Text

Emergency Plan Implementing Procedure Revision
	ML23248A494
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/05/2023
From:	Keele R; Entergy Operations
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
	0CAN092301
	Download: ML23248A494 (1)
	v • d • e

~ entergy Riley D. Keele, Jr.

Manager. Regulatory Assurance Arkansas Nuclear One Tel 479-858-7826 0CAN092301 10 CFR 50.4(b)(5) 10 CFR 50.54(q)(5) 10 CFR 72.4 10 CFR 72.44(f)

September 5, 2023 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Emergency Plan Implementing Procedure Revision Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313, 50-368, and 72-13 Renewed Facility Operating License Nos. DPR-51 and NPF-6 In accordance with 10 CFR 50.4(b)(5), 10 CFR 50.54(q)(5), 10 CFR 72.4, and 10 CFR 72.44(f),

the Arkansas Nuclear One (ANO) Emergency Plan (EPlan) Emergency Action Level (EAL)

Classification procedure has been revised and is enclosed. A summary of the changes to the implementing procedure is included in the Attachment to the enclosure. The EALs are being revised to accommodate use of the Holtec HI-STORM Flood and Wind (FW) system.

In accordance with 10 CFR 50.54(q), a screening and/or evaluation of the changes to the associated EAL procedure was performed. The screening and/or evaluation concluded that the changes do not reduce the effectiveness of the EPlan, and the EPlan continues to meet the standards of 10 CFR 50.47(b) and 10 CFR 50, Appendix E.

This correspondence contains no new commitments . Should you have any questions regarding this subm ittal, please contact Riley Keele, Manager, Regulatory Assurance, Arkansas Nuclear One at 479-858-7826.

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RDK/mar Entergy Operations, Inc., Arkansas Nuclear One (ANO) , 1448 SR 333, Russellville, AR 72802

0CAN092301 Page 2 of 2

Enclosure:

Procedure OP-1903.010, Revision 62, Emergency Action Level Classification Attachment to

Enclosure:

Summary of Changes to ANO Emergency Plan Implementing Document cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One NRC Director, Division of Fuel Management, Office of Nuclear Material Safety and Safeguards NRC Region IV Senior Emergency Preparedness Inspector Designated Arkansas State Official

Enclosure 0CAN092301 Procedure OP-1903.010, Revision 62, Emergency Action Level Classification

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 1 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Table of Contents Section Page

1.0 INTRODUCTION

.............................................................................................................. 2 2.0 DISCUSSION ................................................................................................................... 2 2.1 Background ............................................................................................................. 2 2.2 Fission Product Barriers .......................................................................................... 3 2.3 Fission Product Barrier Classification Criteria .......................................................... 3 2.4 EAL Organization .................................................................................................... 4 2.5 Technical Basis Information..................................................................................... 5 2.6 Operations Mode Applicability ................................................................................. 7 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ......................................... 8 3.1 General Considerations ........................................................................................... 8 3.2 Classification Methodology .................................................................................... 10

4.0 REFERENCES

............................................................................................................... 13 4.1 Developmental ...................................................................................................... 13 4.2 Implementing ......................................................................................................... 13 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS ......................................................... 13 5.1 Definitions (ref. 4.1.1 except as noted) .................................................................. 13 5.2 Abbreviations/Acronyms ........................................................................................ 18 6.0 ANO-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCE ................................................. 22 7.0 ATTACHMENTS ............................................................................................................ 24 7.1 Attachment 1, Emergency Action Level Technical Bases ...................................... 24 Category A - Abnormal Rad Levels / Rad Effluents ............................................... 25 Category C - Cold Shutdown / Refueling System Malfunction ............................... 68 Category E - Independent Spent Fuel Storage Installation (ISFSI)...................... 107 Category F - Fission Product Barrier Degradation ............................................... 110 Table 1[2]F-1, Fission Product Barrier Threshold Matrix & Bases .. 117 Category H - Hazards and Other Conditions Affecting Plant Safety .................... 163 Category S - System Malfunction ........................................................................ 201 7.2 Attachment 2, Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases .................................................... 243

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 2 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062

1.0 INTRODUCTION

This document provides an explanation and rationale for each Emergency Action Level (EAL) included in the EAL Upgrade Project for Arkansas Nuclear One (ANO). It should be used to facilitate review of the ANO EALs and provide historical documentation for future reference.

Decision-makers responsible for implementation of 1903.010, Emergency Action Level Classification, may use this document as a technical reference in support of EAL interpretation.

This information may assist the Emergency Director in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training and for explaining event classifications to off-site officials.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases when conditions are present and have been recognized. Use of this document for assistance is not intended to delay the emergency classification.

Because the information in a basis document can affect emergency classification decision-making (e.g., the Emergency Director refers to it during an event), the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10 CFR 50.54(q).

2.0 DISCUSSION

2.1 Background

EALs are the plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions defined in the ANO Emergency Plan.

In 1992, the NRC endorsed NUMARC/NESP-007 Methodology for Development of Emergency Action Levels as an alternative to NUREG-0654 EAL guidance.

NEI 99-01 (NUMARC/NESP-007) Revisions 4 and 5 were subsequently issued for industry implementation. Enhancements over earlier revisions included:

Consolidating the system malfunction initiating conditions and example emergency action levels which address conditions that may be postulated to occur during plant shutdown conditions.

Initiating conditions and example emergency action levels that fully address conditions that may be postulated to occur at permanently Defueled Stations and Independent Spent Fuel Storage Installations (ISFSIs).

Simplifying the fission product barrier EAL threshold for a Site Area Emergency.

Subsequently, Revision 6 of NEI 99-01 has been issued which incorporates resolutions to numerous implementation issues including the NRC EAL Frequently Asked Questions (FAQs).

Using NEI 99-01 Revision 6, "Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, November 2012 (ref. 4.1.1), ANO conducted an EAL implementation upgrade project that produced the EALs discussed herein.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 3 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 2.2 Fission Product Barriers Fission product barrier thresholds represent threats to the defense in depth design concept that precludes the release of radioactive fission products to the environment. This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment.

Many of the EALs derived from the NEI methodology are fission product barrier threshold based. That is, the conditions that define the EALs are based upon thresholds that represent the loss or potential loss of one or more of the three fission product barriers. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. A Loss threshold means the barrier no longer assures containment of radioactive materials.

A Potential Loss threshold implies a greater probability of barrier loss and reduced certainty of maintaining the barrier.

The primary fission product barriers are:

A. Fuel Clad Barrier (FCB): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.

B. Reactor Coolant System Barrier (RCB): The Reactor Coolant System Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

C. Containment Barrier (CNB): The Containment Barrier includes the Reactor Building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the Reactor Building up to and including the outermost secondary side isolation valve.

Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.

2.3 Fission Product Barrier Classification Criteria The following criteria are the bases for event classification related to fission product barrier loss or potential loss:

Alert:

Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:

Loss or potential loss of any two barriers General Emergency:

Loss of any two barriers and loss or potential loss of the third barrier

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 4 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 2.4 EAL Organization The ANO EAL scheme includes the following features:

Division of the EAL set into three broad groups:

o EALs applicable under any plant operating modes - This group would be reviewed by the EAL-user any time emergency classification is considered.

o EALs applicable only under hot operating modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup, or Power Operation mode.

o EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling or Defueled mode.

The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.

Within each group, assignment of EALs to categories and subcategories:

Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. The ANO EAL categories are aligned to and represent the NEI 99-01, Recognition Categories. Subcategories are used in the ANO scheme as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The ANO EAL categories and subcategories are listed below.

The primary tool for determining the emergency classification level is the EAL Classification Matrix. The user of the EAL Classification Matrix may (but is not required to) consult the EAL technical bases in order to obtain additional information concerning the EALs under classification consideration. The user should consult Section 3.0 and Attachment 1 of this document for such information.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 5 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 EAL Groups, Categories and Subcategories EAL Group/Category EAL Subcategory Any Operating Mode:

A - Abnormal Rad Levels / Rad Effluent 1 - Radiological Effluent 2 - Irradiated Fuel Event 3 - Area Radiation Levels H - Hazards and Other Conditions Affecting 1 - Security Plant Safety 2 - Seismic Event 3 - Natural or Technological Hazard 4 - Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7 - Emergency Director Judgment E - Independent Spent Fuel Storage 1 - Confinement Boundary Installation (ISFSI)

Hot Conditions:

S - System Malfunction 1 - Loss of Essential AC Power 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4 - RCS Activity 5 - RCS Leakage 6 - RPS Failure 7 - Loss of Communications 8 - Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier Degradation None Cold Conditions:

C - Cold Shutdown / Refueling System 1 - RCS Level Malfunction 2 - Loss of Essential AC Power 3 - RCS Temperature 4 - Loss of Vital DC Power 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems 2.5 Technical Bases Information EAL technical bases are provided in Attachment 1 for each EAL according to EAL group (Any, Hot, Cold), EAL category (A, C, E, F, H and S) and EAL subcategory. A summary explanation of each category and subcategory is given at the beginning of the technical bases discussions of the EALs included in the category. For each EAL, the following information is provided:

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 6 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Category Letter & Title Subcategory Number & Title Initiating Condition (IC)

Site-specific description of the generic IC given in NEI 99-01 Rev. 6.

EAL Identifier (enclosed in rectangle)

Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel. Four characters define each EAL identifier:

1. First character (letter): Corresponds to the EAL category as described above (A, C, E, F, H or S)

2. Second character (letter): The emergency classification (G, S, A or U)

G = General Emergency S = Site Area Emergency A = Alert U = Unusual Event

3. Third character (number): Subcategory number within the given category. Subcategories are sequentially numbered beginning with the number one (1). If a category does not have a subcategory, this character is assigned the number one (1).

4. Fourth character (number): The numerical sequence of the EAL within the EAL subcategory. If the subcategory has only one EAL, it is given the number one (1).

Classification (enclosed in rectangle):

Unusual Event (U), Alert (A), Site Area Emergency (S) or General Emergency (G)

EAL (enclosed in rectangle)

Exact wording of the EAL as it appears in the EAL Classification Matrix. If an ANO Unit 2 EAL threshold value differs from Unit 1, the Unit 2 threshold is enclosed in brackets. For example, in the EAL threshold RVLMS Levels 1 through 8 indicate DRY [RVLMS Levels 1 through 5 indicate DRY], RVLMS Levels 1 through 5 indicate DRY apply only to Unit 2.

Mode Applicability One or more of the following plant operating conditions comprise the mode to which each EAL is applicable: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, DEF - Defueled, or All. (See Section 2.6 for operating mode definitions).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 7 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Definitions:

If the EAL wording contains a defined term, the definition of the term is included in this section. These definitions can also be found in Section 5.1.

Basis:

An EAL basis section that provides ANO-relevant information concerning the EAL as well as a description of the rationale for the EAL as provided in NEI 99-01 Rev. 6.

Reference(s):

Source documentation from which the EAL is derived.

2.6 Operating Mode Applicability Unit 1 (ref. 4.1.6):

1 Power Operation Keff 0.99, reactor power > 5%

2 Startup Keff 0.99, reactor power 5%

3 Hot Standby Keff < 0.99, reactor coolant temperature 280°F 4 Hot Shutdown Keff < 0.99, reactor coolant temperature 280°F > Tavg > 200°F and all reactor vessel head closure bolts fully tensioned 5 Cold Shutdown Keff < 0.99, reactor coolant temperature 200°F and all reactor vessel head closure bolts fully tensioned 6 Refueling One or more reactor vessel head closure bolts less than fully tensioned DEF Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pool.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 8 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Unit 2 (ref. 4.1.6):

1 Power Operation Keff 0.99, reactor power > 5%, average coolant temperature 300°F 2 Startup Keff 0.99, reactor power 5%, average coolant temperature 300°F 3 Hot Standby Keff < 0.99, average coolant temperature 300°F 4 Hot Shutdown Keff < 0.99, average coolant temperature 300°F > Tavg > 200°F 5 Cold Shutdown Keff < 0.99, average coolant temperature 200°F 6 Refueling Keff 0.95, average coolant temperature 140°F, reactor vessel head unbolted or removed, and fuel in the vessel.

DEF Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pool.

The plant operating mode that exists at the time that the event occurs (prior to any protective system or operator action being initiated in response to the condition) should be compared to the mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the mode that existed at the time the event occurred.

3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 3.1 General Considerations When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assessment of an Initiating Condition (IC). This includes the Emergency Action Level (EAL) plus the associated Operating Mode Applicability, Notes, and the informing basis information. In the Recognition Category F matrices, EALs are based on loss or potential loss of Fission Product Barrier Thresholds.

EAL matrices should be read from left to right, from General Emergency to Unusual Event, and top to bottom. Declaration decisions should be independently verified before declaration is made except when gaining this verification would exceed the 15 minute declaration requirement. Place keeping should be used on all EAL matrices.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 9 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 3.1.1 Classification Timeliness NRC regulations require the licensee to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. The NRC staff has provided guidance on implementing this requirement in NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" (ref. 4.1.8).

3.1.2 Valid Indications All emergency classification assessments shall be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicators operability, the conditions existence, or the reports accuracy. For example, verification could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by plant personnel.

An indication, report, or condition is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

3.1.3 Imminent Conditions For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.

3.1.4 Planned vs. Unplanned Events A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that: 1) the activity proceeds as planned, and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component. In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72 (ref. 4.1.4).

3.1.5 Classification Based on Analysis The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments,

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 10 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 chemistry sampling, RCS leak rate calculation, etc.). For these EALs, the EAL wording or the associated basis discussion will identify the necessary analysis. In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available). The NRC expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift).

3.1.6 Emergency Director Judgment While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 EAL scheme provides the Emergency Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.

A similar provision is incorporated in the Fission Product Barrier Tables; judgment may be used to determine the status of a fission product barrier.

3.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL must be consistent with the related Operating Mode Applicability and Notes. If an EAL has been met or exceeded, the associated IC is likewise met, the emergency classification process clock starts, and the ECL must be declared in accordance with plant procedures no later than fifteen minutes after the process clock started.

When assessing an EAL that specifies a time duration for the off-normal condition, the clock for the EAL time duration runs concurrently with the emergency classification process clock.

For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref. 4.1.8).

3.2.1 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared. For example:

If an Alert EAL and a Site Area Emergency EAL are met, whether at one unit or at two units, a Site Area Emergency should be declared.

There is no additive effect from multiple EALs meeting the same ECL. For example:

If two Alert EALs are met, whether at one unit or at two units, an Alert should be declared.

3.2.2 Consideration of Mode Changes During Classification The mode in effect at the time that an event or condition occurred, and prior to any plant or operator response, is the mode that determines whether or not an IC is applicable. If an event

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 11 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 or condition occurs, and results in a mode change before the emergency is declared, the emergency classification level is still based on the mode that existed at the time that the event or condition was initiated (and not when it was declared). Once a different mode is reached, any new event or condition, not related to the original event or condition, requiring emergency classification should be evaluated against the ICs and EALs applicable to the operating mode at the time of the new event or condition.

For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicable in the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is entered during the subsequent plant response. In particular, the fission product barrier EALs are applicable only to events that initiate in the Hot Shutdown mode or higher.

3.2.3 Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all emergency classification levels, this approach is particularly important at the higher emergency classification levels since it provides additional time for implementation of protective measures.

3.2.4 Emergency Classification Level Upgrading and Termination An ECL may be terminated when the event or condition that meets the classified IC and EAL no longer exists, and other site-specific termination requirements are met.

3.2.5 Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events include an earthquake or a failure of the reactor protection system to automatically trip the reactor followed by a successful manual trip.

3.2.6 Classification of Transient Conditions Many of the ICs and/or EALs employ time-based criteria. These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to the classification of these conditions.

EAL momentarily met during expected plant response - In instances in which an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operator

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 12 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 actions are performed in accordance with procedures.

EAL momentarily met but the condition is corrected prior to an emergency declaration - If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required. For illustrative purposes, consider the following example:

An ATWS occurs and the high pressure ECCS systems fail to automatically start. The plant enters an inadequate core cooling condition (a potential loss of both the Fuel Clad and RCS Barriers). If an operator manually starts a high pressure ECCS system in accordance with an EOP step and clears the inadequate core cooling condition prior to an emergency declaration, then the classification should be based on the ATWS only.

It is important to stress that the 15-minute emergency classification assessment period (process clock) is not a grace period during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event. Emergency classification assessments must be deliberate and timely, with no undue delays. The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the Emergency Director completing the review and steps necessary to make the emergency declaration. This provision is included to ensure that any public protective actions resulting from the emergency classification are truly warranted by the plant conditions.

3.2.7 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.

In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022 (ref. 4.1.3) is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR § 50.72 (ref. 4.1.4) within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

3.2.8 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (ref. 4.1.3).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 13 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062

4.0 REFERENCES

4.1 Developmental 4.1.1 NEI 99-01 Revision 6, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession Number ML12326A805 4.1.2 RIS 2007-02 Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2, 2007.

4.1.3 NUREG-1022 Event Reporting Guidelines: 10CFR50.72 and 50.73 4.1.4 10 § CFR 50.72 Immediate Notification Requirements for Operating Nuclear Power Reactors 4.1.5 10 § CFR 50.73 License Event Report System 4.1.6 Unit 1[2] Technical Specifications Table 1.1-1[1.1], Modes[Operational Modes]

4.1.7 Arkansas Nuclear One Offsite Dose Calculation Manual (ODCM) 4.1.8 NSIR/DPR-ISG-01 Interim Staff Guidance, Emergency Planning for Nuclear Power Plants 4.1.9 Arkansas Nuclear One Emergency Plan 4.1.10 1015.008 Unit 2 SDC Control 4.2 Implementing 4.2.1 1903.010 Emergency Action Level Classification 4.2.2 NEI 99-01 Rev. 6 to ANO EAL Comparison Matrix 4.2.3 ANO EAL Matrix 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS 5.1 Definitions (ref. 4.1.1 except as noted)

Selected terms used in Initiating Condition, Emergency Action Level statements and EAL bases are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

Alert Events are in progress, or have occurred, which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 14 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Confinement Boundary The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the ANO ISFSI, the Confinement Boundary is comprised of either the Multi-assembly Sealed Basket (MSB) (SNC System) or Multi-Purpose Canister (MPC) (Holtec System) HI-STORM 100 and HI-STORM FW.

Containment Closure The action to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions (ref. 4.1.10).

As applied to ANO, Containment Closure must be capable of being set within 30 minutes.

Containment Closure is set when the penetrations are isolated by manual or automatic isolation valve, blind flange, or equivalent.

Emergency Action Level (EAL)

A pre-determined, site-specific, observable threshold for an INITIATING CONDITION that, when met or exceeded, places the plant in a given emergency classification level.

Emergency Classification Level (ECL)

One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:

Unusual Event (UE)

Alert Site Area Emergency (SAE)

General Emergency (GE)

Explosion A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events require a post-event inspection to determine if the attributes of an explosion are present.

Faulted The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 15 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Fire Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

Fission Product Barrier Threshold A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.

Flooding A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

General Emergency Events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

Hostage A person(s) held as leverage against the station to ensure that demands will be met by the station.

Hostile Action An act toward ANO or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on ANO. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the SECURITY OWNER CONTROLLED AREA).

Hostile Force One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

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

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 16 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Impede(d)

Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Independent Spent Fuel Storage Installation (ISFSI)

A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

Initiating Condition (IC)

An event or condition that aligns with the definition of one of the four emergency classification levels by virtue of the potential or actual effects or consequences.

Projectile An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

Protected Area An area clearly demarcated by a fence or building wall with an entrance portal that is regulated by Security Personnel to control access (ref. 4.1.9).

RCS Intact The RCS should be considered intact when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams).

Refueling Pathway All the cavities, tubes, canals and pools through which irradiated fuel may be moved, but not including the reactor vessel.

Ruptured The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection (automatic or manual).

Safety System A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2):

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 17 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Security Condition Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A Security Condition does not involve a HOSTILE ACTION.

Security Owner Controlled Area (SOCA)

The SOCA is the area demarcated as a Vehicle Barrier System (VBS) consisting of passive elements including a series of large concrete blocks on the inside of a delay fence with early warning capabilities. The SOCA is the area between the SOCA Fence and the PROTECTED AREA Boundary (ref. 4.1.9).

Site Area Emergency Events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA PAG exposure levels beyond the SITE BOUNDARY.

Site Boundary That boundary defined by a 1046 meter (0.65 mile) radius around the plant (ref. 4.1.7).

Unisolable An open or breached system line that cannot be isolated, remotely or locally.

Unplanned A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 18 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Unusual Event Events are in progress or have occurred which indicate a potential degradation in the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of SAFETY SYSTEMS occurs.

Valid An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Visible Damage Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train.

5.2 Abbreviations/Acronyms

°F .................................................................................................................. Degrees Fahrenheit

° ...................................................................................................................................... Degrees AC................................................................................................................... Alternating Current ANO .......................................................................................................... Arkansas Nuclear One AOP ............................................................................................. Abnormal Operating Procedure ATWS ................................................................................. Anticipated Transient Without Scram BMS .................................................................................................. Boron Management System BWST .............................................................................................. Borated Water Storage Tank CDE .................................................................................................. Committed Dose Equivalent CET ........................................................................................................Core Exit Thermocouple CFR ................................................................................................. Code of Federal Regulations CIAS ................................................................................ Containment Isolation Actuation Signal CMT, CNTMT, CTMT ................................................................................................Containment CNB .............................................................................................................. Containment Barrier DBA ...........................................................................................................Design Basis Accident DBE ...................................................................................................... Design Basis Earthquake DC .......................................................................................................................... Direct Current DEF ............................................................................................................................... Defueled

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 19 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 D/G .................................................................................................................... Diesel Generator DHR ............................................................................................................ Decay Heat Removal DROPS ........................................................... Diverse Reactor Overpressure Protection System DSC ........................................................................................................... Dry Shielded Canister DSS .......................................................................................................... Diverse Scram System EAL .........................................................................................................Emergency Action Level ECCS ....................................................................................... Emergency Core Cooling System ECL..............................................................................................Emergency Classification Level DEF ............................................................................................................................... Defueled ENS .............................................................................................Emergency Notification System EOF ..............................................................................................Emergency Operations Facility EOP .......................................................................................... Emergency Operating Procedure EPA ......................................................................................... Environmental Protection Agency ERG ........................................................................................... Emergency Response Guideline EPIP ........................................................................... Emergency Plan Implementing Procedure ESAS .......................................................................... Engineered Safeguards Actuation System ESF.................................................................................................... Engineered Safety Feature ESFAS ................................................................. Engineered Safety Features Actuation System FAA.............................................................................................. Federal Aviation Administration FBI ...............................................................................................Federal Bureau of Investigation FCB ................................................................................................................... Fuel Clad Barrier FEMA...........................................................................Federal Emergency Management Agency GE ................................................................................................................ General Emergency HPI........................................................................................................... High Pressure Injection IC .....................................................................................................................Initiating Condition IPEEE ............................. Individual Plant Examination of External Events (Generic Letter 88-20)

ISFSI........................................................................ Independent Spent Fuel Storage Installation Keff..................................................................................... Effective Neutron Multiplication Factor LCO ............................................................................................. Limiting Condition of Operation LER........................................................................................................... Licensee Event Report LOCA .....................................................................................................Loss of Coolant Accident LRW.................................................................................................................. Liquid Rad Waste LTOP ..........................................................................................Low Temperature Overpressure LWR.............................................................................................................. Light Water Reactor

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 20 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 MCC ............................................................................................................ Motor Control Center MPC............................................... Maximum Permissible Concentration/Multi-Purpose Canister mR, mRem, mrem, mREM ........................................................... milli-Roentgen Equivalent Man MSL ................................................................................................................... Main Steam Line MTS .............................................................................................................. Margin to Saturation MW ............................................................................................................................... Megawatt NDTT .....................................................................................Nil Ductility Transition Temperature NEI.......................................................................................................... Nuclear Energy Institute NEIC .............................................................................. National Earthquake Information Center NESP .............................................................................. National Environmental Studies Project NORAD ............................................................... North American Aerospace Defense Command NOT ............................................................................................. Normal Operating Temperature (NO)UE ........................................................................................... Notification of Unusual Event NPP ............................................................................................................. Nuclear Power Plant NRC ........................................................................................... Nuclear Regulatory Commission NSSS ............................................................................................ Nuclear Steam Supply System OBE ................................................................................................. Operating Basis Earthquake ODCM ....................................................................................... Off-site Dose Calculation Manual ORO .............................................................................................Offsite Response Organization PA ......................................................................................................................... Protected Area PAG ................................................................................................... Protective Action Guideline PRA/PSA ................................. Probabilistic Risk Assessment / Probabilistic Safety Assessment P-T ............................................................................................................ Pressure-Temperature PTS................................................................................................... Pressurized Thermal Shock PWR .................................................................................................. Pressurized Water Reactor PSIG ........................................................................................... Pounds per Square Inch Gauge R ................................................................................................................................... Roentgen RB....................................................................................................................... Reactor Building RCC ....................................................................................................... Reactor Control Console RCB ............................................................................................ Reactor Coolant System Barrier RCP .......................................................................................................... Reactor Coolant Pump RCS ....................................................................................................... Reactor Coolant System Rem, rem, REM ................................................................................... Roentgen Equivalent Man Rep CET ...................................................................... Representative Core Exit Thermocouples

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 21 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 RETS ..................................................................... Radiological Effluent Technical Specifications RPS .................................................................................................... Reactor Protection System RV......................................................................................................................... Reactor Vessel RVLMS ......................................................................... Reactor Vessel Level Monitoring System RWT .......................................................................................................... Refueling Water Tank SAR .......................................................................................................... Safety Analysis Report SBO .................................................................................................................... Station Blackout SCBA .................................................................................. Self-Contained Breathing Apparatus SDC ................................................................................................................. Shutdown Cooling SOCA ......................................................................................... Security Owner Controlled Area SG .....................................................................................................................Steam Generator SI ......................................................................................................................... Safety Injection SPDS ....................................................................................... Safety Parameter Display System SPING .................................................................................. Super Particulate Iodine Noble Gas SRO ....................................................................................................... Senior Reactor Operator TEDE ...........................................................................................Total Effective Dose Equivalent TOAF ............................................................................................................... Top of Active Fuel TSC ......................................................................................................Technical Support Center USGS ........................................................................................ United States Geological Survey VBS .......................................................................................................... Vehicle Barrier System

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 22 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 6.0 ANO-TO-NEI 99-01 REV. 6 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of an ANO EAL within the NEI 99-01 IC/EAL identification scheme. Further information regarding the development of the ANO EALs based on the NEI guidance can be found in the EAL Comparison Matrix.

ANO NEI 99-01 Rev. 6 EAL IC Example EAL AU1.1 AU1 1, 2 AU1.2 AU1 3 AU2.1 AU2 1 AA1.1 AA1 1 AA1.2 AA1 2 AA1.3 AA1 3 AA1.4 AA1 4 AA2.1 AA2 1 AA2.2 AA2 2 AA2.3 AA2 3 AA3.1 AA3 1 AA3.2 AA3 2 AS1.1 AS1 1 AS1.2 AS1 2 AS1.3 AS1 3 AS2.1 AS2 1 AG1.1 AG1 1 AG1.2 AG1 2 AG1.3 AG1 3 AG2.1 AG2 1 CU1.1 CU1 1 CU1.2 CU1 2 CU2.1 CU2 1 CU3.1 CU3 1 CU3.2 CU3 2 CU4.1 CU4 1

PROC./WORK PLAN N

O. PROCEDURE

/WORK PLAN TITLE: PAGE: 23 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 ANO NEI 99-01 Rev. 6 EAL IC Example EAL CU5.1 CU5 1, 2, 3 CA1.1 CA1 1 CA1.2 CA1 2 CA2.1 CA2 1 CA3.1 CA3 1, 2 CA6.1 CA6 1 CS1.1 CS1 1 CS1.2 CS1 2 CG1.1 CG1 1 CG1.2 CG1 2 EU1.1 EU1 1 FA1.1 FA1 1 FS1.1 FS1 1 FG1.1 FG1 1 HU1.1 HU1 1, 2, 3 HU2.1 HU2 1 HU3.1 HU3 1 HU3.2 HU3 2 HU3.3 HU3 3 HU3.4 HU3 4 HU4.1 HU4 1 HU4.2 HU4 2 HU4.3 HU4 3 HU4.4 HU4 4 HU7.1 HU7 1 HA1.1 HA1 1, 2 HA5.1 HA5 1 HA6.1 HA6 1 HA7.1 HA7 1 HS1.1 HS1 1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 24 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 ANO NEI 99-01 Rev. 6 EAL IC Example EAL HS6.1 HS6 1 HS7.1 HS7 1 HG7.1 HG7 1 SU1.1 SU1 1 SU3.1 SU2 1 SU4.1 SU3 1 SU4.2 SU3 2 SU5.1 SU4 1, 2, 3 SU6.1 SU5 1 SU6.2 SU5 2 SU7.1 SU6 1, 2, 3 SU8.1 SU7 1, 2 SA1.1 SA1 1 SA3.1 SA2 1 SA6.1 SA5 1 SA9.1 SA9 1 SS1.1 SS1 1 SS2.1 SS8 1 SS6.1 SS5 1 SG1.1 SG1 1 SG1.2 SG8 1 7.0 ATTACHMENTS 7.1 Attachment 1, Emergency Action Level Technical Bases 7.2 Attachment 2, Safe Operation & Shutdown Areas Tables 1[2]A-3 & 1[2]H-2 Bases

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 25 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Category A - Abnormal Rad Levels / Rad Effluent EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

Many EALs are based on actual or potential degradation of fission product barriers because of the elevated potential for offsite radioactivity release. Degradation of fission product barriers though is not always apparent via non-radiological symptoms. Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification.

At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions may result which require offsite protective actions. Elevated area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.

Events of this category pertain to the following subcategories:

1. Radiological Effluent Direct indication of effluent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits. Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.

2. Irradiated Fuel Event Conditions indicative of a loss of adequate shielding or damage to irradiated fuel may preclude access to vital plant areas or result in radiological releases that warrant emergency classification.

3. Area Radiation Levels Sustained general area radiation levels which may preclude access to areas requiring continuous occupancy also warrant emergency classification.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 26 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:

AU1.1 Unusual Event Reading on any Table 1[2]A-1 effluent radiation monitor > column "UE" for 60 min.

(Notes 1, 2, 3)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 27 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses a potential reduction in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 28 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways as well as radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit.

Such releases are typically associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

Escalation of the emergency classification level would be via IC AA1.

Reference(s):

1. OP-1604.051 Ventilation Radiation Monitor System

2. Offsite Dose Calculation Manual

3. EP-CALC-ANO-1701 Radiological Effluent EAL Values

4. NEI 99-01 AU1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 29 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:

AU1.2 Unusual Event Sample analysis for a gaseous or liquid release indicates a concentration or release rate 2 x ODCM limits for 60 min. (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

None Basis:

This IC addresses a potential reduction in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

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

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 30 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

Escalation of the emergency classification level would be via IC AA1.

Reference(s):

1. Offsite Dose Calculation Manual

2. NEI 99-01 AU1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 31 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.1 Alert Reading on any Table 1[2]A-1 effluent radiation monitor > column "ALERT" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Note 4 The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table 1A-1 Unit 1 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE RX-9820 Containment Purge 4.15E+01 Ci/cc 4.15E+00 µCi/cc 4.15E-01 µCi/cc 1.21E-03 µCi/cc (SPING 1)

RX-9825 Radwaste Area 2.67E+01 Ci/cc 2.67E+00 µCi/cc 2.67E-01 µCi/cc 4.94E-04 µCi/cc Gaseous (SPING 2)

RX-9830 Fuel Handling Area 6.20E+02 Ci/cc 6.20E+01 µCi/cc 6.20E+00 µCi/cc 5.44E-04 µCi/cc (SPING 3)

Emergency RX-9835 6.55E+02 Ci/cc 6.55E+01 µCi/cc 6.55E+00 µCi/cc 1.21E-02 µCi/cc Penetration Room (SPING 4)

Liquid Liquid Radwaste RE-4642 ---- ---- ---- 2.46E+05 cpm

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 32 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Table 2A-1 Unit 2 Effluent Monitor Classification Thresholds (2 min. avg reading)

Release Point Monitor GE SAE Alert UE 2RX-9820 Containment Purge 1.88E+01 Ci/cc 1.88E+00 µCi/cc 1.88E-01 µCi/cc 5.48E-04 µCi/cc (SPING 5) 2RX-9825 Radwaste Area 2.35E+01 Ci/cc 2.35E+00 µCi/cc 2.35E-01 µCi/cc 4.35E-04 µCi/cc Gaseous (SPING 6) 2RX-9830 Fuel Handling Area 6.86E+02 Ci/cc 6.86E+01 µCi/cc 6.86E+00 µCi/cc 6.04E-04 µCi/cc (SPING 7)

Emergency 2RX-9835 5.88E+02 Ci/cc 5.88E+01 µCi/cc 5.88E+00 µCi/cc 1.09E-02 µCi/cc Penetration Room (SPING 8)

BMS Liquid 2RE-2330 ---- ---- ---- 2.45E+04 cpm Discharge Liquid Regenerative 2RE-4423 ---- ---- ---- 2.45E+05 cpm Waste Discharge Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

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

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 33 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1604.051 Ventilation Radiation Monitor System

2. EP-CALC-ANO-1701 Radiological Effluent EAL Values

3. NEI 99-01 AA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 34 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.2 Alert Dose assessment using actual meteorology indicates doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4: The pre-calculated effluent monitor values presented in EALs AA1.1, AS1.1 and AG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

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

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1904.002 Offsite Dose Projections

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 35 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases

2. NEI 99-01 AA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 36 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.3 Alert Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

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

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

This EAL is assessed per the ODCM (ref. 2).

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 37 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1904.002 Offsite Dose Projections

2. Offsite Dose Calculation Manual

3. NEI 99-01 AA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 38 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

AA1.4 Alert Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 10 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 min. of inhalation (Notes 1, 2)

Note 1: The Emergency Director should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded. The Emergency Director is not allowed an additional 15 minutes to declare after the time limit is exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That boundary defined by a 1046 meter (0.65 mile) radius around the plant.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

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

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 39 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC AS1.

Reference(s):

1. OP-1905.002 Offsite Emergency Monitoring

2. NEI 99-01 AA1

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 40 of 245 1903.010 EMERGENCY ACTION LEVEL CLASSIFICATION CHANGE: 062 Attachment 1 - Emergency Action Level Technical Bases Category: A - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

AS1.1 Site Area Emergency Reading on any Table 1[2]A-1 effluent radiation monitor > column "SAE" for 15 min.