific indication of an inability to adequately remove heat from the core)OR 2. (Site-specific indication of an inability to adequately remove heat from the RCS)MS3 Initiating Condition:

Inability to shutdown the reactor causing a challenge to RPV water level or RCS heat removal.Operating Mode Applicability:

1,2 Emergency Action Level (EAL): 1. Automatic scram did not shutdown the reactor as indicated by Reactor Power> 6%.AND 2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 6%.AND 3. EITHER of the following conditions exist: " RPV water level cannot be restored and maintained

> -164 inches.OR" Heat Capacity Limit (DEOP 200-1, Fig. M) exceeded.D- No Change M Difference D Deviation 1) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scram Page 33 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA5 Initiating Condition:

ALERT Automatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:

Power Operation Example Emergency Action Levels: Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

I. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor.AND b. Manual action taken at the reactor control consoles are not successful in shutting down the reactor.MA3 Initiating Condition:

Automatic or manual scram fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:

1,2 Emergency Action Level (EAL): Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. Automatic or manual scram did not shutdown the reactor as indicated by Reactor Power > 6%.AND 2. Manual I ARI actions taken at the reactor control consoles are not successful in shutting down the reactor as indicated by Reactor Power > 6%.D- No Change FIDifference 1'1 Deviation 1) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scram Page 34 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification SU5 Initiating Condition:

UNUSUAL EVENT Automatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor.Operating Mode Applicability:

Power Operation Example Emergency Action Levels: (1 or 2)Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor.AND b. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.2. a. A manual scram ([PWR] / scram [BWR]) did not shutdown the reactor.AND b. EITHER of the following:

1. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.OR 2. A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor.MU3 Initiating Condition:

Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:

FH No Change M Difference 1 Deviation 1 ) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scram 1,2 Emergency Action Level (EAL): Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. a. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 6%..AND b. Subsequent manual / ARI action taken at the reactor control consoles is successful in shutting down the reactor.OR 2. a. Manual scram did not shutdown the reactor as indicated by Reactor Power > 6%.AND b. EITHER of the following:

1. Subsequent manual / ARI action taken at the reactor control consoles is successful in shutting down the reactor.OR 2. Subsequent automatic scram / ARI is successful in shutting down the reactor.Page 35 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA2 MA4 Initiating Condition:

ALERT UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Alert promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.[see table below][ SWR parameter list] [PWR parameter list]Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED event results in the inability to monitor ANY Table MI parameter from within the Control Room for >15 minutes.M No Change FIDifference FIDeviation Reactor Power Reactor Power RPV Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In Core/Core Exit Temperature Levels in at least (site specific Suppression Pool Level number) steam generators Steam Generator Auxiliary or Suppression Pool Temperature Emergency Feed Water Flow Table M1 Control Room Parameters" Reactor Power" RPV Water Level* RPV Pressure* Primary Containment Pressure* Torus Level* Torus Temperature AND 1 2. ANY Table M2 transient in progress.AND b. Any of the following transient events in progress.* Automatic or Manual runback greater than 25% thermal reactor power* Electrical load rejection greater than 25% full electrical load* Reactor Scram [BWR] / trip [PWR]* ECCS (SI) actuation* Thermal power oscillations greater than 10% [BWR]Table M2 Significant Transients" Turbine Trip" Reactor Scram" ECCS Activation" Recirc. Runback > 25% Reactor Power Change" Thermal Power oscillations

> 10% Reactor Power Change Page 36 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU2 Initiating Condition:

UNUSUAL EVENT UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.[see table below][BWR parameter list] [PWR parameter list]Reactor Power Reactor Power RPV Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In Core/Core Exit Temperature Levels in at least (site specific Suppression Pool Level number) steam generators Steam Generator Auxiliary or Suppression Pool Temperature Emergency Feed Water Flow MU4 Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.UNPLANNED event results in the inability to monitor ANY Table M1 parameter from within the Control Room for > 15 minutes.F] No Change FIDifference FIDeviation Table M1 Control Room Parameters

Reactor Power* RPV Water Level* RPV Pressure* Primary Containment Pressure* Torus Level Torus Temperature Page 37 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA9 MA6 Initiating Condition:

ALERT Initiating Condition:

ALERT IF1 No Change FX Difference F] Deviation Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: 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-specific hazards)* Other events with similar hazard characteristics as determined by the Shift Manager AND b. EITHER of the following:

1. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.OR 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:

1,2,3 Emergency 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 the Shift Manager AND 2. EITHER of the following:

a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specification for the current operating mode.OR b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specification for the current operating mode.1) No additional site specific hazard noted 2) Changed the word "needed" to "required" in the IC and to "required by Technical Specification" in the EAL, to be consistent with terminology used by operators and minimize confusion.

Page 38 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification SU4 Initiating Condition:

UNUSUAL EVENT RCS leakage for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage greater than (site-specific value) for 15 minutes or longer.2. RCS identified leakage greater than (site-specific value) for 15 minutes or longer 3. Leakage from the RCS to a location outside containment greater than 25 gpm for 15 minutes or longer MU6 Initiating Condition:

RCS leakage for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage in the Drywell > 10 gpm for> 15 minutes.OR 2. RCS identified leakage in the Drywell >25 gpm for> 15 minutes.OR 3. Leakage from the RCS to a location outside the Drywell >25 gpm for> 15 minutes.F-H No Change F IDifference FIDeviation 1 ) Listed site specific values to ensure timely classification.

2) Changed wording from containment to Drywell for clarity to better define the primary containment structure.

3) In EAL #1 and 2 added "into the Drywell' to differentiate between EAL #1/2 and#3. Without this wording would have been in EAL #1 or #2 concurrent with #3. With the added wording each EAL can be called separately.

Page 39 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification SUB Initiating Condition:

UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods: (site-specific list of communications method 2. Loss of ALL of the following ORO communications s) methods: (site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods: (site-specific list of communications methods)MU7 Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

1,2,3 H No Change F Difference F Deviation 1) Listed site specific communication methods to ensure timely classification.

Emergency Action Level (EAL): 1. Loss of ALLTable M3 Onsite communications capability affecting the ability to perform routine operations.

OR 2. Loss of ALL Table M3 Offsite communication capability affecting the ability to perform offsite notifications.

OR 3. Loss of ALL Table M3 NRC communication capability affecting the ability to perform NRC notifications.

Table M3 Communications Capability System Onsite Offsite NRC Plant Radio X Plant Page X Sound Powered Phones X All telephone Lines (Commercial and X X X microwave)

ENS X X HPN X X Satellite Phones X X Page 40 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA2 Initiating Condition:

ALERT Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling, Defueled Example Emergency Action Levels: Note: The Emergency Director should declare the Alert promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.CAI Initiating Condition:

Loss of all offsite and onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:

4,5, D Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to unit ECCS buses.AND 2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators to supply power to unit ECCS buses.AND 3. Failure to restore power to at least one unit ECCS bus in < 15 minutes from the time of loss of both offsite and onsite AC power.No Change 1 Difference 1 Deviation 1) Listed site specific equipment to ensure timely classification.

Page 41 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU2 CU1 -oCag -ifrne F- eito Initiating Condition:

UNUSUAL EVENT Initang Condition:No Change Difference Deviation Loss of all but one AC power source to emergency buses for 15 minutes or longer. Loss of all but one AC power source to emergency buses for 15 minutes or 1) Listed site specific equipment to ensure timely classification.

Operating Mode Applicability:

longer.Cold Shutdown, Refueling, Defueled Operating Mode Applicability:

Example Emergency Action Levels: 4,5, D Note: The Emergency Director should declare the Unusual Event promptly upon Emergency Action Level (EAL): determining that 15 minutes time has been exceeded, or will likely be exceeded.

Note: 1. a. AC power capability to (site-specific emergency buses) is reduced to a The Emergency Director should declare the event promptly upon determining that single power source for 15 minutes or longer, the applicable time has been exceeded, or will likely be exceeded.AND 1. AC power capability to unit ECCS buses reduced to only one of the b. Any additional single power source failure will result in loss of all AC following power sources for > 15 minutes.power to SAFETY SYSTEMS.

Reserve auxiliary Transformer TR-22 (TR-32)* Unit auxiliary transformer TR-21 (TR-31)* Unit Emergency Diesel Generator DG 2(3)* Shared Emergency Diesel Generator DG 2/3* Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakers AND 2. ANY additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.Page 42 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CAS Initiating Condition

-ALERT Hazardous event affecting SAFETY SYSTEM needed for the current operating mode.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: 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-specific hazards)" Other events with similar hazard characteristics as determined by the Shift Manager AND b. EITHER of the following:

1. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.OR 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.CA2 Initiating Condition:

Hazardous event affecting SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:

4,5 Emergency 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 the Shift Manager AND 2. EITHER of the following:

a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.OR b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.D No Change E Difference Deviation 1) No additional site specific hazard noted 2) Changed the word "needed" to "required" in the IC and to "required by Technical Specification" in the EAL, to be consistent with terminology used by operators and minimize confusion.

Page 43 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT Initiating Condition:

CU1 No Change Difference Deviation Loss of Vital DC power for 15 minutes or longer. Loss of Vital DC power for 15 minutes or longer. 1) Listed site specific voltage and equipment to ensure timely classification.

Operating Mode Applicability:

2) Removed the word "indicated" this will allow for an indication problem to not Cold Shutdown, Refueling 4, 5 cause confusion on the need to declare.Example Emergency Action Levels: Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Event promptly upon Note: determining that 15 minutes time has been exceeded, or will likely be The Emergency Director should declare the event promptly upon determining that exceeded, the applicable time has been exceeded, or will likely be exceeded.Indicated voltage is less than (site-specific bus voltage value) on required Vital DC buses for 15 minutes or longer.Voltage is < 105 VDC on required 125 VDC battery buses #2 and #3 for> 15 minutes.Page 44 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification CU5 Initiating Condition:

UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability:

Cold Shutdown, Refueling, Defuled Example Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods: (site-specific list of communications method 2. Loss of ALL of the following ORO communications s) methods: (site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods: (site-specific list of communications methods)CU4 Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

4,5, D Emergency Action Level (EAL): 1. Loss of ALL Table C1 Onsite communications capability affecting the ability to perform routine operations.

OR 2. Loss of ALL Table C1 Offsite communication capability affecting the ability to perform offsite notifications.

OR 3. Loss of ALL Table C1 NRC communication capability affecting the ability to perform NRC notifications.

Table Cl Communications Capability System Onsite Offsite NRC Plant Radio X Plant Page X Sound Powered Phones X All telephone Lines (Commercial and X X X microwave)

ENS X X HPN X X Satellite Phones X X E No Change D ] Difference 1 Deviation 1) Listed site specific communications methods to ensure timely classification Page 45 of 66 0 NEI 99-01 Rev 6 Proposed EAL Justification CA3 CAB Initiating Condition:

ALERT Initiating Condition:

E No Change Difference Deviation Inability to maintain the plant in cold shutdown.

Inability to maintain plant in cold shutdown.

1) Listed site specific Technical Specification cold shutdown temperature limit and Operating Mode Applicability:

Operating Mode Applicability:

site-specific pressure reading to ensure timely classification.

Cold Shutdown, Refueling 4, 5 Example Emergency Action Levels: (1 or 2) Emergency Action Level (EAL): Note: The Emergency Director should declare the Alert promptly upon Note: determining that the applicable has been exceeded, or will likely be exceeded.

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit) for greater than the duration specified in the following table. 1. UNPLANNED rise in RCS temperature>

212rF due to loss of decay 2. UNPLANNED RCS pressure increase greater than (site-specific pressure heat removal for > Table C2 duration.reading). (This EAL does not apply during water-solid plant conditions.

[PWRJ) Table C2 RCS Heat-up Duration Thresholds Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Duration RCS Status Containment Closure Heat-up Duration Status Status Intact Not Applicable 60 minutes*Intact (but not Established 20 minutes*RCS Reduced Not Applicable 60 minutes* Not Intact Inventory

[PWR]) Not Established 0 minutes Not Intact (or at Established 20 minutes' Not Established 0 minutes reduced inventory

-[PWR]) Not Established 0 minutes *If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not* If an RCS heat removal system is in operation within this time frame and applicable.

RCS temperature is being reduced, the EAL is not applicable.

OR 2. UNPLANNED RPV pressure rise > 10 psig as a result of temperature rise due to loss of decay heat removal.Page 46 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT CU3 Initiating Condition:

CU5 No Change Difference Deviation UNPLANNED increase in RCS temperature.

UNPLANNED rise in RCS temperature.

1) Listed site specific Technical Specification cold shutdown temperature limit Operating Mode Applicability:

Operating Mode Applicability:

to ensure timely classification.

Cold Shutdown, Refueling 4, 5 2) Changed the word increase to rise in the initiating condition to be consistent Example Emergency Action Levels: (1 or 2) Emergency Action Level (EAL): with operations language and training.Note: The Emergency Director should declare the Unusual Event promptly Note: upon determining that 15 minutes time has been exceeded, or will likely The Emergency Director should declare the event promptly upon determining be exceeded.that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit).2. Loss of ALL RCS temperature and (reactor vessel/RCS

[PWR] or RPV 1. UNPLANNED rise in RCS temperaturem>

212F due to loss of decay[BWR]) level indication for 15 minutes or longer. heat removal.OR 2. Loss of the following for >15 minutes." ALL RCS temperature indications AND" ALL RPV water level indications Page 47 of 66 0 NEI 9941 Rev 6 ] Proposed EAL Justification CGa Initiating Condition:

GENERAL EMERGENCY Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability:

Cold Shutdown.

Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the General Emergency promptly upon determining that 30 minutes time has been exceeded, or will likely be exceeded.1. a. (Reactor vessel/RCS

[P/R] or RPV [BWR]) vessel level less than (site-specific level) for 30 minutes or longer.AND b. ANY indication from the Containment Challenge Table 2. a.. (Reactor vessel/RCS

[PWR] or RPV [BW4R) vessel level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following:

(Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication

[P/R]* UNPLANNED increase in (site-specific sump and/or tank levels) of sufficient magnitude to indicate core uncovery* (Other site-specific indications)

AND c. ANY indication from the Containment Challenge Table).CG6 Initiating Condition:

Loss of RPV inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. RPV water level < -143 inches (TAF) for > 30 minutes.AND b. Any Containment Challenge Indication (Table C4)OR 2. a. RPV water level unknown for > 30 minutes.AND b. Core uncovery is indicated by ANY of the following:

Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Refuel Floor Hi Range ARM >3000 mR/hr.AND c. ANY Containment Challenge Indication (Table C4)LI No Change E Difference I: Deviation 1) Listed site specific levels, radiation monitors, and sumps and tanks to ensure timely classification.

2) Listed Explosive mixture in the Containment Challenge Table to ensure timely classification.

3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss Table: Containment Challenge Table* CONTAINMENT CLOSURE not established*

(Explosive mixture) exists inside containment

UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [BWR]if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.*Rise in level is attributed to a loss of RPV inventory.

Table C4 Containment Challenge Indications

Primary Containment Hydrogen Concentration

> 6% and Oxygen >5%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established*

ANY Secondary Containment radiation monitor > DEOP 300-1 Maximum Safe operating level.if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.Page 48 of 66 NEI 9901 Rev 6 Proposed EAL Justification CSI Initiating Condition:

SITE AREA EMERGENCY Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory affecting core decay heat removal capability.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 30 minutes time has been exceeded, or will likely be exceeded.1. a. CONTAINMENT CLOSURE not established.

AND b. (Reactor vessel/RCS

[PIVR] or RPV [BWR]) level less than (site-specific level).2. a. CONTAINMENT CLOSURE established.

AND b. (Reactor vessel/RCS

[PVAR] or RPV [BWR]) level less than (site-specific level).3. a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following: " (Site-specific radiation monitor) reading greater than (site-specific value)" Erratic source range monitor indication

[PWR]" UNPLANNED increase in (site-specific sump and/or tank levels) of sufficient magnitude to indicate core uncovery" (Other site-specific indications)

CS6 Initiating Condition:

Loss of RPV inventory affecting core decay heat removal capabilities.

Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. With CONTAINMENT CLOSURE not established, RPV water level<-60 inches OR 2. With CONTAINMENT CLOSURE established, RPV water level < -143 inches (TAF)OR 3. a. RPV water level unknown for > 30 minutes AND b. Core uncovery is indicated by ANY of the following: " Table C3 indications of a sufficient magnitude to indicate core uncovery.OR" Refueling Floor Hi Range ARM >3000 mR/hr.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.

D No Change E Difference 1 Deviation 1) Listed site specific values for level, radiation monitors, and sumps and tanks to ensure timely classification.

2) EAL #1 Dresden Station does not have a low, low, low RPV water level value stated within their Technical Specifications, all ESF functions come from the low, low value of -54 inches, NEI 99-01 rev 6 developer notes for CS1 request the developer to use the low, low, low value for declaration of a SAE when Containment Closure is not established, as such an RPV water level -60 inches was selected as the threshold value since it is substantially above TAF RPV water level of -143 inches and substantially below the low low value of -54.15 clearly indicating a worsening of the condition and the need to escalate the emergency from an Alert condition, 3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Page 49 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification CA1 Initiating Condition:

ALERT Loss of (reactor vessel/RCS

[PWR] or RPV [BWRJ) inventory Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Alert promptly upon determining that 15 minutes time has been exceeded, or witl likely be exceeded.1 Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory as indicated by level less than (site-specific level).2. a. (Reactor vessel/RCS

[PWR] or RPV [BVVR]) level cannot be monitored for 15 minutes or longer AND b. UNPLANNED increase in (site-specific sump and/or tank) levels due to a loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory.

CA6 Initiating Condition:

Loss of RPV inventory Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of RPV inventory as indicated by level < -54 inches.OR 2. a. RPV water level unknown for > 15 minutes.AND b. Loss of RPV inventory per Table C3 indications.

Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.

D- No Change E Difference El Deviation 1) Listed site specific levels, and sumps and tanks to ensure timely classification.

2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Page 50 of 66 0 NEI 99-01 Rev 6 Proposed EAL Justification Cu1 Initiating Condition:

UNUSUAL EVENT UNPLANNED loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory for 15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in (reactor vessel/RCS

[PWR] or RPV [BWR]) level less than a required lower limit for 15 minutes or longer.2. a. (Reactor vessel/RCS

[PIAR] or RPV [BWR]) level cannot be monitored.

AND b. UNPLANNED increase in (site-specific sump and/or tank) levels.CU6 Initiating Condition:

UNPLANNED loss of RPV inventory for 15 minutes or longer.Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in the inability to restore and maintain RPV water level above the procedurally established lower limit for > 15 minutes.OR 2. a. RPV water level unknown AND b. Loss of RPV inventory per Table C3 indications.

Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.

D No Change f Difference 1: Deviation 1) Described "a required lower limit" as a procedurally established lower limit, and listed site specific sumps and tanks to ensure timely classification.

2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Page 51 of66 NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL Justification 1 -1 HG1 HG1 Initiating Condition:

GENERAL EMERGENCY HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:

All Example Emergency Action Levels: 1. a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific security shift supervision).

AND b. EITHER of the following:

1. ANY of the following safety functions cannot be controlled or maintained.

Reactivity control* Core cooling [PWR] / RPV water level [BWR]RCS heat removal OR 2. Damage to spent fuel has occurred or is IMMINENT Initiating Condition:

HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:

1, 2, 3,4, 5, D Emergency Action Level (EAL): 1. A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.AND 2. a. ANY Table H1 safety function cannot be controlled or maintained.

OR b. Damage to spent fuel has occurred or is IMMINENT Table HI Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)F No Change M Difference 1 Deviation 1) List site security shift supervision as Security Force.2) Added descriptors to better explain each safety function and allow for a timely classification.

Page 52 of 66 NEI199-01 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL Justification HS1 HSI Initiating Condition:

SITE AREA EMERGENCY HOSTILE ACTION within the Protected Area.Operating Mode Applicability:

Initiating Condition:

HOSTILE ACTION within the Protected Area.Operating Mode Applicability:

1, 2, 3,4, 5, D No Change FIDifference

[IDeviation

1) List site security shift supervision as Security Force.All Example Emergency Action Levels: A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-security shift supervision).

Emergency Action Level (EAL): A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.Page 53 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification HA1 Initiating Condition:

ALERT HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2)1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the (site-specific security shift supervision).

2. A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.HA1 Initiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.Operating Mode Applicability:

1,2,3,4,5,D Emergency Action Level (EAL): 1. A validated notification from NRC of an aircraft attack threat < 30 minutes from the site.OR 2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.No Change -Difference

-Deviation 1) List site security shift supervision as Security Force.Page 54 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HUI HUIt Initiating Condition:

UNUSUAL EVENT Initiating Condition:

HUI No Change [j- Difference

[ Deviation Confirmed SECURITY CONDITION or threat.Confirmed SECURITY CONDITION or threat. 1) List site security shift supervision as Security Force.Operating Mode Applicability:

2) Further described credible security threat through listing a site specific Operating Mprocedure.

All 1, 2, 3,4, 5, D Example Emergency Action Levels: (1 or 2 or 3)Emergency Action Level (EAL): 1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the (site-specific security shift supervision).

1. Notification of a credible security threat directed at the site as determined per SY-AA-101-1 32, Security Assessment and Response to Unusual Activities.

2. Notification of a credible security threat directed at the site.OR 3. A validated notification from the NRC providing information of an aircraft 2. A validated notification from the NRC providing information of an aircraft threat, threat.OR 3. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.Page 55 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HS6 HS2 Initiating Condition:

SITE AREA EMERGENCY Initiating Condition:

H No Change I Difference FIDeviation Inability to control a key safety function from outside the Control Room. Inability to control a key safety function from outside the Control Room. 1) EAL uses the site specific Control Room evacuation procedure to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedure the Control Room would enter Operating Mode Applicability:

Operating Mode Applicability:

should such an event occur, this allows for greater clarity as to when this EAL would apply than if each panel and station used in alternate shutdown were to All 1,2, 3, 4, 5, D be listed, 2) Added descriptors to better explain each safety function and allow for a Example Emergency Action Levels: (1 and 2) Emergency Action Level (EAL): timely classification.

Note: The Emergency Director should declare the Site Area Emergency Note: promptly upon determining that (site-specific number of minutes) has 3) Changed "An event" to" A Control Room evacuation" to remove confusion if been exceeded, or will likely be exceeded.

The Emergency Director should declare the event promptly upon determining that the partial plant control was transferred to outside the control room with the control applicable time has been exceeded, or will likely be exceeded.

room still staffed, due to testing or equipment failure.1. An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control stations).

1 A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per DSSP 0100-CR, Hot Shutdown Procedure

-2. Control of ANY of the following key safety functions is not reestablished Control Room Evacuation.

within (site-specific number of minutes).

AND* Reactivity control 2. Control of ANY Table H 1 key safety function is not reestablished in < 15 minutes.Core cooling [PWtR] / RPV water level [BWR]* RCS heat removal Table HI Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Page 56 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA6 HA2 Initiating Condition:

ALERT Initiating Condition:

F No Change M Difference L-J Deviation Control Room evacuation resulting in transfer of plant control to alternate locations.

Control Room evacuation resulting in transfer of plant control to alternate locations.

1) EAL uses the site specific Control Room evacuation procedure to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedure the Control Room would enter should such an Operating Mode Applicability:

Operating Mode Applicability:

event occur, this allows for greater clarity as to when this EAL would apply than if each panel and station used in alternate shutdown were to be listed, All 1, 2, 3,4, 5,0D 2) Changed "An event" to" A Control Room evacuation" to remove confusion if partial plant control was transferred to outside the control room with the control Example Emergency Action Levels: Emergency Action Level (EAL): room still staffed, due to testing or equipment failure.An event has resulted in plant control being transferred from the Control Room to A Control Room evacuation has resulted in plant control being transferred from (site-specific remote shutdown panels and local control stations).

the Control Room to alternate locations per DSSP 0100-CR, Hot Shutdown Procedure

-Control Room Evacuation.

Page 57 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HU4 Initiating Condition:

UNUSUAL EVENT FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3 or 4)Note: The Emergency Director should declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. A FIRE is NOT extinguished within 15-minutes of ANY of the following 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 alarm AND b. The FIRE is located within ANY of the following plant rooms or areas: (site-specific list of plant rooms or areas)2. a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).AND b. The FIRE is located within ANY of the following plant rooms or areas: (site-specific list of plant rooms or areas)AND c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.3. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.

4. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

HU3 Initiating Condition:

M No Change I Difference I Deviation Listed site specific list of plant rooms or areas that contain SAFETY SYSTEM equipment to ensure timely classification.

FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:

1,2.3,4, 5, D Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of the following 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 alarm Table H2 Vital Areas* Reactor Building (when inerted the Drywell is exempt)* Aux Electric Room* Control Room* Unit and Shared Emergency Diesel Generator Rooms* 4KV ECCS Switchgear Area (includes Bus 23, 24, 33 and 34 only)* CRD & CCSW Pump Rooms* Turbine Building Cable Tunnel* Turbine Building Safe Shutdown Areas as follows:* B- Train Control Room HVAC Room* Battery Rooms and DC Distribution Areas 1) U2 Battery Room (includes DC switchgear, 125V, and 250V battery rooms)2) U3 Battery Room, Battery Cage area, and U3 Battery Charger Room (all on U3 TB 538)* Crib House OR 2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).AND b. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR 3. A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.

OR 4. A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

Page 58 of 66 0 NEI 99.01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT HU2 Initiating Condition:

HU4 D No Change M Difference F Deviation Seismic event greater than OBE levels. Seismic event greater than OBE levels. 1) Used Alternate developer notes allowed wording since specific Control Room indication of a seismic event > OBE is not available.

Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels: Emergency Action Level (EAL): Seismic event greater than Operating Basis Earthquake (OBE) as indicated by: a. (site-specific indication that a seismic event met or exceeded OBE limits) 1. Control Room personnel feel an actual or potential seismic event.AND 2. The occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager or Emergency Director.Page 59 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA5 HAm Initiating Condition:

ALERT Initiating Condition:

LFI No Change [-1 Difference

[:1 Deviation Gaseous release impeding access to equipment necessary for normal plant Gaseous release impeding access to equipment necessary for normal plant operations, 1) Listed plant specific rooms and areas with entry related mode applicability to operations, cooldown or shutdown.

cooldown or shutdown, ensure timely classification.

Operating Mode Applicability:

All 1,2,3,4, 5, D Example Emergency Action Levels: Emergency Action Level (EAL): Note: If the equipment in the listed room or area was already inoperable, or out Note'of service, before the event occurred, then no emergency classification is warranted.

If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.

1. a. Release of a toxic, corrosive, asphyxiant or flammable gas into any of the following plant rooms or areas: 1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.(site-specific list of plant rooms or areas with entry-related mode applicability identified)

Table H3 Areas with Entry Related Mode Applicability AND Area Entry Related Mode Applicability

b. Entry into the room or area is prohibited or impeded. Reactor Building*

Modes 3, 4, and 5*Areas required to establish shutdown cooling AND 2. Entry into the room or area is prohibited or impeded Page 60 of 66 S 0 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT Hazardous Event Operating Mode Applicability:

HU3 All Example Emergency Action Levels: (1 or 2 or 3 or 4)Note: EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

I. A tornado strike within the PROTECTED AREA.Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode.3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).4 A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.5. (Site-specific list of natural or technological hazard events)HU6 Initiating Condition:

Hazardous Event Operating Mode Applicability:

1, 2, 3,4,5, D Emergency Action Level (EAL): Note: EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

1. Tornado strike within the PROTECTED AREA.OR 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode.OR 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).OR 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.OR 5. Abnormal River level, as indicated by EITHER: a. High river level > 509 ft.OR b. Low river level < 501 ft. 6 inches.F] No Change FIDifference

[- Deviation 1) Added Abnormal River level to list of natural or technological hazard events.The high river level of 509 ft was selected since it is the lowest opening leading to safety related equipment, and the love river level of 501 ft 6 in was selected since this is the most limiting pump suction requirement(CCSW pumps)2) Changed the word "needed" to "required by Technical Specifications" in the EAL to be consistent with terminology used by operators and minimize confusion.

Page 61 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HG7 HG7 -Initiating Condition:

GENERAL EMERGENCY Initiating Condition:

LhI No Change LJ Difference FIDeviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency.

declaration of a General Emergency.

Operating Mode Applicability:

All 1,2, 3, 4, 5, D Example Emergency Action Levels: Emergency Action Level (EAL): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT Other conditions exist which in the judgment of the Emergency Director indicate substantial core degradation or melting with potential for loss of containment that events are in progress or have occurred which involve actual or IMMINENT integrity or HOSTILE ACTION that results in an actual loss of physical control of substantial core degradation or melting with potential for loss of containment the facility.

Releases can be reasonably expected to exceed EPA Protective Action integrity or HOSTILE ACTION that results in an actual loss of physical control of Guideline exposure levels off-site for more than the immediate site area. the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area..Page 62 of 66 NEI 99-01 Rev 6 Proposed EAL Justification H37 HS7 mm Initiating Condition:

SITE AREA EMERGENCY

' Initiating Condition:

[Sj No Change [j Difference Li Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency.

declaration of a Site Area Emergency.

Operating Mode Applicability:

All 1,2, 3,4, 5, D Example Emergency Action Levels: Emergency Action Level (EAL): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major Other conditions exist which in the judgment of the Emergency Director indicate failures of plant functions needed for protection of the public or HOSTILE ACTION that events are in progress or have occurred which involve actual or likely major that results in intentional damage or malicious acts; (1) toward site or failures of plant functions needed for protection of the public or HOSTILE ACTION equipment that could lead to the likely failure of or; (2) that prevent effective that results in intentional damage or malicious acts; (1) toward site personnel or access to equipment needed for the protection of the public. Any releases are not equipment that could lead to the likely failure of or; (2) that prevent effective expected to result in exposure levels which exceed EPA Protective Action access to equipment needed for the protection of the public. Any releases are not Guideline exposure levels beyond the site boundary o expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Page 63 of 66 NEt 99-01 Rev 6 Proposed EAL Justification HA? HA7 Initiating Condition:

ALERT Initiating Condition:

L7 E No Change LJ1 Difference

[J Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert. declaration of an Alert.Operating Mode Applicability:

Operating Mode Applicability:

All 1,2, 3,4, 5, D Example Emergency Action Levels: Emergency Action Level (EAL): Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an actual or potential that evnts e in phe ourred wh e an actor pntial substantial degradation of the level of safety of the plant or a security event that that events are in progress or have occurred which involve an actual or potential involves probable life threatening risk to site personnel or damage to site substantial degradation of the level of safety of the plant or a security event that equipment because of HOSTILE ACTION. Any releases are expected to be involves probable life threatening risk to site personnel or damage to site limited to small fractions of the EPA Protective Action Guideline exposure levels, equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Page 64 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HU7 HU7 mmF Initiating Condition:

UNUSUAL EVENT Initiating Condition:

[Uj No Change [j Difference

[j Deviation Other conditions existing which in the judgment of the Emergency director warrant declaration of an UNUSUAL EVENT. Other conditions existing which in the judgment of the Emergency director warrant declaration of an UNUSUAL EVENT.Operating Mode Applicability:

Operating Mode Applicability:

All 1, 2, 3,4, 5, D Example Emergency Action Levels: Other conditions exist which in the judgment of the Emergency Director indicate Emergency Action Level (EAL): that events are in progress or have occurred which indicate a potential Other conditions exist which in the judgment of the Emergency Director indicate degradation of the level of safety of the plant or indicate a security threat to facility that events are in progress or have occurred which indicate a potential protection has been initiated.

No releases of radioactive material requiring offsite degradation of the level of safety of the plant or indicate a security threat to facility response or monitoring are expected unless further degradation of safety systems protection has been initiated.

No releases of radioactive material requiring offsite occurs. response or monitoring are expected unless further degradation of safety systems occurs.Page 65 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT E-HUI Initiating Condition:

E-HUI H No Change F Difference FIDeviation Damage to a loaded cask CONFINEMENT BOUNDARY.Damage to a loaded cask CONFINEMENT BOUNDARY.

1) Listed 2x the site specific cask specific allowable radiation level as per Operating Mode Applicability:

Certificate of Compliance No. 1014 Appendix A, Section 5.7 (WEST HI-STORM), Operating Mode Applicability:

Certificate of Compliance No. 1014 Appendix A, Section 3.2.3 (EAST HI-STORM), and Certificate of Compliance No. 1008 Appendix A, Amendment 2, Section All 1 2.2.1 (EAST HI-STAR)1, 2,3,4, 5, D Example Emergency Action Levels: Emergency Action Level (EAL): Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-technical specification allowable radiation level) on the surface of the spent fuel contact radiation reading: cask.1. EAST HI-STAR:* > 160 mrem/hr (neutron + gamma) on the top of the Overpack OR* > 250 mremlhr (neutron+

gamma) on the side of the Overpack OR 2. EAST HI-STORM:* > 20 mremlhr (neutron+

gamma) on the top of the Overpack OR* >100 mremlhr (neutron+

gamma) on the side of the Overpack OR* > 45 mremlhr (neutron+

gamma) at the inlet and outlet vent ducts of the Overpack OR 3. WEST HI-STORM:* > 40 mrem/hr (neutron+

gamma) on the top of the Overpack OR* >100 mremnhr (neutron+

gamma) on the side of the Overpack, excluding inlet and outlet ducts Page 66 of 66 Dresden Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARG1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRremn TEDE or 5000 mRfem thyroid CDE.Operating Mode Applicability:

1,2,3, 4,5, D Emergency Action Level (EAL): Notes:* The Emeraency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* Tho Em......Y r-ocr..e-shnould dlar the 9Vr-t prom.ptly upon ae9torm. 1Inng atM Me appnc~a~Io mime has seen oXceepep, Or Will Wieiy me oxcocaca." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.I

The pre-calculated effluent monitor values presented in EAL_#1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

(1) Reading on ANY of the following radiation monito-s greater than the reading Shown fo.r 15 minutes , o longeir (site-specific monitor list and threshold v:alues)1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs > 7.90 E+09 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond (Site-sf08fiG dose rec.Ptor voint) the site boundary of EITHER: a. > 1000 mRem TEDE OR b. > 5000 mRem CDE Thvroid.. .................

... * ....Month 20XX DR 3-1 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS OR/'%1 -- -- J __ --I .... =JI ...... L--AL ---- d ----IJ't L---CAesed windew dese Fates weafeF !RaA JWWW FnKERF eXPeGlecl 19 GGRURUe-fGF 60t m **tesr. a.. nmr trr- &L--- ff tff%for AMo hour of inhalaion.

3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >1000 mRlhr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.

Basis: This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases.

Releases of this magnitude will require implementation of protective actions for the public.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1000 mR-em while the 5000 mRfem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.enviroenment is, ostablished.

If thc Afflucnt.

floW past an effluent monitor is known to hav stopped due to Wcions to iselate the roleaso path, thenA the efletmoio eading is no longer valid for class-ification purposes-.

Month 20XX DR 3-2 EP-AA-1004 (Revision XX)

Nuclear Dresden AnnexA Exellnn Nuclea~r RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis Reference(s):

1. NE1 99-01 Rev 6, AG1 2. EP-AA-1 12-500 Emergency Environmental Monitoring

3. ODCM Section 12.4 Gaseous Effluents and Total Dose 4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From the Unit 2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using the Eberline Control Terminal 5. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Dresden Station 6. DEOP 300-2, Radioactivity Release Control Month 20XX DR 3-3 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARS1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 100 mR-em TEDE or 500 mRem thyroid CDE.Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): Notes: 9 The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.II I I l l9 no immcr1Aonc WIrccoF cnouiaI aociare the Site Area EmoreAon even; or-oAmpl V d !I roll I*1 I I I m s I iI a al la I I ew I I iinnn ru~tnrmininn Tn~t mA ~nnhlr~flIA timn flap flnfln nYr'nnCinri nr w'n IlkAl'.! nn-........-....--

I-.E-,..---.-..-----..-~~------,-....

e xGeeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

14 E3. .4;A r AK $V a ý' $ka aI a. nn A;a a .n4artnaaa.

ka k a naka.i t-et " "" ....W. .. M M-M-W". M.W. -_. -_ ._. .- .__1 10 01 Mrvvrl I -"IMI-1 1117 tbutti buldrdaimu WHWHOtidF Hbt dwou twMiUbMAU YtHutot" (2) Dose ass.essmnt using actumial meteorology dos.... greater than 100 mrcm~ TEDE Or 600 FArom thyroi cl DE, at or beyond (sito spocific dote recepto (3) Field cun.'oy results ind-icate EITHER Of the folloWing at Or beyond (sito specific_doe r..et point).: " Closed window dose rates greater- than 100 ffd4A expected to continue for 60 fpnutes or- longer-" Analyses of field survey samples indieate thyroid CDE greater- than 500 mrwem for- one hour of inhalation.

Month 20XX DR 3-4 EP-AA-1004 (Revision XX)

Dresden Annex Exellon Nuclear Dresden Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 3. 1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs > 7.90 E_.8 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 100 mRem TEDE OR b. > 500 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >100 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.

Basis: This IC addresses a release of gaseous radioactivity that results in projected or actual offsite 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 are associated 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 and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1000 mR-em while the 500 mR-em thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Claccification based on offluent moneitor reading~s assumos that. a release path t tho enyirnment is ,stablished.

if the effu,,t flo past an effluent .m"noter is known to have stopped due to actions to isolate the release path, then the effluent moni;tor reading is no lonecr valid fo classificatio' uoss Month 20XX DR 3-5 EP-AA-1004 (Revision XX)

Dresden Annex Exellon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Escalation of the emergency classification level would be via IC RAG1.Basis Reference(s):

1. NEI 99-01 Rev 6, AS1 2. EP-AA-1 12-500 Emergency Environmental Monitoring

3. ODCM Section 12.4 Gaseous Effluents and Total Dose 4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From the Unit 2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using the Eberline Control Terminal 5. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Dresden Station 6. DEOP 300-2, Radioactivity Release Control Month 20XX DR 3-6 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA1 Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRferm TEDE or 50 mRem thyroid CDE.Operating Mode Applicability:

1,2, 3, 4,5, D Emergency Action Level (EAL): Notes: " The Emerqency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded." Tho Emnergency Diroctor should declare tho Alert event promptly upon detormining that the applicab-le ti~me h-as boon oxceoedod, Or Will likely be exne-ed-ed-." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

for 15 mninutesO or loger: (site-specific_

monitor list and threshold

'..aluois)

(2) Dose assessment using actual mcetoorolegy indicates doses greater than 1 Omrom TEDE or 50 mrom thyroid CDE at Or beyond (cite. c..ific dose reecptor DnOW).(3) A~naly'sis of a liquid effluent sample indicates, a Goncentrtien or release rate that would result in doses greater than 10 Qmem TEDE Sor 50 rnrorn thyroid ODE ato beyond (site-spocific dose receptor point) for one hour of exposure (4) Field sur.'oy results indicate EITHER of the following atGorbeyond (site spccific dose receptor point):-*l*.e.. wind. w c.ose .ate. greater- thant L0 .. ..expected to continue or o6 .miutes or longefn* .o* Analyses et field sur.'ey samulies indicate thyroidI CDE ercater- than ;)U mfemn tor on hour- of inhalation.

Month 20XX DR 3-7 EP-AA-1 004 (Revision XX)

Annex I:xAIon Nuclear Drescln Annex Exelon NulewIar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+07 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 10 mRem TEDE OR b. > 50 mRem CDE Thwroid OR 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary a. 10 mRem TEDE for 60 minutes of exposure OR b. 50 mRem CDE Thyroid for 60 minutes of exposure OR 4. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.

Month 20XX DR 3-8 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear Dresden Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Basis: This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual 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 this magnitude represent an actual or potential substantial degradation of the level of safety of the 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 and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1000 mRrem while the 50 mR-erm thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Classification based on effluent mnonitor readings assumes that a roloaso path t the enyironmont.

is- establoishecd.

If t~he efflu-ent flowA patafflluent mon8itor is known t havestoped duo to- act~ionsn to soat the release path, then the effluent monitor reading is no longer valid for classificatio pupoes Escalation of the emergency classification level would be via IC RASi.Basis Reference(s):

1 .NEI 99-01 Rev 6, AA1 2. ODOM Section 12.3 Liquid Effluents 3. ODCM Section 12.4 Gaseous Effluents 4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From the Unit 2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using the Eberline Control Terminal 5. UNIT 2/3 DAN 2223-6 A-12 "2/3 RADWASTE DISCHARGE HIGH RADIATION" 6. UNIT 2/3 DOP 2000-110, Radioactive Waste Discharge to River With the Off-Stream Liquid Effluent Monitor Operable 7. UNIT 2/3 DOP 2000-109, Waste Surge Tank Batching for a Radwaste River Discharge 8. Structural Drawing B-01A Composite Site Plan Dresden Station Units 1, 2 & 3 9. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Dresden Station 10. DEOP 300-2, Radioactivity Release Control 11. EP-EAL-0620 Revision 0, Dresden Criteria for Choosing Radiological Liquid Effluent EAL Threshold Values Month 20XX DR 3-9 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARMl Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODOM (eite-speGifie effluent rolcase conroll1ing document) limits for 60 minutes or longer.Operating Mode Applicability:

1, 2,3,4,5, D Emergency Action Level (EAL): Notes: 0 The Emeraencv Director should declare the event D~romotlv upon determining that the appIlicable time has been exceeded, or will likely be exceeded.0 noe LmorA8ency wirector GAnoula aciare mne unusual tyeni event prompily upon-j- j--- :11 1:1-1.. --A* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.(1) Reading on ANY effluent radiation mon;itor gr-eater than 2 times the (site speciific effluent release conroll1ing documnent) limitS for 60 mninuter, or longer:.(site-specific-monitor list and thre~shold-vsalues corresponding to 2 timer, the controlling document limtits)(2) Reading on ANY effluent radiation moni~tor greater than 2 times the alarm setpon established by a current radioactivity disch-arge oormit for 60 minutes Or 'OgR.'% rn ^ ^ n ^ C- 11 ^ r 1ý -ARIagZaUR er I i r^ A" ARIAR ý fn f%jqLqgq r rpip -pfiq rgq+gr +knn 0 Crypp, +km !,,O+r%-,-

pe,;f 6, pff h i^n+ ^rAn+rplion docu montl lomite for 60 min-utAR~

or lonnoer zi 1. Readina on any of the followina effluent monitors > 2 times alarm setooint established by a current radioactive release discharge permit for 2t 60 minutes." Radwaste Effluent Monitor 2/3-2001-948 OR" Discharae Permit Soecified monitor OR Month 20XX DR 3-10 Mont 2OX DR -10EP-AA-1 004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 2. The sum of readings on the Unit 2/3 Rx BIdg and Unit 2/3 Chimney SPINGs > 9.02 E+05 uCi/sec for > 60 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).HVAC and SGTS- Radiation Moitr-rs;.1706 (1.17 ntro-l room Panels -OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.Basis: This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release).

It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases.

The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Claaessific-atione.

basoed on effluent monitor roadingc assumes that a reloase patht the onvironment is established.

If. the effluont flow past an effluent monitor is. known~ to have stopped due to actions to isolate tho roloaso path, then the effluent monitor reading is no Inger valid for clai purp9seG-.

Releases should not be prorated or averaged.

For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.EAL #1 Basis EAL-#2-- This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathwavs (e.g.. radwaste.

waste gas).The effluent monitors listed are those normally used for planned discharges.

If a discharge is performed using a different flowpath or effluent monitor other than those listed (e.g., a portable or temporary effluent monitor), then the declaration criteria will be based on the monitor specified in the Discharge Permit.EAL #2 Basis Month 20XX DR 3-11 EP-AA-1004 (Revision XX)

N.nlAar flmpaitn Annpx ExelInn Nnnvlasar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS EAL-#1----This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous e,-iq;id -effluent pathways.EAL #3 Basis EAL--#3---This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Escalation of the emergency classification level would be via IC RAA1.Basis Reference(s):

1. NEI 99-01 Rev 6, AU1 2. ODCM Section 12.3 Liquid Effluents 3. ODCM Section 12.4 Gaseous Effluents 4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From the Unit 2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using the Eberline Control Terminal 5. UNIT 2/3 DAN 2223-6 A-12 "2/3 RADWASTE DISCHARGE HIGH RADIATION" 6. UNIT 2/3 DOP 2000-110, Radioactive Waste Discharge to River With the Off-Stream Liquid Effluent Monitor Operable 7. UNIT 2/3 DOP 2000-109, Waste Surge Tank Batching for a Radwaste River Discharge 8. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Dresden Station 9. DEOP 300-2, Radioactivity Release Control Month 20XX DR 3-12 EP-AA-1004 (Revision XX) nroarhn Annov PIrglr~n khio RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA2 Initiating Condition:

Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:

1, 2,3,4,5, D Emergency Action Level (EAL): (1) Unco'voy of irr-adi-iatd fuel in the REFUELING PATHWAY.(2) Damage to irradiated fuel resultiRg in a roloaso of radI-o-activity fro-R the ;in;ated by ANY of th lin ation monirs: (sito spocific, listing of radiation moenito-rs, and tho associatod readings, setpoints andwor alarmsA)(3) LowriI ng of spent fuel pool love! to Levol 2 value). [See Developei e Uncovery of irradiated fuel in the REFUELING PATHWAY.OR* Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R1 Radiation Monitor readinq >1000 mRem/hr Table R1 Fuel Handling Incident Radiation Monitors" Refuel Floor High Range ARM Station #2(4)" Fuel Pool Radiation Monitor Basis: REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.IMMINENT:

The traiectorv of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.CONFINEMENT BOUNDARY:

The irradiated fuel dry storage cask barrier(s) between areas containina radioactive substances and the environment.

Month 20XX DR 3-13 EP-AA-1004 (Revision XX)

AnnAY FyAInn frpqripn Annpx Fvplnn Nmir-Iapar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly., or- a ig. .niiant l.o.ing of wat.r lovel w.,hin the spent fu,, pool (sco Dov...r. .Notes). -These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment.

As such, they represent an actual or potential substantial degradation of the level of safety of the plant.This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1.~eea4at~onOTm oogooywui O aoaonotnr1-ocgito iaoqr;: o Ic V v EAL #1 Basis EAL-#1 This EAL escalates from RAU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters.

Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

While an area radiation monitor could detect an in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered.

To the degree possible, readings should be considered in combination with other available indications of inventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.EAL #2 Basis EAL-#2 This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly.

Soent fuel uncovery represents a maior ALARA concern in that radiation levels could exceed 10,000 R/hr on the refuel bridge when fuel uncovery begins. The value of 1000 mR/hr was conservatively chosen for classification purposes.

A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).

Escalation of the emergency would be based on either Recognition Category RA-or C ICs.Month 20XX DR 3-14 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 9AL #3 Spent ful. pool water l at this value Or, wthin the lower end of the level Fang necossary to prevent significant dose conseguoncos, from dierect gamma radiation to porsonnei porferming operatione in the Vicinit,'

Of the spent fuel pool. This conditio roflects a significant loss of spent fuel pool water invontory and thus it. iss alsoe a precurFso to a less of the ability to adequately cool the ifradiate" fu1l asese~mblcc Mtore d in the pool.Er.calation of the emergency classification level would be '.ia I~s AS! Or AS2 (see AS Dovelopr-ANoes).Basis Reference(s):

1 .NEI 99-01 Rev 6, AA2 2. DAN 902(3)-3 C-1 6(E-1 6) Reactor Building Fuel Pool Hi Radiation 3. DAN 902(3)-3 B-i Refuel Floor Hi Radiation 4. DAN 902(3)-3 A-3(F-1 4) Reactor building Vent Hi-Hi Radiation 5. UFSAR 9.1 6. DAN 902(3)-4 D-24 Fuel Peel Skimmer Tank Level Lo 7. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation

8. DFP 0850-01 Water Level Loss in SEP or Cavity 9. DOP 1900-03 Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool Level Control Month 20XX DR 3-15 EP-AA-1004 (Revision XX)

Dry.dAn Annex Drvvden Annex Evelon Nule Iasr RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARU2 Initiating Condition:

UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:

1,2, 3, 4, 5, D Emergency Action Level (EAL): I14\ I INIDI I~ I ,-v, , .~ lrr ;n skn D~rl:I I1:I INt"f- DATI.JIAIAV n- I; te by ANY of the followinei:v (sitoe-socific level indications).

AND b. U1 IPI-AN.'NE'6 D io in as o rdiation lovls. ;as indicated by ANY of the_ !--I .. .... !1_ __\(Rtsn-pd1 RDOII unof area radatiaon mrontirel'-...- r" ...... ... ..... ..1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following: " Refueling Cavity water level < 466 in._(Refuel Outage Reactor Vessel and Cavity Level Instrument LI 2(3)-263-114)

OR* Spent Fuel Pool water level < 19 ft. above the fuel (< 33 ft. 9 in.indicated level).OR" Indication or report of a drop in water level in the REFUELING PATHWAY.AND b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table RI.Table R1 Fuel Handling Incident Radiation Monitors" Refule Floor High Range ARM Station #2(4)* Fuel Pool Radiation Monitor Month 20XX DR 3-16 EP-AA-1004 (Revision XX) nroadon Annoy E=xalnn flm~dAn Ann~v Fv~Inn Nsir~I~~ar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis: UNPLANNED:

A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.REFUELING PATHWAY: all the cavities, tubes, canals and pools throuqh which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.This IC addresses a deeeease-loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.I A water level deGrease-loss will be primarily determined by indications from available level instrumentation.

Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available) or from any other temporarily installed monitoring instrumentation.

A significant drop in the water level may also cause aa iner-easerise in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered.

For example, a refueling bridge area radiation monitor reading may inereaserise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly.

Note that this EAL is applicable only 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 in accordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RAA2.Basis Reference(s):

1. NEI 99-01 Rev 6, AU2 2. RP-AA-203 Exposure Control and Authorization

3. Technical Specifications 3.7.8 4. Technical Specifications 3.9.6 5. UFSAR 9.1 6. DAN 902(3)-4 D-24 Fuel Pool Skimmer Tank Level Lo 7. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation

8. DFP 0850-01 Water Level Loss in SFP or Cavity Month 20XX DR 3-17 EP-AA-1004 (Revision XX)

Dresden Annex Exellon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 9. DOP 1900-03 Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool Level Control 10. DGP 02-02, Reactor Vessel Slow Fill 11. DAN 902(3)-3 C-1 6(E-1 6) Reactor Building Fuel Pool Hi Radiation 12. DAN 902(3)-3 B-1 Refuel Floor Hi Radiation 13. DAN 902(3)-3 A-3(F-14)

Reactor building Vent Hi-Hi Radiation Month 20XX DR 3-18 EP-AA-1 004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA3 Initiating Condition:

Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

1,2,3, 4,5, D Emergency Action Level (EAL): Note: 9 If the equipment in the listed-room or area listed in Table R3 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted/IN ^^o% r£1r% re% +^r fk., 1 A rnr2/%r On AIlV +kA U ,r. .\ ' I ,--v,.,v , to ---.-W" Cntrol Room." Central A4arm Statiea" (other- site specific afeask/rooms)OA hd ;i MR UNPr6ANIM eventL iU.uIlt II Fin aIRIIiIIR

.lev 11Ui AFOIUKILI O[ UIMM99U aGUeL ;9 I any of the following plant roome6 Or aroac:-;J[:-- --J[--I----x

.......isne speemTI liiT of DIflT F9oomS OF Warc WI1!RenR:

reF0aioo monoe aooiicantii ideRtified)

...... I" ..............

..~... 1....... I- r-.. .J e Dose rate than> 15 mR/hr in ANY of the followina areas: Table R2 Areas Requiring Continuous Occupancy* Main Control Room (Unit 2 ARM Station #22)* Central Alarm Station -(by survey)OR* UNPLANNED event results in radiation levels that prohibit or significantly impede access to any of the following plant rooms or areas: Month 20XX DR 3-19 EP-AA-1004 (Revision XX)

I=yAIon Nuelmar rnmnden Annex Exelon Nuclarw RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Table R3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*

Modes 3, 4, and 5*Areas required to establish shutdown cooling Basis: UNPLANNED:

A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to transition the Plant from normal plant operation to cooldown and shutdown as specified in normal plant proceduresmaintain normal plant operation, Or to perFo-m a normal plant .o.ldown and h,-tdew,-.

As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine if another IC may be applicable.

Table R3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown.

This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the elevated radiation levels preclude the ability to place shutdown cooling in serviceat the time of tho olo'eatod radiation levols. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding beyond that required by procedure, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply.Month 20XX DR 3-20 EP-AA-1004 (Revision XX) l=yRlnn frmaidan Annex Exelnn Nucleanr RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS" The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation inereaserise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.* The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category RA, C or F ICs.Basis Reference(s):

1. NEI 99-01 Rev 6, AA3 2. DOP 1800-01 Area Radiation Monitors 3. FSAR Section 3.2 Classification of Structures, Components and Systems 4. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-10 5. DEOP 300-2, Radioactivity Release Control Month 20XX DR 3-21 EP-AA-1 004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS SRU3 Initiating Condition:

Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): (-1-)-- (Sitoe-pocific radiatio moitr)rading groator than (cite-s9*

vpcfc'a4o)-.

(2) Sample analysis indicatoc that a reactor coolant activity valueo ia greater than an allowable limit specified in Tcc~hnical Specifiations.

1. Offgas system radiation monitor HI-HI alarm.OR 2. Specific coolant activity > 4.0 uCll/m Dose equivalent 1-131.Basis: This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications.

This condition is a precursor to a more significant event 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 clad degradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity.

An Unusual Event is only warranted when actual fuel clad damage is the cause of the elevated coolant sample activity (as determined by laboratory confirmation).

Fuel clad damage should be assumed to be the cause of elevated Reactor Coolant activity unless another cause is known.Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category RA ICs.Basis Reference(s):

1. NEI 99-01 Rev 6, SU3 2. Technical Specifications 3.4.6, RCS Specific Activity 3. DAN 902(3)-3 C-2(D-2) Off Gas Rad Monitor Hi-Hi 4. Technical Specifications 3.7.6, Main Condenser Offgas 5. DGA 16 Coolant High Activity/Fuel Element Failure Month 20XX DR 3-22 EP-AA-1 004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FG1 Initiating Condition:

Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier 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-2 Month 20XX DR 3-23 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FS1 Initiating Condition:

Loss or Potential Loss of ANY two barriers.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier 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-2 Month 20XX DR 3-24 EP-AA-1004 (Revision XX)

Exelon Nuclear rlrsden Annex Ex.lon Nulela. r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FA1 Initiating Condition:

ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Alert classification level, Fuel Cladding and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability.

Note that the loss or potential loss of Containment barrier in combination with loss or potential loss of either Fuel Cladding or RCS barrier results in declaration of a Site Area Emergency under EAL FS1.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX DR 3-25 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1 Initiating Condition:

RCS Activity Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS A. (Sito Spocific indications that rcactor coolant actiVity is groater than 30Q0uGi~gm doc 3.)Coolant activity > 300 uCilcm Dose Equivalent 1-131.Basis: This threshold indicates that RCS radioactivity concentration is greater than 300 gCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete.

Nonetheless, a sample-related threshold is included as a backup to other indications.

There is no Potential Loss threshold associated with RCS Activity.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. DGA-1 6, Coolant High Activity / Fuel Element Failure Month 20XX DR 3-26 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 Initiating Condition:

RPV Water Level Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS A-.1. Plant conditions indicate Primary GContainment flooding is required.POTENTIAL LOSS A-.2. RPV water level cannot be restored and maintained abovo (site specific RPV.at.. level ,..Or...pnding to top of acti'. ful)> -143 inches (TAF)9 RPV water level cannot be determined.

Basis: RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions.

Compensated values may be used in accordance with the Technical Support Guidelines.

Loss 2-AThreshold

1 Basis The Loss threshold represents the EOP requirement for primary containment flooding.This is identified in the BWROG EPGs/SAGSAMGs when the phrase, "Primary Containment Flooding Is Required," appears. Since a site-specific RPV water level is not specified here, the Loss threshold phrase, "Primary containment flooding required," also accommodates the EOP need to flood the primary containment when RPV water level cannot be determined and core damage due to inadequate core cooling is believed to be occurring.

Potential Loss 2AThreshold

2 and #3 Basis This water level corresponds to the top of the active fuel and is used in the EOPs to indicate a challenge to core cooling.The RPV water level threshold is the same as RCS baIieF-Barrier RC2 Loss threshold 2-.A. Thus, this threshold indicates a Potential Loss of the Fuel Clad barrier and a Loss of the RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency.

This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV-waterRPV water level cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure Month 20XX DR 3-27 EP-AA-1004 (Revision XX)

DrAsden Annex.r..d.n Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RPV injection sources preclude Emergency RPV depressurization.

EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this Fuel Clad barrier Potential Loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory.

The term "cannot be restored and maintained above" means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation below the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to tho top of act--ieve order to reduce reactor power. RPV ..at..r le"vl is then contro.lled btwoon tho top of active fuol thoSteanm Cooling RPV Water Loeveol Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority.

For such events, ICs SA5-MA3 or SS-MS3 will dictate the need for emergency classification.

Since the loss of ability to determine if adequate core cooling is being provided presents a significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier is specified.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. DEOP 100 RPV Control 3. DEOP 400-5 Failure to Scram 4. DEOP 400-1 RPV Flooding 5. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Procedures and Severe Accident Management Guidelines

6. Technical Support Guidelines Month 20XX DR 3-28 EP-AA-1 004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Month 20XX DR 3-29 EP-AA-1004 (Revision XX)

Annoy fras~eIan Annexv FYAlnn Nucleasr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC5 Initiating Condition:

Primary Containment Radiation Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS A. Primary containment radiation monitor reading greater than (site-cpecific value)Drywell radiation monitor reading > 6.70 E+02 R/hr (670 R/hr).Basis: L~ess4.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals 300 gCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCS Barrier RC5 Loss tThreshold 4 7 A-since it indicates a loss of both the Fuel Clad Barrier and the RCS Barrier. Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.

I There is no Fuel Clad Barrier Potential Loss threshold associated with Primary Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. Core Damage Assessment Methodology (CDAM)Month 20XX DR 3-30 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC7 Initiating Condition:

Emergency Director Judgment.Operating Mode Applicability:

1,2,3 EAL Threshold Values: LOSS 1A. Any condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.POTENTIAL LOSS 2A. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.Basis: Loss Threshold

1 Basis This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold

2 Basis Potential Loec 6.A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX DR 3-31 EP-AA-1004 (Revision XX)

Exelon Nuclear Dresden Annex Eeo ula RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 Initiating Condition:

RPV Water Level Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS 1. RPV water level cannot be restored and maintained above (.ite.specific RPV water ll corr to the top of acti'..., -143 inches (TAF)R-OR 2. RPV water level cannot be determined.

Basis: Less-2-RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions.

Compensated values may be used in accordance with the Technical Support Guidelines.

This water level corresponds to the Ttop of Aactive Ffuel (TAF) and is used in the EOPs to indicate challenge to core cooling.The RPV water level threshold is the same as Fuel Clad baFi8F Barrier FC2 Potential Loss threshold .A. Thus, this threshold indicates a Loss of the RCS barrier and Potential Loss of the Fuel Clad barrier and that appropriately escalates the emergency classification level to a Site Area Emergency.

This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV-waterRPV water level cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this RCS barrier Loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory.

Month 20XX DR 3-32 EP-AA-1004 (Revision XX)

Dresden Annex Exellon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION The term, "cannot be restored and maintained above," means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation beyond the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to the top of act*ve fuel in order to reduce reactor power. RPV Wator level is then controlled betowen the top Of actiVe fuel and the Minimu.m Steam Coolin;g W^.Atr L ev.el (MSCR'A'W).

Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority.

For such events, ICs SA5-MA3 or SS-MS3 will dictate the need for emergency classification.

There is no RCS Potential Loss threshold associated with RPV Water Level.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. DEOP100 RPV Control 3. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Procedures and Severe Accident Management Guidelines

4. Technical Support Guidelines Month 20XX DR 3-33 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3 Initiating Condition:

Primary Containment Pressure Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS A. Primar,' containment pre6Suro greater than (site specific value) duo to RCS loakag.1. Drywell pressure >2.0 psig.AND 2. Drywell pressure rise is due to RCS leakage Basis: Less4-7 A The (.ite

...

2.0 psia primary containment pressure is the high pressure setpoint which indicates a LOCA by automatically initiating the-ECCS-GF equivalent mrakeup system.The second threshold condition focuses the fission product barrier loss threshold on a failure of the RCS instead of the non-LOCA malfunctions that may adversely affect pdmary containment pressure.

Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drvwell cooling or inability to control primary containment vent/purge.

The release of mass from the RCS due to the as-designed/expected operation of any relief valve does not warrant an emergency classification.

A stuck-open Electromatic relief valve (ERV)/Target Rock SRV or ERV/ Target Rock SRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable to this EAL.There is no Potential Loss threshold associated with Primary Containment Pressure.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. Technical Specifications Table 3.3.5.1-1 3. DAN 902(3)-5 D-1 1 4. DEOP 100 RPV Control 5. DEOP 200-1 Primary Containment Control Month 20XX DR 3-34 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC4 Initiating Condition:

RCS Leak Rate Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS Al. UNISOLABLE Main Steam Line (MSL), Isolation Condenser, HPCI, Feedwater, or RWCU line break. in ANY of the foI.wing:. .... fc Systems with potential for high enorgyImbra)

OR B2. Emergency RPV Depressurization is required.POTENTIAL LOSS 3A. UNISOLABLE primary system leakage that results in EITHER of the following:

al-. Secondary Containment area temperature

> DEOP 300-1 MaximumMax Normal Ooperating T-emperaturelevels.

OR b2. Secondary Containment area radiation level > DEOP 300-1 Maximum Max-Normal Ooperating A^-p Radiation Level.Basis: UNISOLABLE:

An open or breached system line that cannot be isolated, remotely or locally.Classification of a system break over system leakage is based on information available to the Control Room from the event. Indications that should be considered are: " Reports describing magnitude of steam or water release." Use of system high flow alarms / indications, if available,* Significant changes in makeup requirements," Abnormal reactor water level changes in response to the event.The use of the above indications provides the Control Room the bases to determine that the on going event is more significant than the indications that would be expected from system leakage and therefore should be considered a system break.Month 20XX DR 3-35 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Loss Threshold

1 Basis-&A Large high-energy lines that rupture outside primary containment can discharge significant amounts of inventory and jeopardize the pressure-retaining capability of the RCS until they are isolated.

If it is determined that the ruptured line cannot be promptly isolated fr"m :the Co-,ntrol Room, the RCS barrier Loss threshold is met.Loss Threshold

2 Basis3.Emergency RPV Depressurization in accordance with the EOPs is indicative of a loss of the RCS barrier. If Emergency RPV Depressurization is performed, the plant operators are directed to open safety relief valves (SRVs) and keep them open. Even though the RCS is being vented into the Torus, a Loss of the RCS barrier exists due to the diminished effectiveness of the RCS to retain fission products within its boundary.Potential Loss Threshold-

3 Basis 3.Potential loss of RCS based on primary system leakage outside the primary containment is determined from EOP temperature or radiation Max Normal Operating values in areas such as main steam line tunnel, RGIG,-HPCI, etc., which indicate a direct path from the RCS to areas outside primary containment.

A Max Normal Operating value is the highest value of the identified parameter expected to occur during normal plant operating conditions with all directly associated support and control systems functioning properly.The indicators reaching the threshold barriers and confirmed to be caused by RCS leakage from a primary system warrant an Alert classification.

A primary system is defined to be the pipes, valves, and other equipment which connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.In general, multiple indications should be used to determine if a primary system is discharging outside Primary Containment.

For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the Reactor Building since this may be caused by radiation shine from nearby steam lines or the movement of radioactive materials.

Conversely, a high area radiation condition in conjunction with other indications (e.g. room flooding, high area temperatures, reports of steam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building.An UNISOLABLE leak which is indicated by Max Normal Operating values escalates to a Site Area Emergency when combined with Containment Barrier CT6 Loss Tthreshold

13&A (after a containment isolation) and a General Emergency when the Fuel Clad Barrier criteria is also exceeded.Month 20XX DR 3-36 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. M-12, M-345, Main steam piping 3. Technical Specifications 3.4.4 RCS Operational LEAKAGE 4. Technical Specifications Section 3.4.5, RCS Leakage Detection Instrumentation

5. DAN 902(3)-4 A-17 DRWAELLDRYWELL EQUIP SUMP LVL HI-HI 6. DAN 902(3)-4 H-18 DRY-AWELLDRYWELL FLOOR DRN SUMP LVL HI-HI 7. DOA 0040-01 SLOW LEAK 8. DOP 2000-24 DRYWELLDRYWELL SUMP OPERATION 9. DEOP 300-1, Secondary Containment Control 10. UFSAR Section 5.2.5 Month 20XX DR 3-37 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC5 Initiating Condition:

Primary Containment radiation Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS 1. Drywell radiation monitor reading > 100PRhr (>1.00 E+02 R/hr).A. Pdmary containment radiation roading groator than (site spociflc value).Basis: The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC5 Loss Tthreshold 4-A-since it indicates a loss of the RCS Barrier only.I There is no RCS Potential Loss threshold associated with Primary Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor Reading Indicative of loss of the RCS Barrier.Month 20XX DR 3-38 EP-AA-1004 (Revision XX)

AnnAy I=xAIon Nuclear flmsden Annex Exelon Nucleasr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC7 Initiating Condition:

Emergency Director Judgment.Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS Al. Any condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.POTENTIAL LOSS A2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Basis: Loss SAThreshold

1 Basis This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the RCS Barrier is lost.Potential Loss 6,AThreshold

2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX DR 3-39 EP-AA-1004 (Revision XX)

ExAIon Dresden Annex ExeIon Nuclasr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2 Initiating Condition:

RPV Water Level Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS X. Plant conditions indicate PrimaryGContainment flooding is required.Basis: Potential Lo h -2.A The Potential Loss threshold is identical to the Fuel Clad Barrier -RC2 Loss threshold, RPV Water Level thFroheldA.

The Potential Loss requirement for Primary Containment Flooding indicates adequate core cooling cannot be restored and maintained and that core damage is possible.

BWR EPGs/SAGSAMGs specify the conditions that require primary containment flooding.

When primary containment flooding is required, the EPGs are exited and SAGSAMGs are entered. Entry into SAQSAMGs is a logical escalation in response to the inability to restore and maintain adequate core cooling.PRA studies indicate that the condition of this Potential Loss threshold could be a core melt sequence which, if not corrected, could lead to RPV failure and increased potential for primary containment failure. In conjunction with the RPV water level Loss thresholds in the Fuel Clad and RCS barrier columns, this threshold results in the declaration of a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. Severe Accident Management Guidelines

3. DEOP 0100, RPV Control 4. DEOP 0400-01, RPV Flooding 5. DEOP 0400-05, Failure to Scram Month 20XX DR 3-40 EP-AA-1004 (Revision XX)

NuelAar Dresden Annex Exelon Nucle~ar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 Initiating Condition:

Primary Containment Conditions Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS Al. UNPLANNED rapid drop in prma.' contai.montDrvwell pressure following p~4mry eeitairmnetDrywell pressure rise.OR I 82. Prim.ary c ..tainmen. D-..,. pressure response not consistent with LOCA conditions.

POTENTIAL LOSS A3. Primary -.ntainmcP..lwD=ll pressure gr.ator than (site specific.

value)> 62 DsiQ and rising.OR 84. specific explosive mi.ture) exists Inside pr.mar; containmen.

a. Drywell or torus hydrogen concentration

> 6%.AND b. Drvwell or torus oxygen concentration

> 5%.OR G5. HT-LGHeat Capacity Limit (DEOP 200-1, Fig.M) exceeded.Basis: UNPLANNED:

A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.Loss !.A and4-BThreshold

1 and #2 Basis Rapid UNPLANNED loss of primary containment pressure (i.e., not attributable to I dFyweADrywell spray or condensation effects) following an initial pressure kdse indicates a loss of primary containment integrity.

Primary containment pressure should i i eris__ee as a result of mass and energy release into the primary containment from a LOCA. Thus, primary containment pressure not increasing under these conditions indicates a loss of primary containment integrity.

These thresholds rely on operator recognition of an unexpected response for the condition and therefore a specific value is not assigned.

The unexpected (UNPLANNED) response is important because it is the indicator for a containment Month 20XX DR 3-41 EP-AA-1004 (Revision XX) rmcdpn Annpv I=yplnn N.nlpnr flrn~d.n AnnAYExueInn Nunivpar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION bypass condition.

A pressure suppression bypass path would not be an indication of a containment breach.Potential Loss ".AThreshold

3 Basis The threshold pressure is the primary containment internal design pressure.

Structural acceptance testing demonstrates the capability of the primary containment to resist pressures greater than the internal design pressure.

A pressure of this magnitude is greater than those expected to result from any design basis accident and, thus, represent a Potential Loss of the Containment barrier.Potential Loss 1-.BThreshold

4 Basis If hydrogen concentration reaches or exceeds the lower flammability limit, as defined in plant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If the combustible mixture ignites inside the primary containment, loss of the Containment barrier could occur.Potential Loss GThreshold

5 Basis The Heat To-mperatue Limit (HCTI) is the highest Tr.us temperature from which Emerg RPV will not raise: equipment within t.he u which may be .cqui.ed to operate when the RP12i.OR TOM p~ssm aoveP~ma~

ontainment Pressure Limit A., while theFat ecRegy transfer froM the RPV to the containment is greater than the capacityo the ontak;nmeRnt vent.The HCTL is a function of RPV pressure, Torus temperature and Torus water level. It is utilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintain plant parameters below the limit constitutes a potential loss of containment.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. UFSAR 6.2.1.3.2.1

3. UFSAR Table 6.2-3 4. UFSAR 15.6.5 5. UFSAR 6.2.1.1 6. DEOP 200-1 Primary Containment Control 7. DEOP 200-2 Hydrogen Control Month 20XX DR 3-42 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT5 Initiating Condition:

Primary Containment Radiation Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS A. PrimAa,' containment I adiation monGito0r eading greater than (Iit i pecific value)1. Drywell radiation monitor reading > 1.60 E+03 RPhr (1600 R/hr).Basis: There is no Loss threshold associated with Primary Containment Radiation.

Potential Lessl.,A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary 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 Fuel Clad Barrier Loss and RCS Barrier Loss thresholds.

NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant 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 protective actions. For this condition to exist- there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. Core Damage Assessment Methodology (CDAM)Month 20XX DR 3-43 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 Initiating Condition:

Primary Containment Isolation Failure Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS Al. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal.OR 82. Intentional Pprimary CgGontainment venting/Durainc per EOP's or SAMGs due to accident conditions.

OR G3. UNISOLABLE primary system leakage that results in EITHER of the following:

4-a. Secondary Containment area temperature

> DEOP 300-1. MaximumMax Safe OQperating TemrpeFatulevels.

OR 2b. Secondary Containment area radiation level > DEOP 300-1. MaximumMax Safe Qoperating Radiatien-Llevels.

Basis: UNISOLABLE:

An open or breached system line that cannot be isolated, remotely or locally.These thresholds address incomplete containment isolation that allows an UNISOLABLE direct release to the environment.

Loss &AThreshold

1 Basis The use of the modifier "direct" in defining the release path discriminates against release paths through interfacing liquid systems or minor release pathways, such as instrument lines, not protected by the Primary Containment Isolation System (PCIS).Leakage into a closed system is to be considered only if the closed system is breached and thereby creates a significant pathway to the environment.

Examples include unisolable Main Steamline, HPCI steamline breaks, unisolable RWCU system breaks.and unisolable containment atmosphere vent paths.Examples of "downstream pathway to the environment" could be through the Turbine/Condenser, or direct release to the Turbine or Reactor Building.The existence of a filter is not considered in the threshold assessment.

Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.Month 20XX DR 3-44 EP-AA-1004 (Revision XX) nroadon Annoy I=Yplnn Exelon Nurlosar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Following the leakage of RCS mass into primary containment and a rise in primary containment pressure, there may be minor radiological releases associated with allowable primary containment leakage through various penetrations or system components.

Minor releases may also occur if a primary containment isolation valve(s)fails to close but the primary containment atmosphere escapes to an enclosed system.These releases do not constitute a loss or potential loss of primary containment but should be evaluated using the Recognition Category A-RICs.Loss "BThreshold

2 Basis EOPs may direct primary containment isolation valve logic(s) to be intentionally bypassed, even if offsite radioactivity release rate limits will be exceeded.

Under these conditions with a valid primary containment isolation signal, the containment should also be considered lost if primary containment venting is actually performed.

Intentional venting of primary containment for primary containment pressure or combustible gas control to the secondary containment and/or the environment is a Loss of the Containment.

Venting for primary containment pressure control when not in an accident situation (e.g., to control pressure below the djywWDrywell high pressure scram setpoint) does not meet the threshold condition.

Loss 3TCThreshold

3 Basis The Max Safe Operating Temperature and the Max Safe Operating Radiation Level are each the highest value of these parameters at which neither: (1) equipment necessary for the safe shutdown of the plant will fail, nor (2) personnel access necessary for the safe shutdown of the plant will be precluded.

EOPs utilize these temperatures and radiation levels to establish conditions under which RPV depressurization is required.The temperatures and radiation levels should be confirmed to be caused by RCS leakage from a primary system. A primary system is defined to be the pipes, valves, and other equipment which connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.In general, multiple indications should be used to determine if a primary system is discharging outside Prmary Containment.

For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the Reactor Building since this may be caused by radiation shine from nearby steam lines or the movement of radioactive materials.

Conversely, a high area radiation condition in coniunction with other indications (e.g. room flooding, high area temperatures, reports of steam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building.In combination with RCS Barrier RC4 Ppotential LI-oss Threshold-

3,3A_this threshold would result in a Site Area Emergency.

There is no Potential Loss threshold associated with Primary Containment Isolation I Failure.Month 20XX DR 3-45 EP-AA-1004 (Revision XX)

Dresden Nuclear Dlresden Annex Exellnn NucleAar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. DEOP 200-1 Primary Containment Control 3. DEOP 200-2 Hydrogen Control 4. DEOP 500-4 Containment Venting 5. DEOP 300-1 Secondary Containment Control Month 20XX DR 3-46 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT7 Initiating Condition:

Emergency Director Judgment.Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS I Aj. Any condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.POTENTIAL LOSS I A2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Basis: Loss GAThreshold

1 Basis This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Containment Barrier is lost.Potential Loss 6AThreshold

2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX DR 3-47 EP-AA-1004 (Revision XX) roadan Annoy I=Yalnn Nu nazlir flrnerI~n Annv Fv.Inn M.ir~Iu~ar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSG1 Initiating Condition:

Prolonged loss of all Off-site and all On-Site AC power to emergency busesesbuses.

Operating Mode Applicability:

1,2,3 Emergency Acton Level (EAL): Note: 9 The Emeraencv Director should declare the event promptlv upon determinina that the applicable time has been exceeded, or will likely be exceeded.Th maai Smta ahul dina t.. .. ... ..nun a= ano aszt i aamndt W y i i: t1i I I III LI LI IV The EamergencY Director should declare the Gonreal Emorgency promnptly upon that (ito-specific has bcen Or will likely be exceeded.1-a-. Loss of ALL offsite and ALL oncite AC power to (site specific emergency buses)unit ECCS buses.AND 2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators to supply power to unit ECCS buses.AND 3b. EITHER of the following:

a. Restoration of at least one emeigeR~yunit ECCS bus in < 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is notless than+ s .pific hours) is Rot likely.OR b. RPV water level cannot be restored and maintained

> -164 inches.I Site 6-e-ecific-indic-ation of an inability to adeauatelY remove heat froem the core')dl J Basis: SAFETY SYSTEM: A system reauired for safe plant operation.

coolina down the piant and/or placing it in the cold shutdown condition, including the EGGS. These are typically systems classified as safety-related.

Month 20XX DR 3-48 EP-AA-1004 (Revision XX)

Dresden Annex Exellon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS I This IC addresses a prolonged loss of all power sources to AC emergency buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A prolonged loss of these buses will lead to a loss of oAn Or moeany fission product barriers.

In addition, fission product barrier monitoring capabilities may be degraded under these conditions.

RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions.

The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FG1. This will allow additional time for implementation of offsite protective actions.Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation.

Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time 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 power results in parameters that indicate an inability to adequately remove decay heat from the core.Basis Reference(s):

1. NEI 99-01 Rev 6, SG1 2. UFSAR 8.3 3. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 1 4. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure 5. DOA 6500-01 4-KV Bus Failure 6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System 7. UFSAR 9.5.9 8. DOP 6620-05, Powering Unit 2(3) 4-KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC Power 10. DEOP100 RPV Control Month 20XX DR 3-49 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS

11. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Procedures and Severe Accident Management Guidelines Month 20XX DR 3-50 EP-AA-1004 (Revision XX)

Dry.dAn AnnAy Dresden An nex Exelnn Nucler~I~RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS1 Initiating Condition:

Loss of all offsite and all onsite AC power to emergency busesbuses for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Acton Level (EAL): Note: I* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.*Tk~ a 11rk%..~ +k^ a;+^ A r~ mrrr1!~'r, r^r, Mv+r4I1 I.~dot.. ..n.na thv, t 1I nu F%- h .......A......t ..n ..c. .d. or will bo ..ood. ." " 1. Loss of ALL offsite and ALL "e-it+ AC Power to (site ..peif ic omergency ECCS buses for 15 ""minute" or 'on. .I b, nit AND 2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators to supply power to unit ECCS buses.AND 3. Failure to restore power to at least one ECCS bus in < 15 minutes from the time of loss of both offsite and onsite AC power Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS.These are typically systems classified as safety-related.

This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. In addition, fission product barrier monitoring capabilities may be degraded under these conditions.

This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Month 20XX DR 3-51 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Escalation of the emergency classification level would be via ICs RAG1, FG1,_-eq M._SG 1, or MG2.Basis Reference(s):

1. NEI 99-01 Rev 6, SS1 2. UFSAR 8.3 3. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 1 4. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure 5. DOA 6500-01 4KV Bus Failure 6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System 7. UFSAR 9.5.9 8. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC Power Month 20XX DR 3-52 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA1 Initiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Acton Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.The Emnergency Dierccto should declaro the Alo~t proemptly upon dotormining that 15 min*utoc hac boon oxcooded, or will likely be cxccedod 1. AC power capability to unit ECCS buses reduced to only one of the following power sources for > 15 minutes." Reserve auxiliary Transformer TR-22 (TR-32)" Unit auxiliary transformer TR-21 (TR-31)" Unit Emergency Diesel Generator DG 2(3)" Shared Emergency Diesel Generator DG 2/3" Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakers a. AC powor capability to (cite-spccific omergency buses) is rcduccd to a singlc nowemr nowanep for 15 mninutpe or longeF V AND 2b. Any additional single power source failure will result in a loss of ALLa# AC power to SAFETY SYSTEMS.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are tvDicallv systems classified as safety-related.

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.

This IC provides an escalation path from IC MSU1.Month 20XX DR 3-53 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS I An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.j _A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).

A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being baGk-fed from the unit main generator." A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being baek-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.Escalation of the emergency classification level would be via IC MSS1.Basis Reference(s):

1. NEI 99-01 Rev 6, SA1 2. UFSAR 8.3 3. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 1 4. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure 5. DOA 6500-01 4KV Bus Failure 6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System 7. UFSAR 9.5.9 Station Blackout System 8. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-1 2 Partial or Complete Loss of AC Power Month 20XX DR 3-54 EP-AA-1004 (Revision XX)

Annex resden Annex Exelnn Nucl~easr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU1 Initiating Condition:

Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Acton Level (EAL): Note:* The Emergency Director should declare the event Promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.The Emergency Director ehould doclaro the Unusual Event prom~ptly upon determining that 1 6 ute, has been ev-edod,or Oi,;ll likely be eXveeded.--.Loss of ALL offsite AC power capability to unit ECOS buses (;.ite...epific em.ergency

> 15 minutes-e-r-loPWe.

Basis: This IC addresses a prolonged loss of offsite power. The loss of offsite power sources renders 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 power source(s) is available to the emergency buses, whether or not the buses are powered from it. (e.g. unit cross-tie breakers)Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.Escalation of the emergency classification level would be via IC MSA1.Basis Reference(s):

1. NEI 99-01 Rev 6, SU1 2. UFSAR 8.3 3. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 1 4. DOA-6400-01, 138 kV System and 345 kV Alternate Supply Failure 5. DOA 6500-01 4kV Bus Failure 6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System 7. UFSAR 9.5.9 8. DOP 6620-05, Powering Unit 2(3) 4kV Busses via the SBO D/G 2(3)Month 20XX DR 3-55 EP-AA-1004 (Revision XX)

Dresden Annex Exellon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS

9. DGA-12 Partial or Complete Loss of AC Power Month 20XX DR 3-56 EP-AA-1004 (Revision XX)

Dry.dAn AnnAxNuclear frw dwn Annex Exelvn Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSG28 Initiating Condition:

Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Acton Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.The E-morgncY Dir;ctAOr shuld dlclare the GoAn-ciral promptly upnR dotermining that 15 minutos h-as boon excocdcd, Or Will likoly bo oXccoded.1. Loss of ALL offsite AC power to unit ECCS buses.AND 2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators to supply power to vital buses.AND 3. Voltage is < 105 VDC on 125 VDC battery buses #2 and #3.AND 4. ALL AC and Vital DC power sources have been lost for > 15 minutes.1 .a. Loss of ALL offtet and ALL ensito AC powor to (site-Specific.

cmcrgcncy buses) f-r 15 m;nt,- or I6,nger.ANM b. indicatod v.oltage is loss than (sito specific bus voltage value) on ALL (site spocific Vital DC u- suss o 5 iue o ogr Basis: SAFETY SYSTEM: A svstem reguired for safe plant operation, cooling down the plant and/or Dlacina it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

Month 20XX DR 3-57 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A loss of Vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both AC and DC power will lead to multiple challenges to fission product barriers.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. The 15-minute emergency declaration clock begins at the point when all EAL conditionse are met.Basis Reference(s):

1. NEI 99-01 Rev 6, SG8 2. UFSAR 8.3 3. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 1 4. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure 5. DOA 6500-01 4KV Bus Failure 6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System 7. UFSAR 9.5.9 8. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-1 2 Partial or Complete Loss of AC Power 10. UFSAR 8.3.2 11. DOA 6900-02(3)

Failure of Unit 2(3) 125 VDC Power Supply 12. Technical Specification B.3.8.4, DC Power Sources -Operating Month 20XX DR 3-58 EP-AA-1 004 (Revision XX)

I=yplnn rflmrtdpn Annex ExelInn NucleIair RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS28 Initiating Condition:

Loss of all vital DC power for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Acton Level (EAL): Note:* The Emerqency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.The .Emergency Dirovtv 6h1u4d0d-caro thoSit.e Are. n EmergencY promptly upon dotormining that 15 minutes ha6 boon eXcoodod, or Will likely be excccded.,,diGated--Voltage is < 105 VDC Iere" than (c..ite bus voltage value) "on 125 VDC battery buses #2 and #3ALL (cite -pci..c; Vital DG bu.. ..uses4 for>15 minutes-OF-.eRge Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a loss of Vital DC power which compromises the ability to monitor and control SAFETY SYSTEMS. In modes above Cold Shutdown, this condition involves a major failure of plant functions needed for the protection of the public.I Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via ICs RAG1, FG1 or MSG28.Basis Reference(s):

1. NEI 99-01 Rev 6, SS8 2. UFSAR 8.3.2 3. DOA 6900-02(3)

Failure of Unit 2(3) 125 VDC Power Supply 4. Technical Specification B.3.8.4, DC Power Sources -Operating Month 20XX DR 3-59 EP-AA-1 004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS3, Initiating Condition:

Inability to shutdown the reactor causing a challenge to RPV water level or RCS heat removal.Operating Mode Applicability:

1,2 Emergency Acton Level (EAL): 1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 6%.AND 2. ALLA. manual / ARI actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 6%.AND 3. EITHER of the following conditions exist: " RPV water level cannot be restored and maintained

> -164 inches OR" Heat Capacity Limit (DEOP 200-1. Fig. M) exceeded.(Site specific indication of.an ia to adequately emove heat fFrom the core)(Site specific indication of an nblt to adequatcly remove heat fromn the RCS)Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron injection.

all ,ubsequent operator actions to manually shutdown the reaGcto are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.

In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs.

This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the I reactor.Month 20XX DR 3-60 EP-AA-1004 (Revision XX)

Nr=dmnn Annav J=vainn Nl io-lar flrnc~rI~n Ann~ir FvmLnn Mm mr~Ia~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS RPV values are actual levels, not indicated levels. Therefore, they may need level compensation dependingq on conditions.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Escalation of the emergency classification level would be via IC RAG1 or FG1.Basis Reference(s):

1. NEI 99-01 Rev 6, SS5 2. DEOP 100 RPV Control 3. DEOP 400-5 Failure to Scram 4. DEOP 200-1 Primary Containment Control 5. Technical Support Guidelines Month 20XX DR 3-61 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA35 Initiating Condition:

Automatic or manual scram fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:

1,2 Emergency Acton Level (EAL): Note:* A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. A,-aAutomatic or manual scram did not shutdown the reactor as indicated by Reactor Power > 6%.AND 2. Manual / ARI actions taken at the reactor control consoles are not successful in shutting down the reactor as indicated by Reactor Power > 6%.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor control consoles to shutdown the reactor are also unsuccessful.

This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the reactor control consoles since this event entails a significant failure of the RPS.A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor scram. This action does not include manually driving in control rods or implementation of boron injection strategies.

If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the reactor control consoles (e.g., locally opening breakers).

Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the reactor control consoles".

Taking the Reactor Mode Switch to SHUTDOWN Shutdown is considered to be a manual scram action.The plant response to the failure of an automatic or manual reactor scram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other Month 20XX DR 3-62 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough to cause a challenge to the RPV water level or RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC MSS36. Depending upon plant responses and symptoms, escalation is also possible via IC FSi. Absent the plant conditions needed to meet either IC MSS_3 or FS1, an Alert declaration is appropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F l1s; however, this IC and EAL are included to ensure a timely emergency declaration.

i A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Basis Reference(s):

1. NEI 99-01 Rev 6, SA5 2. DEOP 100 RPV Control 3. DEOP 400-5 Failure to Scram 4. DEOP 200-1 Primary Containment Control Month 20XX DR 3-63 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU36 Initiating Condition:

Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:

1,2 Emergency Acton Level (EAL): Note:*A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. a. Ap,-aAutomatic scram_-did not shutdown the reactor as indicated by Reactor Power > 6%..AND b. A-sSubsequent manual / ARI action taken at the reactor control consoles is successful in shutting down the reactor.OR 2. a. A-nManual scram-did not shutdown the reactor as indicated by Reactor Power > 6%.AND b. EITHER of the following:

1. A-,Subsequent manual / ARI action taken at the reactor control consoles is successful in shutting down the reactor.OR 2. A-sSubsequent automatic scram / ARI is successful in shutting down the reactor.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic scram is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.EAL #1 Basis Following the failure on an automatic reactor scram, operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor scram). If these manual actions are successful in shutting down the Month 20XX DR 3-64 EP-AA-1004 (Revision XX)

AnnoyNuclear fr&AQdJn AnnAY Exellon Nuclasr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.EAL #2 Basis If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor scram / ARI using a different switch). Depending upon several factors, the initial or subsequent effort to manually scram the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor scram signal. If a subsequent manual or automatic scram / ARI is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor scram). This action does not include manually driving in control rods or implementation of boron injection strategies.

Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the reactor control consoles".

Taking the Reactor Mode Switch to Shutdown is considered to be a manual scram action.The plant response to the failure of an automatic or manual reactor scram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor control consoles are also unsuccessful in shutting down the reactor, then the I emergency classification level will escalate to an Alert via IC MSA36. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions I needed to meet either IC MSA35 or FA1, an Unusual Event declaration is appropriate for this event.I A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.I Should a reactor scram signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that creates a real condition that should have included an automatic reactor scram and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated." If the signal generated as a result of plant work does not cause a plant transient but should have generated an RPS scram signal and the scram failure is determined through other means (e.g., assessment of test results), then this IC and the EALs Month 20XX DR 3-65 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS are not applicable and no classification is warranted.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU5 2. Technical Specifications Table 3.3.1.1-1 3. DEOP 100 RPV Control 4. DEOP 400-5 Failure to Scram Month 20XX DR 3-66 EP-AA-1004 (Revision XX)

AnnAxNuelAar Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA42 Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.Operating Mode Applicability:

1,2,3 Emergency Acton Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Tho E=m...goncy Diocto , should do.laro the Aler promptly upon determining that 15 min*utes has boon exceoded, Or Will likely be exceeded-.

1. a.

event results in the inability to monitor oneo Or Table MWet th f",e,.-ewi parameters from within the Control Room for >15 minutes Or--lene .[B 14ZR pammDm, Ust]Reactor Po9wer___________________

Table MI Control Room Parameters RP, ..vel , Reactor Power* RPV Water Level RtP .RPV Pressure* Primary Containment Pressure Pria- .. .t.i-m. .* Torus Level....... e. Torus Temperature Suppression Pool Level Suppression Pool Temperature AND b. Any Table M2Wft the- , transient events in progress." Automatic Or Manual Dunback gratcr than 26% the P-al reactor pRevw Eloc~etrical load rejection greator than 25% full electrical load Month 2OXX DR 3-67 EP-AA-1004 (Revision XX)

AnnexNuelAar n1 VVweln Annex Exilin Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS ECCGS (SI) actuation Table M2 Significant Transients" Turbine Trip" Reactor Scram* ECCS Activation

Recirc. Runback > 25% Reactor Power Change* Thermal Power oscillations

> 10% Reactor Power Change Basis: UNPLANNED:

A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or olacin it in the cold shutdown condition.

includina the ECCS.These are typically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fission product barrier challenge is reduced. It thus represents a potential substantial degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for one mereanv of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s).

For example, the reactor power level cannot be determined from any analog, computer point, digital and recorder source within the Control Room.An event involving a loss of plant indications, 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 is required.

The event would be reported if it significantly impaired the capability to perform emergency assessments.

In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures Month 20XX DR 3-68 EP-AA-1004 (Revision XX)

AnnoyN urJpar flr.~e4. Annv FvInn Nmir-Ipnr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, RPV-IeveIRPV water level and RCS heat removal.The loss of the ability to determine one Or mereany of these parameters from within the Control Room is considered to be more significant than simply a reportable condition.

In addition, if all indication sources for one or mroany of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for RPV water level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.I Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via ICs FS1 or IC RASI.Basis Reference(s):

1. NEI 99-01 Rev 6, SA2 Month 20XX DR 3-69 EP-AA-1004 (Revision XX)

NuelAAr Vlmlden Anne E xeIon Nuc.IeVar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS I MSU42 Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Acton Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.J I 0 I roll l lnoT. iTrýnrV= uirnn.or1

ýVHF wr~noiiici anctar.0 i-Tflf E W Mictiai 1 &flf= nrrn 5 UnM.onW n crmf-%I g IV ml flant 1 R =inir.o hoo hann awaaandnd or wall likalu ha narnandnd a AR-UNPLANNED event results in the inability to monitor onoe Or mooANY Table M1 parameter from within the Control Room for > 15 minutes.Table M1 Control Room Parameters

Reactor Power" RPV Water Level" RPV Pressure" Primary Containment Pressure* Torus Level" Torus Temperature

1. of the following paramctcrs from within the Control Room for 15 minutes 2. [BWVR parmctc 3. [PWR Paramctcfr-

4. Reaetor Power 6. Reactor- Power-8.RVWater Lcvcl9 &RGS LeveI 10. URPV1 Press,,c 11. RCS Pr-essure 1-2.Pr-muw

13. in Cor-e/Cor-e

14. Suppression Pol15. Levels in at least Level (site speeie number) tam 16. Supp sion Poo.17..Ste am lnr Tempematur-e Auxilaye Month 20XX DR 3-70 EP-AA-1004 (Revision XX)

AnnAyNuelAar frPAQd1n Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS

2. [BWIR parawter-

3. WIW-Rparameter Basis: UNPLANNED:

A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. This condition is a precursor to a more significant event and represents a potential degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for nAe-O rmorFany of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s).

For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.An event involving a loss of plant indications, 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 is required.

The event would be reported if it significantly impaired the capability to perform emergency assessments.

In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency 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 key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine one OrFmor-any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition.

In I addition, if all indication sources for eeo r- merany of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.I Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

I Escalation of the emergency classification level would be via IC MSA42.Month 20XX DR 3-71 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, SU2 Month 20XX DR 3-72 EP-AA-1 004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA59 Initiating Condition:

Hazardous event affecting a SAFETY SYSTEM needd -reauired for the current operating mode.Operating Mode Applicability:

1,2,3 Emergency Acton Level (EAL): (44 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 e (sito specific hazards)* Other events with similar hazard characteristics as determined by the Shift Manager AND 2.b, EITHER of the following:Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed-required by Technical Specification for the current operating mode.OR b._ 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed-required by Technical Specification for the current operating mode.Basis: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.EXPLOSION:

A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization.

A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion.

Such events may require a post-event inspection to determine if the attributes of an explosion are present.Month 20XX DR 3-73 EP-AA-1 004 (Revision XX) nroHarn Annoy I=yalnn Nielalr n rncrI~n Ann~v Fv~Inn Nit urI~~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the EGGS. These are typically systems classified as safety-related.

VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis.

The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, needed-required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL 41-b#.a Basis-This EAL addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in seeAieoperation since indications for it will be readily available.

The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.EAL 44.2.b Basis This EAL -addresses damage to a SAFETY SYSTEM component that is- required to be operable by Technical Specifications for the current operating mode, and is not in sepeGvoperation or readily apparent through indications alone, er-as well as damage to a structure containing SAFETY SYSTEM components.

Operators will make this determination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC FS1 or RAS1.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 SA9 Month 20XX DR 3-74 EP-AA-1004 (Revision XX)

Dresden Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU64 Initiating Condition:

RCS leakage for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Acton Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.The Emrgncy Diroct,-r shonulId4 the Unusual Event promptly upon dtrig that 15 mninute has been eXceeded, Or Will likely be oxcevdod.1. RCS unidentified or pressure boundary leakage in the Drywell ..eatef-"ha> 10 apm for> 15 minutes ..(..t spcific value) for 15 m.inutes Or lon.ger..OR 2. RCS identified leakage in the Drvwell qreateF than-5amfo>1 iuts(ie s*pecific value) for 15 mninutec or longer.OR 3. Leakage from the RCS to a location outside Drvwell >25 gpm for >15 minutes .greater than 25 gpm. fo 16 minutes or longer.Basis: UNISOLABLE:

An open or breached system line that cannot be isolated, remotely or locally.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 applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.EAL #1 and EAL #2 Basis These 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 defined in the plant Technical Specifications).

EAL #3 Basis This EAL addresses a RCS mass loss caused by an UNISOLABLE leak through an interfacing system.Month 20XX DR 3-75 EP-AA-1004 (Revision XX)

Annex I=xelon Nuclear fresden Annex Exelnn Nucleanr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS These EALs thus apply to leakage into the containment, a secondary-side system (e-g-., steam gene.r.ato..

r tube,, leakage in a PWR) or a location outside of containment.

The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications.

Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation).

EAL #1 uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage.The release of mass from the RCS due to the as-designed/expected operation of any relief valve does not warrant an emergency classification.

A stuck-onen Electromatic relief valve (ERV)/Taroet Rock SRV or ERV Target Rock SRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable to this EAL.The rel.aso of mass from the RCS due to the as designed.expeted operation of..relief valve does not warrant an omorgoncy classification.

r-.. BWR's, aA stuck- pen Safety Rolief Valve, (SRV) or, SR leakage is not conSidered

+ithe, identified OF unlonintifled leaage by I ifaiation and, tnlo4retro, is not applin lAio to tn"s The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible.Escalation of the emergency classification level would be via ICs of Recognition Category BA or F.Basis Reference(s):

1. NEI 99-01 Rev 6, SU4 2. Technical Specification 3.4.4, RCS Operational Leakage 3. UFSAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary 4. Technical Specifications 3.4.5 5. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log 6. DAN 902(3)-4 A-17 Equip Sump Lvl HI-HI 7. DAN 902(3)-4 H-18 DQywaeDy~well Floor Drn Sump Lvl HI-HI 8. DOA 0040-01 Slow Leak 9. DOP 2000-24 DQywellDrywell Sump Operation 10. DGP 02-02 Reactor Vessel Slow Fill Month 20XX DR 3-76 EP-AA-1004 (Revision XX)

ML14164A064

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