Text

Emergency Plan Implementing Procedures Manual Revisions
	ML040990043
Person / Time
Site:	Point Beach
Issue date:	03/24/2004
From:	Vanmiddlesworth G; Nuclear Management Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC 2004-0029
	Download: ML040990043 (99)
	v • d • e

Committed to NuclearExcellence Point Beach Nuclear Plant Operated by Nuclear Management Company, LLC March 24, 2004 NRC 2004-0029 10 CFR 50.54(q)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 License Nos. DPR-24 and DPR-27 Emergency Plan Implementing Procedures Manual Revisions Enclosed are copies of revised procedures to the Point Beach Nuclear Plant Emergency Plan Implementing Procedures Manual The revised procedures are dated March 10, 2004 and should be filed in your copy of the manual.

Gary Van Middlesworth Site Vice-President, Point Beach Nuclear Plant Nuclear Management Company, LLC Enclosures cc: Incident Response Center, Region III (cd)

Resident Inspector - Point Beach Nuclear Plant, USNRC (wiole)

_N5 6590 Nuclear Road

Two Rivers, Wisconsin 54241 Telephone: 920.755.2321

ENCLOSURE I Emergency Plan Implementing Procedures Manual Revisions

EPIP 1.2 EMERGENCY CLASSIFICATION DOCUMENT TYPE: Technical CLASSIFICATION: NNSR REVISION: 42 EFFECTIVE DATE: March 10, 2004 REVIEWER: Plant Operation's Review Committee APPROVAL AUTHORITY: Department Manager PROCEDURE OWNER (title): Emergency Preparedness OWNER GROUP: Emergency Preparedness Verified Current Copy:

Signature Date Time List pages used for Partial Performance ControllinglWork-Document Numbers

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 TABLE OF CONTENTS SECTION TITLE, PAGE 1.0 PURPOSE .3 2.0 PREREQUISITES .3 3.0 PRECAUTIONS AND LIMITATIONS .3 4.0 INITIAL CONDITIONS .4 5.0 PROCEDURE ............ 4 5.1 Classifying an Emergency ................... 4 5.2 Terminating an Emergency .................... 6 5.3 Missed Classifications ................... 6

6.0 REFERENCES

.7 7.0 BASES .8 ATTACHMENT A EMERGENCY ACTION LEVEL (EAL) OVERVIEW MATRIX ...................... 9 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs) . ..................................10 ATTACHMENT C FISSION PRODUCT BARRIER (FPB) MATRIX . .87 ATTACHMENT D SAFETY AND SAFETY-RELATED SYSTEMS . .95 Page 2 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 1.0 PURPOSE This procedure provides instructions to classify off-normal occurrences at PBNP into one of four standardized emergency classes.

2.0 PREREQUISITES 2.1 Responsibilities 2.1.1 This procedure is intended for immediate use by the Shift Manager (SM).

Following the activation of the Emergency Operations Facility (EOF) the overall responsibility for classification is assumed by the Emergency Director.

He is supported in this effort by Control Room, TSC, and EOF personnel.

2.1.2 When relieved of Emergency Director duties by the Emergency Director, the Shift Manager shall no longer be responsible for performance of actions specified in this procedure, however as an NRC licensee the SM shall bring to the attention of the Emergency Director changing plant conditions which may affect the emergency classification.

2.1.3 Upon activation of the TSC, the Operations Coordinator shall monitor plant conditions and provide event classification recommendations to the Emergency Director.

2.1.4 Upon activation of the EOF, the EAL Monitor will monitor plant and offsite conditions and provide recommendations on changes to the Emergency Director.

2.2 Equipment None 3.0 PRECAUTIONS AND LIMITATIONS 3.1 The notification of state and county emergency government agencies shall be initiated within 15 minutes of event classification, event termination, or change in protective action recommendations (PARS).

3.2 The notification to the NRC shall be completed immediately following state and counties and not exceeding 60-minutes from event classification, event termination, or change in protective action recommendations (PARS).

3.3 Category 8 EALs (Judgment) provide the ability to classify any set of plant conditions based on the Emergency Class definitions, based on NUREG-0654 Appendix 1.

3.4 Certain conditions or occurrences, while not meeting the threshold for classification as an emergency, may nonetheless be reportable to the NRC per 10 CFR 50.72. (Guidance on interpretation of the 10 CFR 50.72 criteria may be found in NUREG-1022.)

Page 3 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 3.5 Continuously reference both plant conditions and the EALs in this procedure for potential re-classification.

3.6 When Emergency conditions exist on both Units due to separate events, then each Unit should be classified separately according to the plant conditions and EALS. Units are independent of each other unless the event affects both units. If an event affects both units a single Emergency Classification is adequate.

4.0 INITIAL CONDITIONS EPIP 1.1 has been (or had previously been) initiated by the Control Room because an off-normal occurrence exists (or has existed) at PBNP.

5.0 PROCEDURE 5.1 Classifvinp anEmergency TIME / INITIALS NOTE: A large version of Attachment A is available in the Control Room, TSC, and EOF.

5.1.1 Determine the category (or categories) of the event. (Column 1 of Attachment A). The categories are:

l

1. Fission Product Barriers Eli

2. System Malfunction FII

3. Electrical Power Eli

4. Radiological LI

5. Internal Events Eli

6. External Events El

7. Fuel Handling[ISFSI Events Eli

8. Emergency Director Judgment El Page 4 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 TIME / INITIALS NOTE: If the EAL relates to Category 1 (Fission Product Barriers),

Attachment C provides additional information on the CHALLENGE and LOSS criteria.

5.1.2 Identify the status of Fission Product Barriers from Attachment C, as required.

Intact Challenge Loss Fuel Clad RCS Containment 5.1.3 Make an initial EAL selection from Attachment A.

/

NOTE: Do not "anticipate" challenge or loss of a barrierunless the trend is rapid, and the values arc close to the threshold/criteria.

5.1.4 Reference the individual EAL page(s) in Attachment B for the EAL(s) selected. Read all fields on the page to determine/confirm that the EAL applies.

I 5.1.5 Also reference the individual EAL pages for the next higher and lower emergency class - in that category- (if such EALs exist). This should further confirm the initial selection and specific EAL.

l NOTE: Classifications are to be made consistent within 15 minutes once plant parameters reach an Emergency Action Level (EAL), indication in the Control Room.

5.1.6 IF an event has been categorized on Attachment A, and the threshold of the EAL and surrounding conditions verified to have been met or exceeded (Attachments B and C),

THEN declare the emergency.

I

a. Record the time of declaration, the emergency classification, and the EAL Classification EAL l

Page 5 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 TIME I INITIALS

b. IF this procedure is being implemented in the EOF, THEN make an announcement to your facility of the emergency and that you are assuming the duties of Emergency Director.

l NOTE: IF this procedure is being implemented from the EOF, THEN verify Control Room is assisting with Gai-tronics announcements / evacuation alarm.

c. IF this procedure was entered from EPIP 1. 1, Course of Actions, THEN return to EPIP 1.1 to ensure all appropriate actions are taken and coordinated with actions of the other ERFs if activated.

l 5.2 Terminating an Emergency IF conditions have improved where an EAL is no longer met THEN implement EPIP 12.1.

5.3 Missed Classifications A missed classification is defined as a set of circumstances or events, which although no longer existing, if recognized at the time of their existence would have resulted in an emergency classification (i.e., met or exceeded an EAL of this procedure). This definition does not include conditions described in EALs which are based on expected plant response which does not occur, but where operator action was successful- such as failure of RPS.

NOTE: In ALL cases, the SM is vested with unilateral authority to classify an emergency and initiate any actions deemed appropriate to place the plant in a safe condition (per NUREG-0654, II.A.1.d, II.B.2).

5.3.1 If the missed classification would have been one classification, but current plant conditions warrant a lower classification, the lower classification shall be declared, but parties notified shall be informed of the temporary higher classification during the notification process.

l Page 6 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 TIME / INITIALS 5.3.2 IF NO current plant conditions meeting any EAL exist at the time of discovery of the missed classification, THEN the actual declaration of the emergency is not required; however an NRC notification should be made within one hour of the discovery of the undeclared event. Notify the Emergency Preparedness staff to ensure courtesy calls are made to offsite agencies.

6.0 REFERENCES

6.1 Technical Specifications 6.2 Final Safety Analysis Report (FSAR) Chapter 14, Appendix A 6.3 Point Beach Nuclear Plant Emergency Plan 6.4 Point Beach Design Basis Document (DBDs) 6.5 Abnormal Operating Procedures (AOPs) 6.6 Emergency Operating Procedures (EOPs) 6.7 Emergency Contingency Actions (ECAs) 6.8 Critical Safety Procedures (CSPs) 6.9 Point Beach Setpoint Document (STPT) 6.10 Security and Safeguards Contingency Plan 6.11 WCAP 7525-L, Likelihood and Consequences of Turbine Overspeed at the Point Beach Nuclear Plant.

6.12 Reg Guide 1.1 15, Protection Against Low-Trajectory Turbine Missiles 6.13 EPRI Document, "Guidelines for Nuclear Plant Response to an Earthquake," dated October 1989 6.14 Probabilistic Safety Assessment - High Winds, and Others Sec 9, Rev 0, Dated July 1995 6.15 Bechtel Corporation, "Westinghouse Electric Corporation-Wisconsin Michigan Power Company-Point Beach Atomic Power Station-Design Criteria for Nuclear Power Plants Against Tornadoes," March 12, 1970, B-TOP-3.

6.16 SOER 85-5, Internal Flooding of Power Plant Buildings Page 7 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 6.17 NrUREG/CR-4982, "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82" 6.18 NRC Information Notice 90-08, "Kr-85 Hazards from Decayed Fuel" 6.19 NUREG-1022, Rev. 2, Event Reporting Guidelines 10CFR50.72 and IOCFR50.73.

7.0 BASES B-1 Code of Federal Regulation, 10 CFR 50 B-2 NTUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Plants, Revision 1, published November, 1980.( note:1)

B-3 NUMARC NESP-007, Methodology for Development of Emergency Actions Levels, Revision 2, January 1992.

B-4 U.S. Regulatory Comrnission Position Paper, Branch Position on Acceptable Deviations to Appendix 1 to NUREG-0654/FEMA-REP-1, dated July 11, 1994.

Note 1: With deviations allowed by "Branch Position on Acceptable Deviations to Appendix I to NUREG -0654 IFEMA -REP-1 dated July 11,1994.

Paae 8 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: Fission Product Barriers EAL 1.1.1.1 Sub-Category: None Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Reactor coolant sample activity greaterthan Technical Specification TS 3.4.16. I Basis:

This EAL is related to a Fission Product Barrier challenge. See Attachment C for additional information.

Elevated reactor coolant activity represents a potential degradation in the level of safety of the plant and is a potential precursor of more serious problems. This EAL addresses reactor coolant samples exceeding coolant Technical Specifications (TSAC 3.4.16.B or TSAC 3.4.16.C has been entered).

Technical Specifications allow exceeding normal coolant activities for limited time periods (TSAC 3.4.16.A). This EAL does not apply while operating within these allowances.

Because RCS leakage and coolant activity are considered precursors to more serious events, and because they should be treated alike (each relating to a Fission Product Barrier) declaration shall be upon validation and shall NOT be delayed until Technical Specification's actions are taken.

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 3b Pace I., 10 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: Fission Product Barriers EAL 1.1.1.2 Sub-Category: Loss of One Barrier Emergency Classification: ALERT Emergency Action Level:

Exceeding the LOSS threshold of eitherFuel Clad OR Reactor Coolant System (RCS) barrierbased on FPBMatrix (See Attachment Cfor thresholds).

Basis:

This Fission Product Barrier (FPB) EAL refers to exceeding the LOSS threshold of either the Fuel Cladding or Reactor Coolant System barrier by comparing plant conditions to the thresholds outlined in the FPB Matrix (Attachment C).

The FPB Matrix LOSS criteria indicate values at which either the Fuel Cladding or RCS barrier has been breached to the point that it no longer serves as an effective barrier to the travel of fission products.

This value is not intended to represent total loss, however one of these two essential barriers is no longer serving its function. A substantial reduction in the level of safety at the plant exists, therefore an Alert classification is appropriate.

Loss of the Containment barrier (by itself) does not create an immediate transport of fission products as the Containment is designed to be a backup to the cladding and RCS barriers. Therefore, if only the Containment barrier is lost, it will be dealt with by Technical Specification action statements. However, if either the Fuel Cladding or RCS barrier is lost, the Containment barrier will be considered at the same level as these.

References:

NEI 97-03 Rev. 2 NUREG 0654, Appendix 1 Initiating Condition: Alert 1b,1c, 5 Page II of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Fission Product Barriers EAL 1.1.1.3 Sub-Category: Loss of Two Barriers Emergency Classification: SITE EMERGENCY Emergency Action Level:

Exceeding the LOSS threshold of any 2 fission product barriersbased on FPB Matrix (See Attachment C I for thresholds).

Basis:

This Fission Product Barrier (FPB) EAL refers to exceeding the LOSS threshold of any two of the three fission product barriers; fuel cladding, reactor coolant system, or containment by comparing plant conditions to the thresholds outlined in the FPB Matrix (Attachment C).

The third barrier must remain INTACT. If challenged or lost, a General Emergency exists.

K> The FPB Matrix LOSS criteria indicate values at which barriers have been breached to the point that they no longer serve as effective barriers to the travel of fission products. These values are not intended to represent total loss, however two important barriers are no longer serving their function. This represents a major failure in plant systems needed to protect the public, therefore a Site Emergency classification is appropriate.

References:

NEI 97-03 NTUREG 0654, Appendix 1 Initiating Condition: Site Emergency 5 Pace 12 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Fission Product Barriers EAL 1.1.1.4 Sub-Category: Loss of Three Barriers Emergency Classification: GENERAL EMERGENCY Emergency Action Level:

Exceeding the LOSS threshold of any 2 fission product barriersAND exceeding the loss OR challenge l threshold of the 3rd barrierbased on the FPB Matrix (See Attachment Cfor thresholds).

Basis:

This Fission Product Barrier (FPB) EAL refers to exceeding the LOSS threshold of any TWO'of the three fission product barriers; fuel cladding, reactor coolant system, or containment AND also exceeding EITHER the loss OR challenge threshold on the third barrier by comparing plant conditions to the thresholds outlined in the FPB Matrix (Attachment C).

The FPB Matrix LOSS criteria indicate values at which barriers have been breached to the point that K , they no longer serve as effective barriers to the travel of fission products. These values are not intended to represent total loss, however the barriers are no longer serving their function. The loss of two and a loss or challenge of the third available barrier represents major failures to plant systems needed to protect the public with the actual or potential release of significant amounts of radioactive materials offsite, therefore a General Emergency classification is appropriate.

References:

NEI 97-03 Rev.2 NUREG 0654, Appendix 1 Initiating Condition: General Emergency 2 Page 13 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Fission Product Barriers EAL 1.1.2.1 Sub-Category: None Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Failedfitel monitor [1(2) RE-109J readinggreaterthan 120 mRem/hfr, or 2 of 3 containment high range I monitors read greaterthan 1000 Rem/hr.

Basis:

This EAL is related to a Fission Product Barrier challenge. See Attachment C for additional information.

Other indications should accompany this indication, such as increased radiation on RE-106 or on hand-held instruments.

Elevated reactor coolant activity as indicated by the failed fuel monitor [1(2) RE-109] represents a potential degradation in the level of safety of the plant and is a potential precursor of more serious problems. This EAL addresses failed fuel monitor readings exceeding approximately 0.1% fuel clad failures.

Because RCS leakage and coolant activity are considered precursors to more serious events, and because they should be treated alike (each relating to a Fission Product Barrier) declaration shall be upon validation and shall NOT be delayed until Technical Specification's actions are taken.

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 3c Page 14 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Fission Product Barriers EAL 1.1.2.2 Sub-Category: Loss of One Barrier Emergency Classification: ALERT Emergency Action Level:

Unisolable steam line break outside containment with greater than 10 gpm , but less than 50 gpm, l primary to secondary leakage.

Basis:

This EAL reflects a unique Initiating Condition from NUREG-0654. It does not meet the loss of one barrier criteria from Attachment C (Fission Product Barrier matrix), yet wvill be classified as an Alert.

Because an unisolable steam line break is evaluated under the Containment section of the Fission Product Barrier matrix, it would not result in an Alert by itself. Because the primary to secondary leakage rate (10 gpm) is less than the LOSS criteria for RCS, it would not result in an Alert. The 10 gpm does meet the CHALLENGE criteria therefore is an Unusual Event. However, there is no logic in the FPB matrix for combinations of LOSS of Containment with CHALLENGE of another barrier.

Due to the unique, specific criteria of NUREG-0654, Appendix 1 criteria, this EAL covers the unique condition of an unisolable steam line break, combined with a small primary to secondary leak.

If the steam line can be isolated, no emergency is warranted. If the steam line cannot be isolated, and the other Fission Product Barriers are INTACT (No leakage, or leakage below 10 gpm) then no emergency is applicable UNLESS the SM determines a potential degradation in the level of safety.

If the steam line cannot be isolated AND primary to secondary leakage is greater than 10 gpm, but less than 50 gpm, then this EAL applies and an Alert must be declared.

If the primary to secondary leak rate exceeds 50 gpm, then the LOSS criteria for RCS Fission Product Barrier has been met. This would constitute LOSS of two barriers, and would be a Site Emergency on EAL 1.1.1.3.

References:

NEI 97-03 Rev. 2 NUREG 0654, Appendix 1 Initiating Condition: Alert 4 Page 15 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR

-Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Fission Product Barriers EAL 1.1.3.1 Sub-Category: None Emergency Classification: UNUSUAL EVENT Emergency Action Level:

r -

Prinzaryto secondary leakage greater than Technical Specification Reference TS 3.4.13.d (500 gallons per day through any one steam generator).

Basis:

This EAL is related to a Fission Product Barrier challenge. See Attachment C for additional information.

Leakage from the RCS in excess of Technical Specifications is considered by the NRC to be a precursor to more serious events. Therefore, an Unusual Event must be declared even if Technical Specification actions are taken.

Because RCS leakage and coolant activity are considered precursors to more serious events, and because they should be treated alike (each relating to a Fission Product Barrier) declaration shall be upon validation and shall NOT be delayed until Technical Specification's actions are taken.

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 5 Page 16 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Fission Product Barriers EAL 1.1.4.1 Sub-Category: None Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Unisolableprimary system leakage greaterthan Technical Specification Reference TS 3.4.13.c I(10 gallonsper minute).

Basis:

This EAL is related to a Fission Product Barrier challenge. See Attachment C for additional information.

Leakage from RCS in excess of Technical Specifications which cannot be isolated is considered by the NRC to be a precursor to more serious events. Therefore, an Unusual Event must be declared even if Technical Specification actions are taken.

Because RCS leakage and coolant activity are considered precursors to more serious events, and because they should be treated alike (each relating to a Fission Product Barrier) declaration shall be upon validation and shall NOT be delayed until Technical Specification's actions are taken.

References:

PBNP Technical Specifications NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 5 Page 17 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: Fission Product Barriers EAL 1.1.5.1 Sub-Category: None Emergency Classification: UN'USUAL EVENT Emergency Action Level:

Excess RCS cooldown or cold overpressurizationof the RCS (ST-4 Integrity Orangepath)

Basis:

The following conditions meet ST-4 Integrity - Orange Path criteria. A challenoe to the RCS barrier is present due to excessive cooldown or cold overpressurization as indicated below:

Decrease in temperature in either cold leg greater than 1000 F in the last 60 minutes AND temperature in either cold leg less than 315'F.

OR Temperature in either cold leg less than 315'F and RCS pressure greater than 425 psig.

Any actual loss of RCS barrier warrants declaration of an Alert per the FPB matrix, Attachment C.

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 17 Page IS of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALS)

Category: System Malfunctions EAL 2.1.1.2 Sub-Category: Failure to Trip Emergency Classification: ALERT Emergency Action Level:

Failureof the reactorprotection system(automatic or manual) to initiateand complete a trip which brings the reactorsubcritical. I Basis:

The reactor protection system may be actuated either by automatic means (exceeding pre-determined thresholds which result in trip signals) or by operator action (manual trip).

The failure of EITHER of these means to cause a trip with subsequent subcriticality meets this EAL (an Alert).

If BOTH these means AND all other means from the Control Room fail, see EAL 2.1.1.3 (a Site Emergency).

References:

NUREG 0654, Appendix 1 Initiating Condition: Alert 11 Page 19 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: System Malfunctions EAL 2.1.1.3 Sub-Category: Failure to Trip Emergency Classification: SITE EMERGENCY Emergency Action Level:

IFailureto rapidly bring the reactorsubcriticalfrom the Control Room. (ST-1 SubcriticalityRed Path) I Basis:

CSFST Subcriticality - RED path is entered based on failure of power range indication (N-41, N-42, N-43, N-44) to decrease below 5% following a reactor trip. This EAL addresses any manual trip or automatic trip signal followed by a manual trip or other Control Room actions which fail to rapidly shut down the reactor.

If any actions must be taken outside the Control Room to effect a reactor trip this EAL is also met.

This condition indicates failure of both the automatic and manual protection systems to trip the reactor, to an extent that emergency boration is required: or actions are needed outside the Control Room to trip the reactor. The failure of both front line and backup protection systems to function in response to a plant transient, along with the continued production of heat, poses a direct threat to fuel clad and RCS integrity and thus warrants declaration of a Site Emergency.

This EAL is synonymous with entry into CSP S-1.

References:

NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 9 Page 20 of 97 REFERENCE USE

PONT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL9)

Category: System Malfunctions EAL 2.2.1.1 Sub-Category: Technical Specification Requirements Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Failureto reach Technical Specification requiredoperating mode or condition within the specified time limit of the LCO action statement.

Basis:

Limiting Conditions of Operation (LCOs) action statements require the plant to be brought to a required condition (often shutdown) when the Technical Specification required configuration cannot be restored.

Depending on the circumstances, this may or may not be an emergency or precursor to a more severe condition. In any case, the initiation of plant shutdown required by the site Technical Specification requires a four hour report under 10 CFR 50.72 (b) non-emergency events. The plant remains within its evaluated safety envelope while changing conditions or being shut down so long as it is accomplished

within the completion time for the required action in the Technical Specifications.

An immediate Unusual Event is required when the plant is not brought to the required operating mode or condition within the allowable action statement time of the Technical Specifications. Declaration of an Unusual Event is based on the time at which the LCO-specified action statement time period elapses under the site Technical Specifications and is not related to how long a condition may have existed.

If a Notice of Enforcement Discretion (NOED) is approved by the NRC prior to the LCO action statement time expiration an emergency need not be declared.

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 15 Page 21 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALi)

Category: System Malfunctions EAL 2.3.1.1 Sub-Category: Loss of Indications/Communications Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Unplanned loss of 7nost (approximately 75%) safety system annunciatorsor indicationson Control Room Panelsforgreater than IS minutes AND increasedmonitoring is requiredforsafe plant operation.

Basis:

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. Recognition of the normal availability of computer based indication equipment is considered.

"Unplanned" loss of annunciators or indicators excludes scheduled maintenance and testing activities, which should not disable such large portions of the system(s).

It is not intended that personnel perform a count of the instrumentation or annunciation lost but use the judgment of the SM as the threshold for determining the severity of the plant condition. The increased monitoring portion of this EAL is met if the SM detennines that additional personnel are required to provide increased monitoring of system operation to safely operate the plant.

It is recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific safety system indicators should remain a function of that specific system or component operability status, and is addressed by the specific Technical Specifications.

Safety systems as used here designates systems with safety-related functions. Attachment D lists safety systems and systems with safety-related functions.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses.

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 14 Page 22 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: System Malfunctions EAL 2.3.1.2 Sub-Category: Loss of Indications/Communications Emergency Classification: ALERT Emergency Action Level:

Unplannedloss of most (approximately 75%) safety system annunciatorsor indicationson Control Room Panelsfor greaterthan 15 minutes AND Increasedmonitoring is requiredforsafe plant operation AND either.

A significantplant transientis in progress OR PPCS is unavailable.

Basis:

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a transient. Recognition of the normal availability of computer based indication equipment is also considered.

"Unplanned" loss of annunciators or indicators excludes scheduled maintenance and testing activities, which should not disable such large portions of the system(s).

Safety systems as used here designates systems with safety-related functions. Attachment-D lists safety systems and systems with safety-related functions.

It is not intended that personnel perform a count of the instrumentation or annunciation lost but the use the judgment of the SM as the threshold for determining the severity of the plant conditions. The increased monitoring portion of this EAL is met if the SM determines that additional personnel are required to provide increased monitoring of system operation to safely operate the plant.

It is recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status and is addressed by the specific Technical Specifications.

Page 23 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALU)

"Significant transient" includes response to automatic or manually initiated functions such as trips, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power ramps of 10% or greater.

If both a major portion of the annunciation system and all computer monitoring is unavailable to the extent that additional personnel are required to monitor indications, the Alert is required. If the operating crew cannot monitor the transient in progress this will be escalated to a Site Emergency.

References:

NUREG 0654, Appendix 1 Initiating Condition: Alert 14 Page 24 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALi)

Category: System Malfunctions EAL 2.3.1.3 Sub-Category: Loss of Indications/Communications Emergency Classification: SITE EMERGENCY Emergency Action Level:

Unplanned loss of most (approx. 75%) safety system annunciatorsor indicationson Control Room Panels.

AAMD Loss of ability to monitor critical safety function status AND A significantplant transient in progress.

Basis:

This EAL recognizes the INABILITY of the Control Room staff to monitor the plant response to a transient. A Site Emergency is considered to exist if the Control Room staff cannot monitor safety functions needed for protection of the public.

"Significant transient" includes response to automatic or manually initiated functions such as trips, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power ramps of 10% or greater.

Safety systems as used here designates systems with safety-related functions. Attachment D lists safety systems and systems with safety-related functions.

"Unplanned" loss of annunciators or indicators excludes scheduled maintenance and testing activities, which should not disable such large portions of the system(s).

References:

NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 12 Page 25 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: System Malfunctions EAL 2.3.2.1 Sub-Category: Loss of Indications/Communications Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Loss of all communications capability affecting the ability to either:

Perfonr routine operations OR Notify offsite agencies or personnel.

Basis:

The purpose of this EAL is to recognize a loss of communications capability that EITHER defeats the plant operation's or staff's ability to perform routine tasks necessary for plant operations OR the ability to communicate problems with offsite authorities. The loss of offsite communications ability anticipated by this EAL is expected to be significantly more comprehensive than the condition addressed by 10 CFR 50.72.

The onsite communications loss must encompass the loss of all means of routine communications (i.e., plant telephone system, Gai-tronics page system, portable radios).

The offsite communications loss must encompass the loss of all means of communications with offsite authorities. This should include Emergency Notification System (ENS) for NRC, Microwave lines, and radio. This EAL is also met when extraordinary means are being utilized to make communications possible (relaying of information from radio transmissions, individuals being sent to offsite locations, etc.).

Procedure DCS 2.1.1 describes lesser communications losses which must be reported to the NRC within eight hours.

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 11 Page 26 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALsD Category: System Malfunctions EAL 2.4.1.2 Sub-Category: Degradation of Safety System Performance Emergency Classification: ALERT Emergency Action Level:

Inability to maintain reactorcoolant temperature less than or equal to 200 'F.

Basis:

This EAL addresses complete loss of functions required for core cooling during refueling and cold shutdown modes. Escalation to Site Emergency or General Emergency would be through other EALs.

An uncontrollable reactor coolant temperature increase that approaches or exceeds the cold shutdown technical specification limit warrants declaration of an Alert. The concern of this EAL is the loss of control resulting in the loss of ability to maintain the plant in cold shutdown which is defined by reactor coolant temperature.

References:

NUREG 0654, Appendix 1 Initiating Condition: Alert 10 Page 27 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: System Malfunctions EAL 2.4.1.3 Sub-Category: Degradation of Safety System Performance Emergency Classification: SITE EMERGENCY Emergency Action Level:

Primaryto secondary leakage greaterthan 400 gallons per minute AND Inability to power BOTH buses A-05 AND A-06from offsite sources.

Basis:

400 gpm is also the expected output from a single SI pump @ 1400 psia RCS pressure. (See DBD-09).

Loss of offsite power combined with an RCS leak (from Primary to Secondary) of this magnitude constitute several major challenges to the protection of the public:

1. Operating on diesel generators.

2. Leak (rupture) near the capacity of a single Safety Injection pump.

3. Transport of nay fission products from Primary to Secondary.

Therefore, major plant functions needed for the protection of the public have been affected. A Site Emergency is warranted.

References:

NUREG 0654, Appendix I Initiating Condition: Site Emergency 3 Page 28 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES N`NSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: System Malfunctions EAL 2.5.1.1 Sub-Category: Reactivity Transient Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Uncontrolled Rod Withdrawal (FSAR 14.1.1 and 14.1.2)

Basis:

A malfunction which results in an uncontrolled withdrawal of control rod(s) is a reactivity transient which indicates a potential degradation of the level of safety of the plant. This condition warrants an Unusual Event Classification.

Uncontrolled is defined as unwarranted rod motion that cannot be prevented by operator action (i.e.,

going to manual).

The Unusual Event classification is warranted if a reactor trip is required to stop rod motion.

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 15.

FSAR 14.1.1, Uncontrolled Rod Withdrawal from Subcritical.

FSAR 14.1.2, Uncontrolled Rod Withdrawal at Power.

Page 29 of 97 REFERENCE USE

POINlT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNTSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALi)

Category: System Malfunctions EAL 2.6.1.4 Sub-Category: FeedwaterTransient Emergency Classification: GENERAL EMERGENCY Emergency Action Level:

TransientlIzitiated By Loss of Feedwater,followed by loss of auxiliaryfeedwaterfor greaterthan 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . As indicated by All of the following:

1. DecreasingSG Levels -

"A" SG [LI-461, LI-462, LI-463]

"B" SG [LI-471, LI-472, LI-473]

2. No auxiliaryfeedwaterflow-

[FI-4002, F1-4007, FI-4014, FI-4036, FI4037]

Basis:

This EAL assures that in the event of a prolonged total loss of feedwater, timely recognition of the loss of heat sink occurs.

Therefore, this condition is indicative of actual or imminent substantial core degradation with potential adverse consequences on the public health and safety. A GENERAL EMERGENCY is warranted.

References:

NUREG 0654, Appendix 1 Initiating Condition: General Emergency 5b Page 30 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: Loss of Electrical Power EAL 3.1.1.1 Sub-Category: Loss of Vital AC Power Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Loss of all offsite AC capability to vital buses as indicatedby the inability to power BOTH buses A-05 IAND A-06 of a given unit from offsite sources for greaterthan 15 minutes. I Basis:

Prolonged loss of offsite AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete loss of AC power (station blackout). Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Therefore, this condition (which is indicative of degraded conditions, but with no adverse consequences on the public health and safety) is classified as an UNUSUAL EVENT.

If primary to secondary leakage also exists, see EAL 2.4.1.3.

References:

FSAR Section 8, Electrical Systems DBD-22, 4160 VAC System NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 7a Page 31 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Loss of Electrical Power EAL 3.1.1.2 Sub-Category: Loss of Vital AC Power Emergency Classification: ALERT Emergency Action Level:

Loss of all safeguard bus AC power of a given unit as indicatedby the inability to power BOTH buses A-05 AND A-06, OR B-03 AND B-04.

AND Loss is for less than 15 minutes.

Basis:

Loss of all AC power safeguards buses compromises critical plant safety functions including RHR, ECCS, containment heat removal, and maintaining the ultimate heat sink. Prolonged loss of all AC power safeguards buses may result in uncovering the core and loss of containment integrity, thus this event can escalate to a General Emergency. The site blackout coping analysis assumes that AC power can be restored in one hour.

This condition is entered when there are indications of a total loss of power to the safeguards buses A-05 and A-06 OR B-03 and B-04 from any source (on or off-site) for less than 15 minutes.

This condition is indicative of actual or potential substantial degradation to plant systems with possible adverse consequences on the public health and safety. An ALERT is warranted and must be declared.

This EAL escalates to a SITE EMERGENCY if loss of AC power continues for greater than 15 minutes.

References:

FSAR Section 8, Electrical Systems DBD-22, 4160 VAC System NUREG 0654, Appendix 1 Initiating Condition: Alert 7 Page 32 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALg)

Category: Loss of Electrical Power EAL 3.1.1.3 Sub-Category: Loss of Vital AC Power Emergency Classification: SITE EMERGENCY Emergency Action Level:

Loss of all safeguard bus ACpower of a given unit as indicated by the inability to power BOTH buses A-05 AND A-06, OR B-03 AND B-04.

AND Loss is for greaterthan 15 minutes.

Basis:

Loss of all AC power safeguards buses compromises critical plant safety functions including RHR, ECCS, containment heat removal, and maintaining the ultimate heat sink. Prolonged loss of all AC power safeguards buses may result in the uncovering core and loss of containment integrity, thus this event can escalate to a General Emergency. The site blackout coping analysis assumes that AC power can be restored in one hour.

This condition is entered when there are indications of a total loss of power to the safeguards buses A-05 and A-06 OR B-03 and B-04 from any source (on or off-site) for more than 15 minutes.

Therefore, this condition (which is indicative of serious plant system conditions with adverse consequences on the public health and safety) is classified as a SITE EMERGENCY.

References:

FSAR Section 8, Electrical Systems DBD-22, 4160 VAC System NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 6 Page 33 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALi)

Category: Loss of Electrical Power EAL 3.1.1.4 Sub-Category: Loss of Vital AC Power Emergency Classification: GENERAL EMIERGENCY Emergency Action Level:

Loss ofall safeguardbus AC power of a given unit as indicated by the inability to power BOTH buses A-05 AND A-06, OR B-03 AND B-04.

AND Loss is greater than 15 minutes.

AND Bothl narrow range SIG level less than [51%o] 29% AND totalfeedwaterflow to SIGs less than 200 gpm.

(ST-3 Heat Sink Red path)

Basis:

Loss of all AC power safeguards buses compromises critical plant safety functions including RHR, ECCS, containment heat removal, and maintaining the ultimate heat sink. Prolonged loss of all AC power safeguards buses may result in the uncovering core and loss of containment integrity, thus this event can escalate to a General Emergency. The site blackout coping analysis assumes that AC power can be restored in one hour.

This EAL assures that in the event of a prolonged station blackout, timely recognition of the loss of heat sink occurs.

Therefore, this condition is indicative of grave plant conditions with potential adverse consequences on the public health and safety. A GENERAL EMERGENCY is warranted and must be declared.

References:

FSAR Section 8, Electrical Systems DBD-22, 4160 VAC System NUREG 0654, Appendix 1 Initiating Condition: General Emergency 5d Page 34 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Loss of Electrical Power EAL 3.1.2.1 Sub-Category: Loss of Vital AC Power Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Loss of all onlsite AC power capabilityto power BOTH buses A-05 AND A-06 of a given unitfromn onsite sources (GOI through G04) for greaterthan 15 minutes.

Basis:

Loss of onsite safety related AC power sources reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete loss of AC power (station blackout). Therefore, an Unusual Event is warranted and must be declared. Fifteen minutes was selected as a threshold to exclude transient losses.

This condition is entered when there are indications of the unavailability of all the emergency diesel generators (GO 1 through G04) or that none of these sources can be aligned to either A-05 or A-06 for greater than 15 minutes.

Therefore, this condition (which is indicative of degraded conditions, but with no adverse consequences on the public health and safety) is classified as an Unusual Event.

References:

FSAR Section 8, Electrical Systems DBD-22, 4160 VAC System NTUREG 0654, Appendix 1 Initiating Condition: Unusual Event 7b Page 35 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: Loss of Electrical Power EAL 3.2.1.2 Sub-Category: Loss of Vital DC Power Emergency Classification: ALERT Emergency Action Level:

Loss of all vital DC power as indicatedby less than 105 vdc on all station battery buses (DO1, D02, D03, D04)for less than 15 minutes.

Basis:

Loss of all vital DC power compromises the ability to monitor and control plant safety functions.

Prolonged loss of all DC power may result in uncovering the core and loss of containment integrity.

Loss of DC power to any AC bus creates the following conditions:

1. Associated breakers cannot be electrically opened or closed remotely or locally;

2. Electrical protection/interlock tripping of associated breakers is rendered inoperable including undervoltage stripping. The one exception is the 480 V individual breaker overloads which remain operable;

3. All associated breaker positions remain AS IS.

Loss of all vital onsite DC power may also be indicated by an "Annunciator Power Failure" alarm.

This EAL escalates to a SITE EMERGENCY if the power loss continues for greater than 15 minutes.

References:

FSAR Section 8, Electrical Systems DBD-19, 125 VDC System NTUREG 0654, Appendix 1 Initiating Condition: Alert 8 Page 36 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNMSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Loss of Electrical Power EAL 3.2.1.3 Sub-Category: Loss of Vital DC Power Emergency Classification: SITE EMIERGENCY Emergency Action Level:

Loss of all vital DCpower as indicatedby less than 105 vdc on all station battery buses (DO1, D02, D03, D04) for greaterthan 15 minutes.

Basis:

Loss of all vital DC power compromises the ability to monitor and control plant safety functions.

Prolonged loss of all DC power may result in uncovering the core and loss of containment integrity.

Loss of DC power to any AC bus creates the following conditions:

1. Associated breakers cannot be electrically opened or closed remotely or locally;

2. Electrical protection/interlock tripping of associated breakers is rendered inoperable including undervoltage stripping. The one exception is the 480 V individual breaker overloads which remain operable.

3. All associated breaker positions remain AS IS.

Loss of all vital onsite DC power may also be indicated by an "Annunciator Power Failure" alarm.

This condition (which is indicative of possible loss of control of the reactor coolant and containment barriers, with possible adverse consequences on the public health and safety) is classified as a SITE EMERGENCY.

References:

FSAR Section 8, Electrical Systems DBD-19, 125 VDC System NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 7 Page 37 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL9)

Category: Radiological Conditions EAL 4.1.1.1 Sub-Category: Off-site Radiological Release Emergency Classification: UNUSUAL EVENT Emergency Action Level:

V'ent radiationreading(s) exceed the high alarn setpointsfor greater than 60 minutes, OR Liquid release in excess of high alann setpoints which cannot be isolated.

Vent Radiation High Alarm Setpoints Reference RMSARB for current 9/99 I setpoint values 1 RE 212 2.73 E-4 uCi/cc if purging, 1.62E-2 if forced vent.

I RE 215 2.71 E+0 uCi/cc RE 214 1.02 E-4 uCi/cc RE221 1.58E-4 uCi/cc RE 224 2.09 E-3 uCi/cc RE 225 1.36 E+0 uCi/cc 2 RE 212 1.78 E-4 uCi/cc if purging, 1.82E-2 if forced vent.

2 RE 215 2.71 E + 0 uCi/cc Liquid Release Limits Service Water Discharge Waste Water Effluent 1(2) RE-229 High Alarm RE-230 High Alarm AND:

AND:

1 Circ. Water pump Release Limit 1 Circ. Water pump AND: (uCi/cc): Release Limit (uCi/cc):

2 Service Water pumps 4.12 E-5 3.70 E-4 3 Service Water pumps 3.27 E-5 4 Service Water pumps 3.03 E-5 5 Service Water pumps 2.87 E-5 6 Service Water pumps 2.78 E-5 2 Circ. Water pump Release Limit 2 Circ. Water pump AND: (uCi/cc): Release Limit (uCilcc):

2 Service Water pumps 7.00 E-5 6.29 E-4 3 Service Water pumps 5.56 E-5 4 Service Water pumps 5.15 E-5 5 Service Water pumps 4.88 E-5 6 Service Water pumps 4.73 E-5

Reference:

C.H. Onesti to G.J. Maxfield, 11/17/92, RE-229 and RE-230 Alarm Setpoints, NPM 92-1035.

Page 38 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NTNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL9)

Basis:

Unplanned airborne releases in excess of the site technical specifications, that cannot be reduced to within technical specifications within 60 minutes, represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the Unusual Event emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not controlled to within Technical Specification limits within 60 minutes.

Therefore, it is not intended that the release be averaged over 60 minutes. For example, a release of 2 times Technical Specifications for 30 minutes, but which is terminated, does not exceed this EAL.

However, the SM should not wait until 60 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or will likely exceed 60 minutes.

Likewise, liquid release values (which would result in very low integrated dose) are not the primary concern. Rather, the fact that the release cannot be isolated represents a potential degradation in the level of safety.

References:

STPT 13.4, Effluent Monitors NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 2 Page 39 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: Radiological Conditions EAL 4.1.1.2 Sub-Category: Off-site Radiological Release Emergency Classification: ALERT Emergency Action Level:

Vent radiation readingsexceed ten times the high alarm setpointsfor greaterthan 15 minutes.

OR Liquid release in excess of ten times high alann setpoint which cannot be isolated.

10 times Vent Radiation High I Reference RMSARB for current setpoint values Alarm Setpoints 9/99 1 RE 212 2.73 E-3 uCi/cc if purging, 1.62E-1 if forced vent 1 RE 215 2.71 E+1 uCi/cc RE 214 1.02 E-3 uCi/cc RE221 1.58E-3 uCi/cc RE 224 2.09 E-2 uCi/cc RE 225 1.36 E+1 uCi/cc 2 RE 212 1.78 E-3 uCi/cc if purging, 1.82E-1 if forced vent 2 RE 215 2.71 E+1 uCi/cc K f Liquid Release Limits Service Water Discharge Waste Water Effluent 1(2) RE-229 High Alarm RE-230 High Alarm AND:

AND:

1 Circ. Water pump Ten times Release 1 Circ. Water pump AND: Limit (uCi/cc): Ten times Release Limit (uci/cc):

2 Service Water pumps 4.12 E-4 3.70 E-3 3 Service Water pumps 3.27 E-4 4 Service Water pumps 3.03 E-4 5 Service Water pumps 2.87 E-4 6 Service Water pumps 2.78 E-4 2 Circ. Water pump Ten times Release 2 Circ. Water pump AND: Limit (uCi/cc): Ten times Release Limit (uci/cc):

2 Service Water pumps 7.00 E-4 6.29 E-3 3 Service Water pumps 5.56 E-4 4 Service Water pumps 5.15 E-4 5 Service Water pumps 4.88 E-4 6 Service Water pumps 4.73 E-4

Reference:

C.H. Onesti to G.J. Maxfield, 11/17/92, RE-229 and RE-230 Alarm Setpoints, NPM 92-1035.

Page 40 of 97 REFERENCE USE

POlNT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NN1SR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Basis:

Release rates in excess of ten times technical specifications which continue for 15 minutes or longer represent a serious situation. Ideally, most releases will begin small, then increase, hence will progress through the Unusual Event classification, allowing time to stop or mitigate them. Assuming this is the case, significant time has passed during which attempts to reduce or terminate the release have failed.

Therefore the required release duration for meeting this EAL was reduced to 15 minutes in recognition of the increased severity.

The final integrated dose (which is still expected to be low at these release rates) is not the primary concern here; it is the degradation in plant control implied by the fact that the release cannot be controlled.

Likewise, liquid release values (which would result in very low integrated dose) are not the primary concern. Rather, the fact that the release cannot be isolated represents a potential degradation in the level of safety.

References:

STPT 13.4, Effluent Monitors NUREG 0654, Appendix 1 Initiating Condition: Alert 15 Page 41 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 A1TACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Radiological Conditions EAL 4.1.1.3 Sub-Category: Off-site Radiological Release Emergency Classification: SITE EMERGENCY Emergency Action Level:

a. Effluent monitors detect levels correspondingto either:

(1) 0.1 Rein Total Effective Dose Equivalent (TEDE).

(2) 0.5 Rem thyroid Committed Dose Equivalent (CDE) at the site boundaryunder actual meteorological conditions.

b. Eitherof the above doses mneasured in the environs.

c. Either of the above doses projected based on plantparameters.

Basis:

The 0.1 rem TEDE is based on the 10 CFR 20 annual average population exposure. This value also provides a desirable gradient (one order of magnitude) between the Site Emergency and General Emergency classes. It is deemed that exposures less than this limit are not consistent with the Site Emergency class description. The 0.5 Rem CDE thyroid dose was established in consideration of the 1:5 ratio of the EPA Protective Action Guidelines for whole body to thyroid.

Dose projection can be based on values obtained from effluent monitors, direct measurements taken in the environment, or any other appropriate plant parameters.

Integrated doses are not monitored in real-time but are projected. In establishing the duration used for the projection, care should be exercised to ensure the time estimates are realistic. If no educated guess can be made regarding estimated duration, the default (4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) shall be used.

References:

NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 13a EPPOS 1, on acceptable Deviation from Appendix 1 of NUREG 0654 EPA 400 Manual of Protective Action Guides and Protective Actions for Nuclear Incidents Page 42 of 97 REFERENCE USE

POINT BEACH NTUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALsD Category: Radiological Conditions EAL 4.1.1.4 Sub-Category: Off-site Radiological Release Emergency Classification: GENERAL EMERGENCY Emergency Action Level:

a. Effluent monitors detect levels correspondingto either:

(1) 1 Rem Total Effective Dose Equivalent (TEDE).

(2) 5 Rem thyroid Commziitted Dose Equivalent (CDE) at the site boundary under actual meteorologicalconditions.

b. Eitherof the above doses measured in the environs.

c. Either of the above doses projected based on plant parameters.

Basis:

The 1 REM TEDE and the 5 REM CDE thyroid integrated doses are based on the EPA protective action guidance which indicates that public protective actions are indicated. This is consistent with the emergency class description for a General Emergency.

Dose projection can be based on values obtained form effluent monitors, direct measurements taken in the environment, or from any other appropriate plant parameters.

Integrated doses are not monitored in real-time but are projected. In establishing the duration used for the projection, care should be exercised to ensure the time estimates are realistic. If no educated guess can be made regarding estimated duration, the default (4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) shall be used.

References:

NUREG 0654, Appendix 1 Initiating Condition: General Emergency la EEPOSI, EPPOS on Acceptable Deviation from Appendix 1 of NUREG 0654 EPA 400 Manual of Protective Action Guides and Protective Actions for Nuclear Incidents Page 43 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: Radiological Conditions EAL 4.2.1.2 Sub-Category: In-Plant Radiological Conditions Emergency Classification: ALERT Emergency Action Level:

Loss of control of radioactivematerial resulting in area radiationexceeding lOOOX normal (or expected) levels within the ProtectedArea. Nonral may be detenrined by trend recorderor other relevant data.

Basis:

By themselves indications of increased levels of radiation would only meet the Unusual Event class description (potential degradation in the level of safety). However, there is no specific Unusual Event EAL on increased radiation. This would be a judgment call by the SM. However, when increased radiation of this magnitude (1000x) is combined with "loss of control" a higher classification is warranted. Non-essential personnel should be assembled to ensure their safety. Additional manpower or other resources may be needed. The ALERT classification is appropriate.

The operative phrase in this EAL is "loss of control". Combined with this is the phrase "or expected levels". For most plant evolutions increases of radiation can be estimated, most within a factor of 1000.

If, in the judgment of those concerned, control has been lost, AND radiation levels increase beyond 1000X normal or expected levels, this EAL is met.

References:

NUREG 0654, Appendix 1 Initiating Condition: Alert 6 Page 44 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NTNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATYIACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Internal Events EAL 5.1.1.1 Sub-Category: Security Threats Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Bomb, credible bomb threat, indication of sabotage, or attempted entry into the ProtectedArea by a hostile force.

Basis:

This EAL is based on the PBNP Security Plan/ISFSI Security Plan. An actual bomb, credible bomb threat, act of sabotage, or attempted entry into the Protected area by a hostile force indicates a potential degradation in the level of safety at the plant. Therefore an Unusual Event classification is warranted.

The Protected Area Physical Barrier is defined in the Security Plan/ISFSI Plan.

A bomb discovered in or near a Plant Vital Area which could affect Safety-Related Functions would result in escalation of the emergency classification. An actual explosion (of a bomb or other source) would be classified based on EALs 5.3.1.1 through 5.3.1.3 depending upon its effects.

Security events that do not represent at least a potential degradation in the level of plant safety are reported under either 10 CFR 73.71 or 10 CFR 50.72 and do not require implementation of the Emergency Plan. Accidental, non-hostile entry, although reportable as a security event, does not warrant declaration of an emergency. The operative consideration is 'intent'. If no malicious intent is determined the EAL does not apply.

References:

SSCP - Security and Safeguards Contingency Plan NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 12 Page 45 of 97 REFERENCE USE

POShT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Internal Events EAL 5.1.1.2 Sub-Category: Security Threats Emergency Classification: ALERT Emergency Action Level:

Intnrsion into the ProtectedArea b a hostile force.

Basis:

For the purposes of this EAL, the intrusion into the Protected Area can be considered a significant security threat. An Alert classification is warranted. If entry is attempted, but not gained by a hostile force see the Unusual Event EAL.

The Protected Area Physical Barrier is defined in the Security Plan. Note: The Independent Spent Fuel Storage Installation (ISFSI) is a separate Protected Area.

Intrusion into a Plant Vital Area escalates this event to a Site Emergency.

Security events that do not represent at least a potential degradation in the level of plant safety are reported under either 10 CFR 73.71 or 10 CFR 50.72 and do not require implementation of the Emergency Plan. Accidental, non-hostile entry, although reportable as a security event, does not warrant declaration of an emergency. The operative consideration is 'intent'. If no malicious intent is determined the EAL does not apply.

References:

SSCP - Security and Safeguards Contingency Plan NUREG 0654, Appendix 1 Initiating Condition: Alert 16 Page 46 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Internal Events EAL 5.1.1.3 Sub-Category: Security Threats Emergency Classification: SITE EMIERGENCY Emergency Action Level:

I Intnrsion into a plant Vital Area by hostile force. I Basis:

Hostile takeover of Vital Areas could lead to loss of physical control of the plant. Therefore a Site Emergency classification is warranted. The Plant Vital Areas are defined in the Security Plan.

Security events that do not represent at least a potential degradation in the level of plant safety are reported under either 10 CFR 73.71 or 10 CFR 50.72 and do not require implementation of the Emergency Plan. Accidental, non-hostile entry, although reportable as a security event, does not warrant declaration of an emergency. The operative consideration is 'intent'. If no malicious intent is determined the EAL does not apply.

References:

SSCP - Security and Safeguards Contingency Plan NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 14 Page 47 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Internal Events EAL 5.1.1.4 Sub-Category: Security Threats Emergency Classification: GENERAL EMERGENCY Emergency Action Level:

A Security Event which results in either:

Loss of physical control of the Control Room OR Loss of remote shutdown capability.

Basis:

This EAL encompasses conditions under which unauthorized personnel have taken physical control of vital areas required to reach and maintain safe shutdown, with the potential that the intruders can cause a significant event with damage to plant systems, damage to the core, and ultimately a release of large amounts of radioactivity.

References:

SSCP - Security and Safeguards Contingency Plan AOP-1OA, Safe Shutdown - Local Control NUREG 0654, Appendix 1 Initiating Condition: General Emergency 3 Page 48 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMIENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Internal Events EAL 5.2.1.2 Sub-Category: Control Room Habitability EmergencyClassification: ALERT Emergency Action Level:

Evacuation of the Control Room has been initiatedwith control of shutdown systems establishedfroml local stations.

Basis:

AOP-1OA directs shutdown activities performed outside the Control Room.

This EAL does not imply that all actions associated with Alternate Shutdown shall be completed in order to avoid the higher EAL pertaining to Control Room evacuation (EAL 5.2.1.3). If the reactor successfully trips, if level, pressure, temperature, etc., are being controlled, and no impediments to the associated Shutdown activities are being encountered, this emergency classification is appropriate. If impediments are being encountered in completing critical Shutdown functions, and more than 15 minutes expire, EAL 5.2.1.3 is met.

Located within the Control Room are the controls, indications, annunciators, and communications equipment necessary for the safe operation of the plant. The ability to assess and control plant conditions and abnormal situations is significantly degraded without access to the Control Room.

With the Control Room evacuated, additional support, monitoring, and direction through the resources of the TSC and/or other emergency facilities is assumed to be necessary - therefore, the declaration of an Alert is appropriate and required.

References:

AOP-1OA, Safe Shutdown - Local Control NUREG 0654, Appendix 1 Initiating Condition: Alert 20 Page 49 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL9)

Category: Internal Events EAL 5.2.1.3 Sub-Category: Control Room Habitability Emergency Classification: SITE EMERGENCY Emergency Action Level:

Evacuation of the Control Room without establishment of plant controlfromn remote shutdown stations within approximately 15 minutes.

Basis:

Located within the Control Room are the controls, indications, annunciators, and communications equipment necessary for the safe operation of the plant. The ability to assess and control plant conditions and abnormal situations is significantly degraded without access to the Control Room.

Once the Control Room is evacuated, if control is not established from remote shutdown stations within a reasonable amount of time (approximately 15 minutes), a significant threat to multiple fission product barriers exists should a plant transient or other emergency condition occur. If plant control cannot be established within this time frame, declaration of a Site Emergency is warranted due to extended lack of control of the plant.

Escalation to a higher classification, if appropriate, will be based on system malfunctions, fission product barrier degradation, radiation levels, or Emergency Director judgment.

References:

AOP-1OA, Safe Shutdown - Local Control NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 18 Paae 50 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLANT IMPLEMENTINGJPROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Internal Events EAL 5.3.1.1 Sub-Category: Fire / Explosion Emergency Classification: UNUSUAL EVENT Emergency Action Level:

I Near or on-site explosion as reported to Shift Managerby plant personnel making visual observation. I Basis:

No attempt is made in this EAL to assess the magnitude of damage. Reports of any explosion is sufficient for declaration.

On-site is defined as the exclusion area which is the area within the site boundary surrounding PBNP in which the plant personnel have the authority to determine all activities including exclusion or removal of personnel and property from the area. At PBNP the outer boundary of the exclusion area is coincident with the site boundary. (Reference Appendix C of Emergency Plan).

As used here, an explosion is a rapid, violent, unconfined combustion or a catastrophic failure of pressurized equipment imparting significant energy to nearby structures and materials. If the explosion damages Safety Systems the event escalates to an Alert or Site Emergency.

The security aspects of the explosion should be considered.

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 14c SSCP - Security and Safeguards Contingency Plan Page 51 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Internal Events EAL 5.3.1.2 Sub-Category: Fire / Explosion Emergency Classification: ALERT Emergency Action Level:

I Explosion affecting operability of one (1) train of safety systems.

Basis:

Safety systems as used here designates systems with safety-related functions. Attachment D lists safety systems and systems with safety-related functions.

Only explosions that actually cause damage to equipment required for safe operation AND only damage that renders a single train of a safety system unable to perform its intended safety function meet the threshold of this EAL. A lengthy damage assessment should not be performed. The occurrence of the explosion with evidence of damage likely to prevent one train from performing its intended safety function is sufficient for declaration.

As used here, an explosion is a rapid, violent, unconfined combustion, or catastrophic failure of pressurized equipment that imparts significant energy to nearby structures and equipment.

If the explosion damages more than one train of a Safety System the event escalates to a Site Emergency.

The security aspects of the explosion should be considered.

References:

NUREG 0654, Appendix 1 Initiating Condition: Alert 1Sc Page 52 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALi)

Category: Internal Events EAL 5.3.1.3 Sub-Category: Fire / Explosion Emergency Classification: Site Emergency Emergency Action Level:

Explosion affecting operabilityof tvo (2) trains of safety systems.

Basis:

Safety systems as used here designates systems with safety-related functions. Attachment D lists safety systems and systems with safety-related functions.

Only explosions that actually cause damage to equipment required for safe operation of more than one safety system train AND only damage that affects the systems' ability to perform intended functions meet the threshold of this EAL. A lengthy damage assessment should not be performed. An immediate assessment of the probability of damage making multiple trains incapable of performing their safety function is all that is required. The occurrence of the explosion with evidence of damage likely to prevent the equipment in more than one train of a safety system from performing intended safety functions is sufficient for declaration.

As used here, an explosion is a rapid, violent, unconfined combustion, or catastrophic failure of pressurized equipment that imparts significant energy to nearby structures and equipment.

If only one train of a safety system is affected, see ALERT classification EAL.

The security aspects of the explosion should be considered.

References:

lNrUREG 0654, Appendix I Initiating Condition: Alert 1Sc Page 53 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALi)

Category: Internal Events EAL 5.3.2.1 Sub-Category: Fire / Explosion Emergency Classification: UNUSUAL EVENT Emergency Action Level:

I Firewithin the ProtectedArea lasting more than 10 minutes after use of fire extinguishing equipment. l Basis:

The purpose of this EAL is to address fires which are potentially significant precursors to damage to safety systems. This condition applies to buildings or areas contiguous to.plant vital areas or other significant buildings or areas.

Specifically excluded are small fires within administration buildings, wastebasket fires, or fires in areas of no safety consequence.

k,.j Escalation to a higher emergency class occurs if the fire affects one or more train(s) of a Safety System(s).

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 10 Page 54 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMAERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: Internal Events EAL 5.3.2.2 Sub-Category: Fire / Explosion Emergency Classification: ALERT Emergency Action Level:

Fire affecting operability of one (1) train of a safety system. I Basis:

Safety systems as used here designates systems with safety-related functions. Attachment D lists safety systems and systems with safety-related functions.

This condition is entered when the Fire Brigade Leader reports a fire affects one train of a safety system or if Control Room Operators become aware of indications of impact to a safety system after a fire has been reported.

Only those fires that actually cause damage to equipment as reported by the Fire Brigade Leader or as noted by Control Room operators meet this EAL.

Escalation to a higher emergency class, if appropriate, is based on further system malfunctions, fission product barrier degradation, abnormal radiation levels, or Emergency Director judgment.

References:

NUREG 0654, Appendix 1 Initiating Condition: Alert 13 Page 55 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALi)

Category: Internal Events EAL 5.3.2.3 Sub-Category: Fire / Explosion Emergency Classification: SITE EMERGENCY Emergency Action Level:

Fireaffecting operabilityof Avo (2) trains of safety systems.

Basis:

Safety systems as used here designates systems with safety-related functions. Attachment D lists safety systems and systems with safety-related functions.

This condition is entered when the Fire Brigade Leader reports a fire that affects more than one train of a safety system or if Control Room Operators become aware of indications of impact on more than one train of a safety system after a fire has been reported.

Only fires that actually cause damage to equipment required for safe operation of more than one safety system train AND only damage that affects the systems' ability to perform intended functions meet the threshold of this EAL. A lengthy damage assessment should not be performed. An immediate assessment of the probability of damage making multiple trains incapable of performing their safety function is all that is required. The occurrence of a fire with evidence of damage likely to prevent the equipment in more than one train of a safety system from performing intended safety functions is sufficient for declaration.

This condition is indicative of severe degradation of the level of safety at the plant with possible adverse consequences on the public health and safety. A Site Emergency is warranted.

Escalation to a higher emergency class, if appropriate, will be based on fission product barrier degradation or emergency management judgment.

References:

NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 11 Page 56 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALi)

Category: Internal Events EAL 5.4.1.1 Sub-Category: Turbine Rotating Component Failures Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Visual conlfinnation of turbine housing penetration by a blade or rotating component.

Basis:

This initiation condition addresses the consequences of turbine failure and turbine missile effects.

Analyses documented in the FSAR on the consequences of turbine overspeed indicate that there would be only a low energy missile generated external to the low pressure turbine casing in the event of a turbine overspeed.

The study determined that the following components are subject to the possible effects of a turbine missile: one main steam line, the condensate storage tanks, reactor makeup water storage tanks, the reactor makeup water storage tank pumps, the refueling water storage tank, diesel generator fuel oil line, and the service water pump electrical leads. These components should be evaluated for damage.

Escalation to a higher emergency classification, if appropriate, is based on further missile damage from any source, system malfunctions, fission product barrier degradation, abnormal radiation levels, or emergency management judgment.

References:

WCAP 7525-L, Likelihood and Consequences of Turbine Overspeed at the Point Beach Nuclear Plant.

Reg Guide 1.115, Protection Against Low-Trajectory Turbine Missiles FSAR 14.1.12, Likelihood of Turbine-Generator Unit Overspeed NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 14e and Alert 18e Page 57 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL9)

Category: External Events EAL 6.1.1.1 Sub-Category: Natural Destructive Phenomena Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Any earthquakefelt by Control Room Operators.

OR An indicatorlight on two or more of thefollowing Seismic Event Monitors SEI-6210 #3 Warehouse SEI-6211 Unit 1 Facade SEI-6212 Drum Prep Room SEI-6213 El. 8'between vital switchgear room and auxfeedwater tunnel Basis:

As defined in the EPRI sponsored "Guidelines for Nuclear Plant Response to an Earthquake," dated October 1989, a "felt earthquake" is:

An earthquake of sufficient intensity such that: (a) the ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic detectors of the plant are activated.

The seismic event monitors are set to alarm at 0.01g. Minor damage to some portions of the site may occur at these levels but should not affect the ability to safely operate the plant. Additional inspections may be desired to determine the extent of any damage. Therefore an Unusual Event classification is warranted.

This EAL requires two valid seismic alarms to eliminate classification due to plant operations or maintenance activities, such as heavy equipment moving near the monitor or an accidental impact to a monitor. Further validation may be accomplished by contacting the University of Wisconsin - Milwaukee Seismic Center.

Page 58 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

References:

PBNP FSAR, Appendix A Setpoint Document STPT 22.1, Seismic Event Monitoring EPRI Document, "Guidelines for Nuclear Plant Response to an Earthquake," dated October, 1989 NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 13a Page 59 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALU)

Category: External Events EAL 6.1.1.2 Sub-Category: Natural Destructive Phenomena Emergency Classification: ALERT Emergency Action Level:

Valid Seismic Event Monitor readings of an intensity greaterthan 0.04g vertical or 0.06g horizontal. I Basis:

This EAL addresses events that may have resulted in the plant's vital equipment being subjected to forces beyond operational limits. Therefore an Alert classification is warranted. Classification should occur prior to a detailed damage assessment.

Values in this EAL are based on the Operating Basis Earthquake (OBE) limits (ground accelerations of

.04g vertical and .06g horizontal) as defined by the FSAR.

Validation of seismic activity would be by severe ground shaking or by contacting University of Wisconsin - Milwaukee Seismic Center (Emergency Telephone Directory).

References:

PBNP FSAR, Appendix A Setpoint Document STPT 22.1, Seismic Event Monitoring EPRI Document, "Guidelines for Nuclear Plant Response to an Earthquake," dated October 1989 NUREG 0654, Appendix 1 Initiating Condition: Alert 17a Page 60 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: External Events EAL 6.1.1.3 Sub-Category: Natural Destructive Phenomena Emergency Classification: SITE EMERGENCY Emergency Action Level:

Valid Seisrnic Event Monitor readings bf an intensity greaterthan 0.08g vertical or 0.12g horizontal.

Basis:

This EAL addresses events that may have resulted in the plant's vital equipment being subject to forces that may prevent safe shutdown and cooldown of the plant. Therefore a Site Emergency classification is warranted. Classification should occur prior to a detailed damage assessment.

Values in this EAL are based on the Safe Shutdown Earthquake (SSE) limits (ground accelerations of

.08g vertical and .12g horizontal) as defined by the FSAR.

Validation of seismic activity would be by severe ground shaking or by contacting University of Wisconsin - Milwaukee Seismic Center (Emergency Telephone Directory).

References:

PBNP FSAR, Appendix A Setpoint Document STPT 22.1, Seismic Event Monitoring EPRI Document, "Guidelines for Nuclear Plant Response to an Earthquake," dated October 1989 NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 15a Page 61 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: External Events EAL 6.1.2.1 Sub-Category: Natural Destructive Phenomena Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Any tonzado visible from the site. l Basis:

This EAL is based on the assumption that a tornado may potentially damage plant or systems.

An Unusual Event classification is warranted.

This condition is entered when a tornado is reported to the Shift Manager by plant personnel making visual observation.

Site is defined as the exclusion area which is the area within the site boundary surrounding PBNP in which the plant personnel have the authority to determine all activities including exclusion or removal of personnel and property from the area. At PBNP, the outer boundary of the exclusion area is coincident with site boundary. (Reference Appendix C of Emergency Plan).

If damage to safety-related equipment is confirmed (either by observation or plant instrumentation) the event may be escalated to an Alert. Other EALs should also be considered such as loss of electrical power.

References:

AOP-13C, Severe Weather Conditions Probabilistic Safety Assessment -- High Winds, and Others Sec 9, Rev 0, Dated July 1995 NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 13c Page 62 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NN SR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL9)

Category: External Events EAL 6.1.2.2 Sub-Categorv: Natural Destructive Phenomena Emergency Classification: ALERT Emergency Action Level:

Indicationsor observations that a tornado has damaged a vital stnicture.

OR WMind speed indicatedas >90 MPH.

Basis:

This EAL addresses events that may have resulted in a plant area being subjected to forces approaching or beyond design limits. It is assumed that damage may have occurred to plant safety systems.

Therefore an Alert classification is warranted. Classification should occur prior to a detailed damage assessment.

The 100 MPH indicated wind speed was chosen as a value approaching the design basis for non-Class 1 metal structures at the plant. Although no damage to permanent plant structures should occur at this level, non-permanent structures (trailers, work shacks, temporary storage, etc.) could have significant damage and impact plant operations. Winds at this level would also impact personnel movement within and to the plant.

References:

AOP-13C, Severe Weather Conditions FSAR 5.1, Containment System Structure Probabilistic Safety Assessment -- High Winds, and Others Sec 9, Rev 0, Dated July 1995 Bechtel Corporation, "Westinghouse Electric Corporation--Wisconsin Michigan Power Company--Point Beach Atomic Power Station--Design Criteria for Nuclear Power Plants Against Tornadoes,"

March 12, 1970, B-TOP-3.

NUREG 0654, Appendix I Initiating Condition: Alert 17c Page 63 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: External Events EAL 6.1.2.3 Sub-Category: Natural Destructive Phenomena Emergency Classification: SITE EMERGENCY Emergency Action Level:

Sustained winds greaterthan 100 MPH AND Reports or indicationsof damage to vital equipmnent or strictures.

Basis:

This EAL addresses events that have resulted in plant areas being subjected to forces beyond design limits. It is assumed that substantial damage has occurred to plant structures with probable damage to safety systems.

It is inferred from Section 5.1 in the FSAR that the design straight wind speed of 108 mph was used in the design of the non-Class 1 metal structures. This is consistent with the Bechtel topical report.

100 mph was used in this EAL due to limitations of available instrumentation.

Therefore, this condition is indicative of serious plant system conditions with possible adverse consequences on the public health and safety. A Site Emergency is warranted.

Emergency classifications under other EALs may also be appropriate due to offsite effects caused by high winds, particularly status of offsite power lines.

References:

AOP-13C, Severe Weather Conditions FSAR 5.1, Containment System Structure Probabilistic Safety Assessment -- High Winds, and Others Sec 9, Rev 0, Dated July 1995 Bechtel Corporation, "Westinghouse Electric Corporation--Wisconsin Michigan Power Company--Point Beach Atomic Power Station--Design Criteria for Nuclear Power Plants Against Tornadoes,"

March 12, 1970, B-TOP-3.

NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 15c Page 64 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALi)

Category: External Events EAL 6.2.1.1 Sub-Category: High Lake/Low Forebay Water Level Emergency Classification: UNUSUAL EVENT.

Emergency Action Level:

Less than -11 /forebay or pump bay level with one unit's CW purnps off, Basis:

This condition is considered a potential degradation in the level of safety of the plant due to Circulating Water Pumps and/or Service Water losing suction. Water levels at or below these levels impairs the ability of these pumps to provide water to their loads, and may result in subsequent loss of the safety function of the ultimate heat sink. Therefore, an Unusual Event classification is warranted.

References:

AOP-5A, Loss of Condenser Vacuum AOP-13A, Circulating Water System Malfunction NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 13b Page 65 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: External Events EAL 6.2.2.1 Sub-Category: High Lake/Low Forebay Water Level Emergency Classification' UNUSUAL EVENT Emergency Action Level:

I Any flooding which precludes access to the site or areas of the plant.

Basis:

This condition is considered to be a potential degradation in the level of safety of the plant due to limited access to the site or potential safety concerns for onsite personnel. Therefore an Unusual Event classification is warranted.

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 13b Page 66 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: External Events EAL 6.2.2.2 Sub-Category: High Lake/Low Forebay Water Level Emergency Classification: ALERT Emergency Action Level:

I Flooding as indicatedby greater than 6" of water in the 8 foot elevation of the Turbine Bldg:;

Basis:

This EAL addresses an event that may result in a plant vital area being subjected to conditions beyond design limits adversely affecting plant safety systems. Therefore, this condition is indicative of abnormal plant conditions with possible adverse consequences on plant safety and is classified as an Alert.

This condition is entered when there is greater than six inches of water in the turbine hall. Although this EAL is in the category High Lak-e/Low Forebay, the cause of the flooding is not a factor. A broken Service Water or Circulating Water pipe could also create this condition.

The Turbine Building would flood before other plant areas, therefore it provides a representative indication of other possible problem areas. The feedwater pumps each sit on a base that is eight inches above the floor. The turbine seal oil pumps are approximately ten inches above the floor.

Escalation to a higher emergency class, if appropriate, will be based on Flooding in Vital Equipment Areas.

References:

NUREG 0654, Appendix 1 Initiating Condition: Alert 17b Page 67 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNISR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: External Events EAL 6.2.2.3 Sub-Category: High Lake/Low Forebay Water Level Emergency Classification: SITE EMERGENCY Emergency Action Level:

Greaterthan 2 'of water in vital switchgear room OR Greaterthan 2 'of water in auxiliaryfeedwater plump room.

Basis:

This EAL addresses conditions where plant vital equipment may be subjected to conditions beyond design limits, and damage may be assumed to have occurred to plant safety systems. Therefore, this condition is indicative of serious plant system conditions with possible adverse consequences on the public health and safety. A Site Emergency is warranted.

Plant vital area designations are contained in the PBNP Security Plan.

Water levels in excess of two feet in the vital switchgear room severely threaten safe plant operations.

Several 125-volt DC station batteries are installed in the vital switchgear room. The bottom and top of these batteries are 6 and 36 inches above the floor, respectively. Numerous electrical cabinets containing electrical components for the safety injection pumps, the station service transformers, and the 4.16 kV electrical system are also located in the room.

Water levels in excess of two feet in the auxiliary feedwater pump room threatens operation of the feedwater system and ultimately the ability to cool the reactor core. The turbine-operated auxiliary feedwater pumps are located approximately 18 inches above the floor and the motor operated auxiliary feedwater pumps are located approximately two feet above the floor. Additionally, the Source Range Output Expansion Control Panel is approximately two feet above the floor.

This EAL used to also contain criteria of greater than three feet of water in both EDG rooms, however this was before G03 and G04 were installed, hence spoke of G01 and G02 only. Due to the electrical arrangement of G03 and G04 as backups to GOI and G02 and the fact that G03 and G04 are at a significantly higher elevation, they have been removed from this EAL.

Emergency classifications under other EALs may be appropriate due to offsite effects caused by severe weather, particularly the status of offsite power lines.

Page 68 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNISR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHIMENT B EMERGENCY ACTION LEVELS (EAL§)

References:

SOER 85-5, Internal Flooding of Power Plant Buildings NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 15b Page 69 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: External Events EAL 6.3.1.1 Sub-Category: Toxic/Flammable Gas Intrusion Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Near or on-site flaminable or toxic gas release as reported to Shift Managerby plant personnel making visual observation.

Basis:

The release of toxic or flammable gas in or near the Exclusion Area may pose a potential threat to reactor plant and personnel safety. It is the potential threat to normal operation or hazard to personnel which must be evaluated. If no such threat exists, the EAL is not met. If, however, personnel safety or plant operation is threatened, an Unusual Event is warranted.

Flammable gases are typically more limiting than toxic gases. Although an SCBA could protect from toxicity, detonation of a flammable gas could be immediately hazardous to personnel.

On-site is defined as the exclusion area which is the area within the site boundary surrounding PBNP in which the plant personnel have the authority to determine all activities including exclusion or removal of personnel and property from the area. At PBNP, the outer boundary of the exclusion area is coincident with the site boundary.

References:

NUREG 0654, Appendix I Initiating Condition: Unusual Event 14d Page 70 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: External Events EAL 6.3.1.2 Sub-Catcgor: Toxic/Flammable Gas Intrusion Emergency Classification: ALERT Emergency Action Level:

l Entry of toxic or flaminable gas into a plant building atmosphereaffecting operation or access.

Basis:

The release of toxic or flammable gas significant enough to affect plant operation (i.e., initiate a plant transient or preclude access to plant equipment) warrants declaration of an Alert:

Flammable gases are typically more limiting than toxic gases. Although an SCBA could protect from toxicity, detonation of a flammable gas could be immediately hazardous to personnel. An area where access is not required for plant operation, which could be evacuated, does not warrant an Alert, but may warrant an Unusual Event if the potential exists to affect operation or personnel.

Any affected area normally accessed for plant operation (PAB, Turbine hall, etc.) meets the Alert level.

If vital areas are affected, see EAL 6.3.1.3.

The primary flammable gases considered are acetylene, propane and hydrogen.

References:

NUREG 0654, Appendix 1 Initiating Condition: Alert 18d Page 71 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL9)

Category: External Events EAL 6.3.1.3 Sub-Category: Toxic/Flammable Gas Intrusion Emergency Classification: SITE EMIERGENCY Emergency Action Level:

Entry of toxic orflamnzable gas into a plant vital areaaffecting operation or personnelsafety AND Reactor coolant temperature greaterthan 200 IF.

Basis:

The release of toxic or flammable gas into a plant vital area poses a significant threat to plant safety by precluding access to plant vital equipment which may be needed for Safe Shutdown. Therefore this condition warrants declaration of a Site Emergency.

Flammable gases are typically more limiting than toxic gases. Although an SCBA could protect from toxicity, detonation of a flammable gas could be immediately hazardous to personnel.

This EAL does not apply in cold shutdown or refueling modes due to the significantly reduced probability that the loss of access would result in fuel failure and/or a release.

References:

NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 16c Page 72 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: External Events EAL 6.4.1.1 Sub-Category: Vehicle/Missile Impacts Emergency Classification: UNUSUAL EVENT Emergency Action Level:

I Unusual aircraftactivity overfacility.

Basis:

This event may warrant the prompt notification of state and local authorities and perhaps a precautionary notification of Emergency Response Organization personnel. This event could pose a potential threat to plant operation or personnel safety and therefore warrants declaration of an Unusual Event.

The Protected Area Physical Barrier is defined in the PBNP Security Plan. Note: The Independent Spent Fuel Storage Installation (ISFSI) is a separate Protected Area.

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 14a SSCP - Security and Safeguards Contingency Plan Paae 73 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: External Events EAL 6.4.1.2 Sub-Category: Vehicle/Missile Impacts Emergency Classification: ALERT Emergency Action Level:

Aircraft crash in ProtectedArea (within the fence)

Basis:

This condition is entered when Control Room Operators become aware of an aircraft crash in the Protected Area (within the fence).

A lengthily damage assessment should not be performed. The occurrence of a crash is sufficient for declaration.

The ISFSI is part of the protected area.

This condition is indicative of abnormal plant system conditions with possible adverse consequences on the public health and safety is classified as an ALERT.

Escalation to a higher emergency class, if appropriate, will be based on further system malfunctions, fission product barrier degradation, abnormal radiation levels, or Emergency Director judgment.

References:

NUREG 0654, Appendix I Initiating Condition: Alert 18a Page 74 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALi)

Category: External Events EAL 6.4.1.3 Sub-Category: Vehicle/Missile Impacts Emergency Classification: SITE EMERGENCY Emergency Action Level:

Aircraft crash affecting operabilityof ivo (2) trains of safety systems.

Basis:

This condition is indicative of severe degradation of the level of safety at the plant and with possible adverse consequences on the public health and safety is classified as a Site Emergency.

Only crashes that actually cause damage to equipment required for safe operation of more than one safety system train AND only damage that affects the systems' ability to perform intended functions meet the threshold of this EAL. A lengthy damage assessment should not be performed. The occurrence of a crash with evidence of damage likely to prevent the equipment in more than one train of a safety system from performing intended safety functions is sufficient for declaration.

Safety systems as used here designates systems with safety-related functions. Attachment D lists safety systems and systems with safety-related functions.

References:

NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 16a Page 75 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: External Events EAL 6.4.2.2 Sub-Category: Vehicle/Missile Impacts Emergency Classification: ALERT Emergency Action Level:

Missile i npact from any source by visual observation of OperationsSupervisor.

Basis:

This condition is entered when Operations Supervision becomes aware of a missile impact.

A lengthily damage assessment should not be performed. The occurrence of a missile impact is sufficient for declaration.

This condition is indicative of abnormal plant system conditions with possible adverse consequences on the public health and safety is classified as an ALERT.

Escalation to a higher emergency class, if appropriate, will be based on further system malfunctions, fission product barrier degradation, abnormal radiation levels, or emergency management judgment.

References:

NUREG 0654, Appendix 1 Initiating Condition: Alert l8b Page 76 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: External Events EAL 6.4.2.3 Sub-Category: Vehicle/Missile Impacts Emergency Classification: SITE EMERGENCY Emergency Action Level:

I Any missile impact affecting operabilityof tio (2) trainsof safety systems.

Basis:

Safety systems as used here designates systems with safety-related functions. Attachment D lists safety systems and systems with safety-related functions.

Only missile impacts that actually cause damage to equipment required for safe operation of more than one safety system train AND only damage that affects the systems' ability to perform intended functions meet the threshold of this EAL. A lengthy damage assessment should not be performed. An immediate assessment of the probability of damage making multiple trains incapable of performing their safety function is all that is required. The occurrence of a missile impact with evidence of damage likely to prevent the equipment in more than one train of a safety system from performing intended safety functions is sufficient for declaration.

Major losses of plant safety systems, as defined by failure of the ability of two or more of the safety systems to perform their intended function, warrants declaration of a Site Emergency.

References:

NUREG 0654, Appendix 1 Initiating Condition: Site Emergency 16b Page 77 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHIMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Fuel HandlingfISFSI Events EAL 7.1.1.2 Sub-Category: Fuel Handling Events Emergency Classification: ALERT Emergency Action Level:

Report of possible damage to irradiatedfuelcombined with an alarm on any of thefollowving radiation monitors RE-21 1, Containment airparticulatemonitor RE-212 Containment noble gas monitor RE-221 Dnrmming Area Vent ManipulatorArea Monitor Spent Fuel BridgeArea Monitor.

Basis:

A report of possible damage to irradiated fuel, combined with an alarm on any of the radiation monitors indicates the probable damage to spent fuel.

NUREG/CR-4982 states that even if no corrective actions are taken, no prompt fatalities are predicted and the risk of injury is low. In addition, NRC Information Notice No. 90-08 presents the following clarifications:

"In the event of a serious accident involving decayed spent fuel, protective actions would be needed for personnel on site, while offsite doses (assuming an exclusion area radius of one mile from the plant site) would be well below the Environmental Protection Agency's Protective Action Guides. Accordingly, it is important to be able to properly survey and monitor for Kr-85 in the event of an accident with decayed spent fuel."

An Alert classification is appropriate for this event. Escalation would be based on actual radiological releases and/or SM judgment.

Page 78 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

References:

NUREG/CR-4982, "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82" N`RC Information Notice No. 90-08, "Kr-85 Hazards from Decayed Fuel" AOP-8B, Irradiated Fuel Handling Accident in Containment AOP-8C, Fuel Handling Accident in Primary Auxiliary Building NUREG 0654, Appendix 1 Initiating Condition: Alert 12 Page 79 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Fuel Handling/ISFSI Events EAL 7.2.1.2 Sub-Category: Irradiated Fuel Events Emergency Classification: ALERT Emergency Action Level:

Indications of irradiatedfitelUncovered.

Basis:

This EAL applies to any area where irradiated fuel is located; reactor cavity, reactor vessel, or the spent fuel pool.

Any releases caused by uncovering the fuel are not generally the primary concern. The primary concern of this EAL is two-fold. First, is the evident loss of control of inventory. The second is the immediate, life threatening dose which could be present in the area due to loss of shielding.

An Alert classification is appropriate for this event. Escalation, if required, would be based on actual radiological releases or Emergency Director judgment.

This EAL applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage.

References:

NUREG/CR4982, "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82" NRC Information Notice No. 90-08, "Kr-85 Hazards from Decayed Fuel" AOP-8F, Loss of Spent Fuel Pool Cooling NUREG 0654, Appendix 1 Initiating Condition: Alert 12 Page 80 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Fuel Handling/ISFSI Events EAL 7.3.1.1 Sub-Category: ISFSI Events Emergency Classification: UNUSUAL EVENT Emergency Action Level:

A loaded spent fitel cask dropped or tipped. I Basis:

The Independent Spent Fuel Storage Installation (ISFSI) stores spent fuel in vertical casks outside the main Protected Area. Engineering safeguards and procedures insure these casks are not dropped or tipped for the duration of their expected lifetimes. If they should be dropped or tipped it is appropriate to declare an Unusual Event until the situation is analyzed and corrected.

References:

NUREG/CR4982, "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82" NRC Information Notice No. 90-08, "Kr-85 Hazards from Decayed Fuel" AOP-8G, Ventilated Storage Cask (VSC) Drop or Tipover NUREG 0654, Appendix 1 Initiating Condition: Alert 12 Page 81 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 .

ATTACHMENT B EMERGENCY ACTION LEVELS (EALs)

Category: Fuel Handling/ISFSI Events EAL 7.3.1.2 Sub-Category: ISFSI Events Emergency Classification: ALERT Emergency Action Level:

Breach of a loaded spcntfiel cask as indicatedby a readingof greaterthan 1000 mRenilhr at 1 meter.

Basis:

The Independent Spent Fuel Storage Installation (ISFSI) stores spent fuel bundles in vertical cask in an area outside the main Protected Area. Engineering safeguards and procedures are in place to insure these casks are not subjected to forces that could breach their integrity. If a cask is breached it is appropriate to declare an Alert due to the potential threat to site personnel.

References:

NUREG/CR-4982, "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82" NRC Information Notice No. 90-08, "Kr-85 Hazards from Decayed Fuel" NUREG 0654, Appendix 1 Initiating Condition: Alert 12 Page 82 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALS)

Category: Emergency Management Judgment EAL 8.1.1.1 Sub-Category: None Emergency Classification: UNUSUAL EVENT Emergency Action Level:

Any event which in the judgment of the Shift Manageror the Emergency Directorcould lead to, or has led to, a potentialdegradationof the level of safety of the plant.

Basis:

This EAL would pertain to conditions not explicitly addressed elsewhere in the EALs, but which warrant the declaration of an emergency due to the potential degradation of the level of safety of the plant. The Shift Manager or Emergency Director makes this determination.

References:

NUREG 0654, Appendix 1 Initiating Condition: Unusual Event 15 Page 83 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EAL§)

Category: Emergency Management Judgment EAL 8.1.1.2 Sub-Category: None Emergency Classification: ALERT Emergency Action Level:

Any event which in the judgment of the Shift Manager or the Emergency Directorcould cause or has caused actual or potential substantialdegradationof the level of safety of the plant.

Basis:

This EAL would pertain to conditions not explicitly addressed elsewhere in the EALs, but which warrant the declaration of an emergency due to the actual or substantial potential degradation of the level of safety of the plant. The Shift Manager or Emergency Director makes this determination.

In keeping with other EALs, generally events which challenge single (RCS or Fuel Cladding) barriers, or affect only single safety systems or functions fall in this category.

References:

NUREG 0654, Appendix 1 Initiating Condition: Alert 19 Page 84 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALS)

Category: Emergency Management Judgment EAL 8.1.1.3 Sub-Category: None Emergency Classification: SITE EMERGENCY Emergency Action Level:

Any event which in the judgment of the Shift Manageror the Emergency Directorcould indicate actual or likely majorfailures ofplantfiunctionsneeded to protect the public. Any releases are not expected to result in exposures in excess of EPA PAGs.

Basis:

This EAL would pertain to conditions not explicitly addressed elsewhere in the EALs, but which warrant the declaration of an emergency due to the actual or likely failure of major plant functions needed for the protection of the public. The Shift Manager or Emergency Director makes this determination.

In keeping with other EALs, generally events which challenge two barriers (but not three), or affect more than one safety system or safety function, fall into this category.

References:

NUREG 0654, Appendix I Initiating Condition: Site Emergency 17 Page 85 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT B EMERGENCY ACTION LEVELS (EALS)

Category: Emergency Management Judgment EAL 8.1.1.4 Sub-Category: None Emergency Classification: GENERAL EMERGENCY Emergency Action Level:

Any event which in the judgment of the Shift Manageror the Emergency Directorcould lead to actual or imminent core damage and the potentialfor a large release of radioactivematerial (in excess of EPA PAGs) outside the site boundary.

Basis:

This EAL pertains to conditions not explicitly addressed elsewhere in the EALs but which warrant declaration of an emergency due to actual or imminent core damage and the potential exists for a release of large amounts of radioactive material. The Shift Manager or Emergency Director makes this determination.

In keeping with other EALs, generally events which challenge all three barriers, indicate the potential for core damage, or which reflect possible large releases fall into this category.

References:

NUREG 0654, Appendix 1 Initiating Condition: General Emergency 4 and 7 Page 86 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT C FISSION PRODUCT BARRIER (FPB) MATRIX This attachment is used to determine the status of the three primary Fission Product Barriers as they relate to classification. Wherever possible existing well-known parameters have been selected as thresholds for determining the status of the barriers. This is to integrate setpoints and thresholds already in existence in EOPs and Critical Safety Status Trees into the classification process. The intended purpose is to minimize the number of separate limits and values.

NOTE: Do not "anticipate" challenge or loss of a barrierunless the trend is rapid, and the values are close to the threshold/criteria.

The table on the following page may be used to 'check off the status of the three Fission Product Barriers. Next to each code (FC-1, RL-2, etc.) is an empty box. If the plant conditions meet the conditions in the box, the associated box may be checked, either in the Challenged or Loss column.

The number and status of Fission Product Barriers may then be compared to the EALs that specifically address Fission Product Barrier status (category 1 of Attachment A).

Generally, one barrier LOST is an Alert (unless the barrier is Containment alone),

two barriers LOST is a Site Emergency, and

two barriers LOST, with a CHALLENGE or LOSS of the third barrier is a General Emergency.

The codes (FC-1, RL-2, etc.) may be used to obtain further explanation as to the basis of their development. Each initial code letter; 'F' for Fuel Cladding, 'R' for Reactor Coolant System, or 'C' for Containment is followed by either 'C' for Challenge or 'L' for Loss. (For example FL-# indicates a parameter for Fuel Cladding LOSS, RC-# indicates a parameter for Reactor Coolant System Challenge.)

The bases are on the pages following the Table, arranged by barrier, Challenge then Loss.

Page 87 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT C FISSION PRODUCT BARRIER (FPB) MATRIX

_ "tFUEL'CLAD CHALLENGE 3-- CLADLv

,.;-F sLOSS FC-1 ST-2 (Core Cooling) Orange Path. FL-1 ST-2 (Core Cooling) Red Path.

E Degraded core cooling as indicated by Inadequate core cooling as indicated ANY of the following: by EITHER:

CET <700'F AND reactor <25' NR

CETs >1200'F Also SAMG entry.

CET >700'F AND reactor >25' NR

CETs > 700'F and reactor vessel

Reactor vessel <[120]1110' WR with level <25' NR

- 2 RCPsOR_<[60]50'_with_1_RCP.

_ FC-2 Failed fuel monitor (RE-109) reading El FL-2 Failed fuel monitor (RE-109) reading greater than 120 mRem/hr. greater than 600 nRem/hr.

FC-3 2 of 3 containment high range monitors FL-3 2 of 3 containment high range monitors reading greater than 1000 Rem/hr. E reading greater than 6000 Rem/hr.

FC-4 Coolant activity greater than Technical FL-4 Coolant activity greater than E Specification TS 3.4.16 E 250 ViCi/gram equivalent of I-131 (TSAC 3.4.16.B or 3.4.16.C entered).

FC-5 Any condition which in the judgment of FL-5 Any condition which in the judgment of E the Emergency Director is indicative of El the Emergency Director is indicative of a challenge to the Fuel Cladding barrier. a loss of the Fuel Cladding barrier.

., ,0: - ';.RCS&>U.QIALLENGE .; :cRCS 7.LOSS RC-I RCS leak greater than 10 gpm or RL-I RCS leak greater than 50 gpm.

El 500 gallons per day in either steam E3 generator (Technical Specifications). If greater than 400 gpm, see also EAL 2.4.1.3 RC-2 ST4 (Integrity) Orange Path. -RL-2 ST-4 (Integrity) Red Path.

Excess RCS cooldown or cold Temperature in either cold leg <285 0F overpressurization of the RCS. and cooldown >1000 F in the last 60 minutes.

E RC-3 Any condition which in the judgment of El RL-3 Any condition which in the judgment of the Emergency Director is indicative of the Emergency Director is indicative of a challenge to the Reactor Coolant a loss of the Reactor Coolant System System barrier, barrier.

v'Wm2'.. ;.,;.CONTAINMENTJ-CIALLENGE BWi:CONTA NT-NLOSS o CC-1 ST-5 (Containment) Orange Path. CL-I ST-5 (Containment) Red Path.

Containment pressure >25 psig and Pressure >60 psig increasing following actuation of containment spray OR Sump 'B' >74" O CC-2 Hydrogen concentration greater than D CL-2 Hydrogen concentration greater than 2%. 4%.

CC-3 Atmospheric dump(s) or reliefs open CL-3 Unisolable steam line break outside and greater than 10 gpm Primary to containment. If primary to secondary Secondary leakage exists leakage >10 gpm exists, see also RC-1.

If >50 gpm, see RL-1.

CC-4 Any condition which in the judgment of CL-4 Inability to isolate Containment.

the Emergency Director is indicative of a challenge to Containment barrier.

E CL-5 Any condition which in the judgment of the Emergency Director is indicative of a loss of the Containment barrier.

Paae 88 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT C FISSION PRODUCT BARRIER (FPB) MATRIX Fuel Cladding - CHALLENGE FC-1 ST-2 (Core Cooling) Orange Path indicates that RCS subcooling has been lost as well as loss of RCS inventory. RCS subcooling and reactor vessel level are fundamental indications of the assurance of adequate core cooling. These conditions indicate a challenge to the fuel cladding barrier due to degraded core cooling.

For the purposes of emergency classification, the barrier is to be considered CHALLENGED.

FC-2 The function of the failed fuel monitor is to monitor coolant activity. As the fuel cladding barrier degrades increasing amounts of activity are present in the coolant, and seen by this monitor. The value selected is approximately Technical Specifications, hence an Unusual Event must also be declared at this value, if this is the only fission product barrier affected. (1.1.2.1)

For the purposes of emergency classification, the barrier is to be considered CHALLENGED.

FC-3 In-containment high radiation monitors monitor activity in the coolant. As the fuel cladding barrier degrades increasing amounts of activity are present in the coolant, and seen by these monitors. This parameter may be the first indication of cladding degradation due to the location of the failed fuel monitor and possible containment isolation. The value is not correlated to a specific percentage of clad damage.

For the purposes of emergency classification, the barrier is to be considered CHALLENGED.

FC-4 Coolant activity greater than Technical Specifications is considered a precursor to loss of the fuel cladding barrier. (TSAC 3.4.16.B or 3.4.16.C has been entered).

For purposes of emergency classification, the barrier is to be considered CHALLENGED.

FC-5 It is unlikely that any classification scheme can anticipate every circumstance. Therefore this

'threshold' criteria is based on an ad hoc judgment call. If the Emergency Director has reason to believe the integrity of this barrier is being challenged, he may declare it so.

He should have objective reason to believe the barrier is challenged. Simply not knowing (for example loss of indications) should not be used as a basis for declaring a barrier challenged or lost.

If the barrier is subsequently determined not to have been challenged, it may be declared intact.

If it is determined that the barrier was challenged, but is no longer challenged, the barrier must remain as challenged, until the Recovery phase of the emergency.

For the purposes of emergency classification, the barrier is to be considered CHALLENGED.

Page 89 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT C FISSION PRODUCT BARRIER (FPB) MATRIX Fuel Cladding - LOSS FL-1 ST-2 (Core Cooling) Red Path indicates that RCS subcooling has been lost as well as significant loss of RCS inventory. RCS subcooling and reactor vessel level are fundamental indications of the assurance of adequate core cooling. These conditions indicate the fuel cladding barrier has been subjected to conditions which may cause its failure due to inadequate core cooling.. For the purposes of emergency classification, the barrier is to be considered LOST.

Core exit thermocouple reading in excess of 1200'F is also an entry condition for Severe Accident Management Guidelines (SAMGs).

FL-2 The function of the failed fuel monitor is to monitor coolant activity. As the fuel cladding barrier degrades increasing amounts of activity are present in the coolant, and seen by this monitor. The value is not correlated to a specific percentage of clad damage, but is beyond Technical Specifications.

For the purposes of emergency classification, the barrier is to be considered LOST.

FL-3 In-containment high radiation monitors monitor activity in the coolant. As the fuel cladding barrier degrades increasing amounts of activity are present in the coolant, and seen by these monitors. This parameter may be the first indication of cladding degradation due to the location of the failed fuel monitor and possible containment isolation. The value is not correlated to a specific percentage of clad damage, but is beyond Technical Specifications.

For the purposes of emergency classification, the barrier is to be considered LOST.

FL-4 Coolant activity greater than this level is not correlated to a specific percentage of clad damage, but is beyond Technical Specifications.

For the purposes of emergency classification, the barrier is to be considered LOST.

FL->

It is unlikely that any classification scheme can anticipate every circumstance. Therefore this

'threshold' criteria is based on an ad hoc judgment call. If the Emergency Director has reason to believe the integrity of this barrier is lost, he may declare it so.

He should have objective reason to believe the barrier is lost. Simply not knowing (for example loss of indications) should not be used as a basis for declaring a barrier challenged or lost.

If the barrier is subsequently determined not to have been lost, it may be declared intact, or challenged, as appropriate.

If it is determined that the barrier was lost, but is no longer lost, the barrier must remain as lost, until the Recovery phase of the emergency.

For the purposes of emergency classification, the barrier is to be considered LOST.

Page 90 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT C FISSION PRODUCT BARRIER (FPB) MATRIX Reactor Coolant System - CHALLENGE RC-1 These conditions represent minor leakage from the RCS. Because the source of the leak may not be known, and leaks can become worse, these conditions are considered precursors to more serious events. As such, an Unusual Event must be declared on these conditions, if the RCS is the only barrier affected. (1.1.3.1, 1.1.4.1)

For the purposes of emergency classification, the barrier is to be considered CHALLENGED.

RC-2 Conditions of ST-4 (Integrity) Orange Path reflect an excessive cooldown of the vessel or cold overpressurization of the RCS. These conditions represent a challenge to the RCS barrier. An Unusual Event must be declared. (1.1.5.1)

For the purposes of emergency classification, the barrier is to be considered CHALLENGED.

RC-3 It is unlikely that any classification scheme can anticipate every circumstance. Therefore this

'threshold' criteria is based on an ad hoc judgment call. If the Emergency Director has reason to believe the integrity of this barrier is being challenged, he may declare it so.

Heshould have objective reason to believe the barrier is challenged. Simply not knowing (for example loss of indications) should not be used as a basis for declaring a barrier challenged or lost.

If the barrier is subsequently determined not to have been challenged, it may be declared intact.

If it is determined that the barrier was challenged, but is no longer challenged, the barrier must remain as challenged, until the Recovery phase of the emergency.

For the purposes of emergency classification, the barrier is to be considered CHALLENGED.

Page 91 of 97 REFERENCE USE

POIINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT C FISSION PRODUCT BARRIER (FPB) MATRIX Reactor Coolant System - LOSS RL-1 This value is derived from NUREG-0654, Appendix 1. Although 50 gpm is well within the capacity of available pumps, this leak can be either into Containment or from Primary to Secondary systems. Thus, the RCS barrier is no longer serving its function of preventing the transport of fission products.

For the purposes of emergency classification, the barrier is to be considered LOST.

RL-2 Conditions of ST-4 (Integrity) Red Path reflect an excessive cooldown of the vessel. These conditions indicate the RCS barrier has been subjected to conditions which may cause its failure For the purposes of emergency classification, the barrier is to be considered LOST.

RL-3 It is unlikely that any classification scheme can anticipate every circumstance. Therefore this

'threshold' criteria is based on an ad hoc judgment call. If the Emergency Director has reason to believe the integrity of this barrier is lost, he may declare it so.

He should have objective reason to believe the barrier is lost. Simply not knowing (for example loss of indications) should not be used as a basis for declaring a barrier challenged or lost.

If the barrier is subsequently determined not to have been lost, it may be declared intact, or challenged, as appropriate.

If it is determined that the barrier was lost, but is no longer lost, the barrier must remain as lost, until the Recovery phase of the emergency.

For the purposes of emergency classification, the barrier is to be considered LOST.

Page 92 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT C FISSION PRODUCT BARRIER (FPB) MATRIX Containment - CHALLENGE CC-1 ST-5 (Containment) Orange Path represent conditions beyond normal operating parameters due to either pressure or sump "B" level.

For the purposes of emergency classification, the barrier is to be considered CHALLENGED CC-2 Existence of hydrogen at these concentrations does not yet represent an explosive mixture, however, there are limited means to reduce hydrogen in containment, especially during an emergency.

For the purposes of emergency classification, the barrier is to be considered CHALLENGED.

CC-3 This challenge threshold is designed to ensure that if Fuel Cladding AND RCS barriers are LOST, a General Emergency would be declared if the atmospheric dump valves or relief valves on the affected steam generator open (or are opened) and greater than 10 gpm Primary to Secondary leakage exists.

If the Primary to Secondary leakage is less than 10 gpm the RCS barrier may be considered intact.

This threshold is included to address NUREG-0654, Appendix 1 Initiating Condition A4.

For the purposes of emergency classification, the barrier is to be considered CHALLENGED.

CC-4 It is unlikely that any classification scheme can anticipate every circumstance. Therefore this

'threshold' criteria is based on an ad hoc judgment call. If the Emergency Director has reason to believe the integrity of this barrier is being challenged, he may declare it so.

He should have objective reason to believe the barrier is challenged. Simply not knowing (for example loss of indications) should not be used as a basis for declaring a barrier challenged or lost.

If the barrier is subsequently determined not to have been challenged, it may be declared intact.

If it is determined that the barrier was challenged, but is no longer challenged, the barrier must remain as challenged, until the Recovery phase of the emergency.

For the purposes of emergency classification, the barrier is to be considered CHALLENGED.

Page 93 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT C FISSION PRODUCT BARRIER (FPB) MATRIX Containment - LOSS CL-1 ST-5 (Containment) Red Path represent conditions indicate the containment barrier has been subjected to conditions which may cause its failure.

For the purposes of emergency classification, the barrier is to be considered LOST.

CL-2 Hydrogen at these concentrations may detonate. This would create an explosion in Containment.

For the purposes of emergency classification, the barrier is to be considered LOST.

CL-3 Main steam line piping outside containment, up to and including the isolation valves may be considered a part of the Containment barrier.

The inability to isolate assumes it is desired and has been attempted. This attempt includes only actions which may be taken from the Control Room. If actions must be taken outside the Control Room to isolate, the barrier must be considered lost.

For the purposes of emergency classification, the barrier is to be considered LOST.

CL-4 This criteria includes all isolation paths, including access hatches. Only one valve or door in a given path need be closed.

A physical loss of integrity (crack or hole) also meets this criteria.

For the purposes of emergency classification, the barrier is to be considered LOST.

CL-5 It is unlikely that any classification scheme can anticipate every circumstance. Therefore this

'threshold' criteria is based on an ad hoc judgment call. If the Emergency Director has reason to believe the integrity of this barrier is lost, he may declare it so.

He should have objective reason to believe the barrier is lost. Simply not knowing (for example loss of indications) should not be used as a basis for declaring a barrier challenged or lost.

If the barrier is subsequently determined not to have been lost, it may be declared intact, or challenged, as appropriate.

If it is determined that the barrier was lost, but is no longer lost, the barrier must remain as lost, until the Recovery phase of the emergency.

For the purposes of emergency classification, the barrier is to be considered LOST.

Page 94 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT D SAFETY AND SAFETY-RELATED SYSTEMS Desienator System* Safety-Related Functions AF Auxiliary Feedwater Feedwater supply AMSAC ATWAS MLitigation System Non-safety-related isolation Actuation Circuitry BS Boron Recycle Supports Safety Injection CC Component Cooling Water Cools safety-related equipment CI Containment Integrity Containment integrity COMP Computers Monitoring CONT Containment Structures Containment integrity CP Containment Penetrations Containment integrity CS Condensate and Feedwater Core Cooling CV Chemical and Volume Control Emergency cooling, containment integrity DA Diesel Starting Air Diesel start DG Diesel Generator Emergency power supply ESF Engineered Safety Features Core Cooling and Integrity (Safeguards)

FH Fuel Handling Fuel integrity FM In core Flux Mapping Fuel integrity FO Fuel Oil Power supply FP Fire Protection Fire Protection FW Feedwater (I&C only) Non-safety-related isolation HV Auxiliary Steam, Heating Steam & Containment cooling and integrity Condensate, Chilled & Hot Water Page 95 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 A1TACHM[ENT D SAFETY AND SAFETY-RELATED SYSTEMS Desienator System Safetv-Related Functions IA Instrument Air Containment isolation and integrity IST Inservice Test Equipment Reactor coolant system integrity (i.e., steam generator nozzle dams)

MRR Metering, Relaying, & Regulation Monitoring MS Main, Extraction, Gland Seal & Containment integrity, heat removal Reheat Steam NG Nitrogen Gas Monitoring NI Nuclear Instrumentation Reactor protection PACV Post-Accident Vent, Drains, etc. Containment integrity, containment hydrogen control PPCS Plant Process Computer System Monitoring RC Reactor Coolant Reactor coolant system integrity, reactor protection, containment integrity RDC Rod Drive Control Reactor coolant system integrity, reactor protection RH Residual Heat Removal (LPSI) Containment integrity, emergency cooling RM Radiation Monitoring Monitoring, RCS and containment integrity RP Reactor Protection Reactor protection, monitoring, RS Radwaste Steam Non-safety-related isolation S Structures Safety-related equipment safety SA Service Air Containment integrity SF Spent Fuel Cooling and Filtration Heat removal and containment integrity SC Primary Sampling Containment and RCS integrity SI Safety Injection (HPSI) Emergency cooling, heat removal, containment integrity Page 96 of 97 REFERENCE USE

POINT BEACH NUCLEAR PLANT EPIP 1.2 EMERGENCY PLAN IMPLEMENTING PROCEDURES NNSR Revision 42 EMERGENCY CLASSIFICATION March 10, 2004 ATTACHMENT D SAFETY AND SAFETY-RELATED SYSTEMS Designator System Safety-Related Functions SW Service Water Feedwater supply, heat removal, containment integrity VNBI PAB Battery & Inverter Room Heat removal, battery room hydrogen H&V control VNCC Containment Accident Fans H&V Heat removal VNDG Diesel Generator Room H&V Support Diesel operation VNPSE Containment Purge Supply & Containment integrity Exhaust H&V VNRC Reactor Cavity Cooling H&V Containment integrity WG Waste Gas Containment integrity WL Waste Liquid Containment integrity Y Vital Instrument Bus 120 VAC Power supply 4.16KV 4160V Electrical Power supply 480V 480V Electrical Power supply 125V 125VDC Electrical Power supply Pagye 97 of 97 REFERENCE USE

NRC 2004-0029, Emergency Plan Implementing Procedures Manual Revisions

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