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NEI 99-01, Revision 7, Development of Emergency Action Levels for Non-Passive Reactors Change Summary
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Issue date:	09/30/2024
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NEI 99-01 Revision 7

Change Summary

September 2024

NOTICE

Neither NEI, nor any of its employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, methods, or process disclosed in this document or that such may not infringe privately owned rights.

This document summarizes the changes made in NEI 99-01, Revision 7.

NEI 99-01 Section NEI 99-01 Rev. 7Change Summary Executive Summary Madeeditorial changes to improve clarity and readability.

There were no intent changes.

Deleted the Permanently Defueled Station section since the generic defueled ICs/EALs were removed from NEI 99- 01. The new location for this EAL guidance will be DG-1346, Emergency Planning for Decommissioning Nuclear Power Reactors [ proposed new Regulatory Guide 1.235]. In the meantime, licensees can continue to use the NRC-endorsed guidance in NEI 99-01, Revision 6, to develop EALs for a permanently defueled station.

Updated the information in the Spent Fuel Pool Monitoring Instrumentation section(e.g., Order EA 1.Regulatory Background 051 was replaced with 10 CFR 50.155). There were no intent changes.

Added section on Decommissioning Facility. The information reflects comments from both the NRC staff and the NEI Decommissioning Working Group. The guidance is aligned with NRC-approved License Amendment Requests related to EAL changes at decommissioning facilities.

Updated references to documents (e.g., added new ones, removed old ones, etc.).

Madeeditorial changes to improve clarity and readability.

Added guidance to section 2.4, Fission Product Barrier Threshold, to better explain the relationship between the 2.Key Terminology Used in FPB thresholds and the radiological release EALs in NE I 99-01 Recognition Category A.

Updated references to documents (e.g., added new ones, removed old ones, etc.).

Made editorial changes to improve clarity and readability.

NEI 99-01 Section NEI 99-01 Rev. 7Change Summary

In section 3.1, removed the discussion on 10 CFR 50.72 because this information does not support EAL scheme development.

Removed the ECL attributes (Section 3.1.1 through 3.1.4) as this information is no longer neededby the industry.

Removed discussion of a Station Blackout based onthe change to IC SG1 (i.e., the SBO coping time is no longer considered in the EAL).

Deleted reference to Permanently Defueled Station EALs 3.Design of the NEI 99 -01 since the generic defueled ICs/EALs were removed from Emergency Classification NE I 99-01. The new location will be DG-1346, Scheme Emergency Planning for Decommissioning Nuclear Power Reactors [ proposed new Regulatory Guide 1.235].

In the meantime, licensees can continue to use the NRC-endorsed guidance in NEI 99-01, Revision 6, to develop EALs for a permanently defueled station.

Added several statements to help licensees better understand NRC staff expectations concerning the content of a scheme conversion LAR.

Updated references to documents (e.g., added new ones, removed old ones, etc.).

Made editorial changes to improve clarity and readability.

Added several statements to help licensees better understand NRC staff expectations concerning the content of a scheme conversion LAR.

Revised section 4.3, Instrumentation Used in EALs, to provide more detail andincorporate operating experience (e.g., from EP findings). The changes also incorporated 4.Site -Specific Scheme information from EPFAQ 2015-12.

Development Guidance

Added section 4.4to ensure that scheme developers are aware of past issues associated with instrumentation supporting dose projection capabilities, and the need to verify that the instrumentation is properly calibrated and maintained.

Updated references to documents (e.g., added new ones, removed old ones, etc.).

Made editorial changes to improve clarity and readability.

Replaced a reference to NRC NSIR/DPR-ISG-01 with

5. Guidance on Making text from the document.

Emergency Classifications

Deleted a paragraph with guidance on not waiting to declare since this information appears in the Notes of the

NEI 99-01 Section NEI 99-01 Rev. 7Change Summary appropriate EALs (i.e., it was duplicative information).

Deleted table in section 5.5, Emergency Classification Level Downgrading and Termination, based on a feedback that th e information was not useful.

Deleted section 5.7, Classification of Short -Lived Events, based on feedback that the information was potentially confusing. The salient points are addressed in section 5.6, Classification of Transient Conditions.

Revised section 5.8, Retraction of the Notification of an Emergency Declaration, to provide better guidance and address operating experience (e.g., ROP FAQ 21- 02).

Made editorial changes to improve clarity and readability.

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

The table below summarizes the changes made to the Initiating Conditions and Emergency Action Levels in all Recognition Categories. As a general statement, the changes also included updat ingreferences to supporting documents (e.g., added new ones, removed old ones, etc.) where needed, and making editorial changes to improve clarity and readability.Also, conforming changes supporting the addition, revision or deletion of an IC or EAL were made where necessary (e.g., references in one IC to another IC that was relocated or deleted were changed as appropriate).

Due to the width of the table columns and table formatting constraints, the appearanceof an EAL (e.g., indentation) in this document may differ slightly from the appearance of the corresponding EAL in Revision 6 or Revision7.

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis IC AU1 Release of gaseous or N/A None -deleted. The IC and EALs were removed because the associated EAL #1 liquid radioactivity greater event represents a very minor loss of control of radioactive EAL #2 than 2 times the (site-materials,and thus poses a safety risk low enough as to EAL #3 specific effluent release not reasonably require an emergency declaration.

controlling document) Activation of a site emergency plan and partial ERO limits for 60 minutes or mobilization would not be necessary to respond to the longer. event. A site would have sufficient procedures and capabilities to respond without declaring an emergency (e.g., use of Radiation Protection and Chemistry resources for locating and assessing radiological releases).

Depending on event-specific conditions, some plant response actions may be required by Technical Specifications or the ODCM, and the site may also make a report to the NRC in accordance with the requirements in 10 CFR Part 20. This event would not create any impediments to activation of the ERO or performance of security plan-related functions. The appropriate lower bound for declaring an emergency due to a radiological release is IC AA1, which is set at 1% of the lower value of the early phase EPA PAG (the range is 1 to 5 rem) or 10 mrem.

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis IC AU2 (1) a. UNPLANNED IC AU2 (1) a. UNPLANNED No change.

EAL #1 water level drop in EAL #1 water level drop in the REFUELING the REFUELING PATHWAY as PATHWAY as indicated by ANY indicated by ANY of of the following: the following:

(site-specific level (site-specific level indications). indications).

AND AND

b. UNPLANNED rise b. UNPLANNED rise in area radiation in area radiation levels as indicated levels as indicated by ANY of the by ANY of the following radiation following radiation monitors. monitors.

(site-specific list of (site-specific list of area radiation area radiation monitors) monitors)

N/A N/A IC AU3 Radiation levels that impede New IC. See discussion below on NEI 99- 01,Rev. 6,IC EAL #1 access to equipment AA3 for change description and basis.

EAL #2 necessary for normal plant operations, cooldown or shutdown IC AA1 (1) Reading on ANY of the IC AA1 (1) Reading on ANY of the No change to the EAL wording. Added a paragraph to the EAL #1 following radiation EAL #1 following radiation basis to explain a note that applies to the precalculated monitors greater than monitors greater than radiation monitor thresholds in EAL #1. These are the reading shown for the reading shown for determined ( back calculated) using the dose value 15 minutes or longer: 15 minutes or longer: specified in the IC, and an assumed source term and meteorology. For this reason, the doses projected at the

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis (site-specific monitor (site-specific monitor time of an event, which will be based on a source term list and threshold list and threshold determined from plant indications and actual metrological values) values) data, may be above or below the dose specified in the IC.

Due to these expected differences, the radiation monitor readings in EAL #1 should not be used for emergency classification assessments if dose assessment results based on actual plant and meteorological conditions are available.

IC AA1 (2) Dose assessment using IC AA1 (2) Dose assessment using No change to the EAL wording. Included discussion in EAL #2 actual meteorology EAL #2 actual meteorology Developer Notes concerning guidance in the 2017 EPA indicates doses greater indicates doses greater PAG Manual (EPA-400/R-17/001, PAG Manual:

than 10 mrem TEDE or than 10 mrem TEDE or Protective Action Guides and Planning Guidance for 50 mrem thyroid CDE 50 mrem thyroid CDE at Radiological Incidents) per EPFAQ 2017-01.

at or beyond (site-or beyond (site-specific specific dose receptor dose receptor point).

point).

IC AA1 (3) Analysis of a liquid N/A None -deleted. This EAL was removed because of challenges associated EAL #3 effluent sample with making a timely assessment ( a legacy issue from indicates a insufficient vetting during the development of R6) and concentration or release bounding by other EALs. An accurate assessment of this rate that would result in EAL will likely require that samples be taken in the field, doses greater than 10 returned to a lab, and analyzed. This evolution cannot be mrem TEDE or 50 completed within the 15-minute assessment period mrem thyroid CDE at or required by regulations and may take up to several hours beyond (site-specific to complete. Moreover, a liquid release will be diluted dose receptor point) for and dispersed as it moves from its source (e.g., a holding one hour of exposure. tank) to the site boundary and the environs beyond. It is extremely unlikely that downstream liquid concentrations could reach the levels needed to result in the specified EAL threshold doses without a starting point source term

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis much greater than that available during normal operations (e.g., need some level of fuel cladding failure). If a sufficiently high source term were present, then another EAL would already be met. Focusing on just the site response to the event, the necessary actions could be taken without activating the emergency plan (similar to that discussed above for AU1) and the event would not create any impediments to activation of the ERO or performance of security plan-related functions. It is also noted that State and local public safety and environmental officials, upon being notified of the release, would mobilize and take actions to address the event without the necessity of an emergency declaration. In summary, the removal of this EAL has minimal impact on a classification scheme.

IC AA1 (4) Field survey results IC AA1 (3) Field survey results Renumbered EAL based on the change discussed above.

EAL #4 indicate EITHER of the EAL #3 indicate EITHER of the following at or beyond following at or beyond No change to the EAL wording.

(site-specific dose (site-specific dose receptor point): receptor point):

Closed window

Closed window dose Included discussion in Developer Notes concerning dose rates greater rates greater than 10 guidance in the 2017 EPA PAG Manual (EPA-400/R-than 10 mR/hr mR/hr are expected 17/001, PAG Manual: Protective Action Guides and expected to continue to continue for 60 Planning Guidance for Radiological Incidents) per for 60 minutes or minutes or longer. EPFAQ 2017- 01.

longer.

Analyses of field

Analyses of field survey samples survey samples indicate thyroid indicate thyroid CDE greater than 50 CDE greater than 50 mrem for one hour mrem for one hour

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis of inhalation. of inhalation.

IC AA2 Significant lowering of IC AA2 Significant lowering of No change to IC or EALs, but expanded the guidance in EAL #1 water level above, or EAL #1 water level above, or the Developer Notes pertaining to instrumentation that EAL #2 damage to, irradiated fuel. EAL #2 damage to, irradiated fuel. requires manual actions to place in service.

EAL #3 EAL #3 IC AA3 Radiation levels that IC AU3 Radiation levels that impede This IC and the EAL s were relocated from an Alert level EAL #1 impede access to EAL #1 access to equipment to an Unusual Event level; no changes were made to the EAL #2 equipment necessary for EAL #2 necessary for normal plant IC or EAL wording.Th e change was made based on a normal plant operations, operations, cooldown or reassessment of the potential impact of the event and cooldown or shutdown. shutdown. associated operating experience. Sites have plans and resources for responding to off-normal radiological conditions (e.g., those needed to meet NRC requirements).

A response to off -normal radiological conditions does not require afull activation of the site ERO, which would occur followingan Alert declaration. The declaration of an Unusual Event willensure that key ERO managers are made aware of the event and available to support the response if needed. Shouldthe event ha ve operational consequences, or lead to more significant radiological consequences, enough to warrant an Alert or higher classification, then the emergency declaration would be based on another IC.

IC AS1 (1) Reading on ANY of the IC AS1 (1) Reading on ANY of the No change to the EAL wording. Added a paragraph to the EAL #1 following radiation EAL #1 following radiation basis to explain a note that applies to the precalculated monitors greater than monitors greater than radiation monitor thresholds in EAL #1. These are the reading shown for the reading shown for determined (back calculated) using the dose value 15 minutes or longer: 15 minutes or longer: specified in the IC, and an assumed source term and (site-specific monitor (site-specific monitor meteorology. For this reason, the doses projected at the time of an event, which will be based on a source term

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis list and threshold list and threshold determined from plant indications and actual metrological values) values) data, may be above or below the dose specified in the IC.

Due to these expected differences, the radiation monitor readings in EAL #1 should not be used for emergency classification assessments if dose assessment results based on actual plant and meteorological conditions are available.

IC AS1 (2) Dose assessment using IC AS1 (2) Dose assessment using No change to the EALs.

EAL #2 actual meteorology EAL #2 actual meteorology EAL #3 indicates doses greater EAL #3 indicates doses greater Included discussion in Developer Notes concerning than 100 mrem TEDE than 100 mrem TEDE or guidance in the 2017 EPA PAG Manual (EPA-400/R-or 500 mrem thyroid 500 mrem thyroid CDE 17/001, PAG Manual: Protective Action Guides and CDE at or beyond (site-at or beyond (site-Planning Guidance for Radiological Incidents) per specific dose receptor specific dose receptor EPFAQ 2017- 01.

point). point).

(3) Field survey results (3) Field survey results indicate EITHER of the indicate EITHER of the following at or beyond following at or beyond (site-specific dose (site-specific dose receptor point): receptor point):

Closed window dose

Closed window dose rates greater than 100 rates greater than 100 mR/hr expected to mR/hr are expected to continue for 60 minutes continue for 60 minutes or longer. or longer.

Analyses of field survey

Analyses of field survey samples indicate samples indicate thyroid thyroid CDE greater CDE greater than 500 than 500 mrem for one mrem for one hour of

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis hour of inhalation. inhalation.

IC AS2 Spent fuel pool level at IC AS2 Spent fuel pool level at No change to IC or EAL, but expanded the guidance in the EAL #1 (site-specific Level 3 EAL #1 (site-specific Level 3 Developer Notes pertaining to instrumentation that description). description). requires manual actions to place in service.

IC AG1 (1) Reading on ANY of the IC AG1 (1) Reading on ANY of the No change to the EAL wording. Added a paragraph to the EAL #1 following radiation EAL #1 following radiation basis to explain a note that applies to the precalculated monitors greater than monitors greater than radiation monitor thresholds in EAL #1. These are the reading shown for the reading shown for determined (back calculated) using the dose value 15 minutes or longer: 15 minutes or longer: specified in the IC, and an assumed source term and (site-specific monitor (site-specific monitor meteorology. For this reason, the doses projected at the list and threshold list and threshold time of an event, which will be based on a source term values) values) determined from plant indications and actual metrological data, may be above or below the dose specified in the IC.

Due to these expected differences, the radiation monitor readings in EAL #1 should not be used for emergency classification assessments if dose assessment results based on actual plant and meteorological conditions are available.

IC AG1 (2) Dose assessment using IC AG1 (2) Dose assessment using No change to the EALs.

EAL #2 actual meteorology EAL #2 actual meteorology EAL #3 indicates doses greater EAL #3 indicates doses greater Added text to the Basis to better explain the relationship than 1,000 mrem TEDE than 1,000 mrem TEDE between IC AG1 and IC FG1.

or 5,000 mrem thyroid or 5,000 mrem thyroid CDE at or beyond (site-CDE at or beyond (site-specific dose receptor specific dose receptor Included discussion in Developer Notes concerning point). point). guidance in the 2017 EPA PAG Manual (EPA-400/R-(3) Field survey results (3) Field survey results 17/001, PAG Manual: Protective Action Guides and indicate EITHER of the indicate EITHER of the Planning Guidance for Radiological Incidents) per following at or beyond following at or beyond EPFAQ 2017- 01.

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis (site-specific dose (site-specific dose receptor point): receptor point):

Closed window dose

Closed window dose rates greater than 1,000 rates greater than 1,000 mR/hr expected to mR/hr are expected to continue for 60 minutes continue for 60 minutes or longer. or longer.

Analyses of field survey

Analyses of field survey samples indicate samples indicate thyroid thyroid CDE greater CDE greater than 5,000 than 5,000 mrem for mrem for one hour of one hour of inhalation. inhalation.

IC AG2 Spent fuel pool level cannot IC AG2 Spent fuel pool level cannot No change to IC or EAL, but expanded the guidance in the EAL #1 be restored to at least (site-EAL #1 be restored to at least (site-Developer Notes pertaining to instrumentation that specific Level 3 specific Level 3 description) requires manual actions to place in service.

description) for 60 minutes for 60 minutes or longer.

or longer.

IC CU1 UNPLANNED loss of N/A None -deleted. The IC and EALs were removed because the associated EAL #1 (reactor vessel/RCS [PWR] events represent a minor loss of inventory control or EAL #2 or RPV [BWR]) inventory monitoring, and thus pose a safety risk low enough as to for 15 minutes or longer. not reasonably require an emergency declaration. The plant is in a cold condition (RCS 200°F) with significant water volumes in the RCS/RPV and available for addition.

Activation of a site emergency plan and partial ERO mobilization would not be necessary to respond to an event. During Cold Shutdownand Refueling modes, stations typically have a large contingent of operations and technical staff onsite 24/7 to work the outage. This means the staff needed to respond to an event are available to

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis take prompt actions. An event would not create any impediments to activation of the ERO or performance of security plan-related functions. An appropriate lower bound for declaring an emergencywould be i f an event resulted in a significant level drop or protracted loss of level indication. In these cases, an event would be classified as an Alert under IC CA1, Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory.

IC CU2 Loss of all but one AC N/A None -deleted. The IC and EAL were removed because theimpact from EAL #1 power source to emergency the event poses a safety risk low enough as to not buses for 15 minutes or reasonably require an emergency declaration. The plant is longer. in a cold condition (RCS 200°F) with significant water volumes in the RCS/RPV and available for addition(in many cases, through gravity feed). The event would be addressed by the requirements in plant Technical Specifications (e.g., immediately restore another required power source to OPERABLE status). Activation of a site emergency plan and partial ERO mobilization would not be necessary to respond to the event. During Cold Shutdown and Refueling modes, stations typically have a large contingent of operations and technical staff onsite 24/7 to work the outage. This means the staff needed to respond to an event are available to take prompt actions.

An appropriate lower bound for declaring an emergency would be if all AC power were lost. In this case, the event would be classified as an Alert under IC CA2, Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.

IC CU3 (1) UNPLANNED increase N/A None -deleted. The EAL w as removed because theassociated event in RCS temperature to represent a minor temperature excursion and thus poses a

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis EAL #1 greater than (site-safety risk low enough as to not reasonably require an specific Technical emergency declaration. Although the cold shutdown Specification cold temperature limit may have be en exceeded, bulk boiling of shutdown temperature the RCS is not imminent. Activation of a site emergency limit). plan and partial ERO mobilization would not be necessary to respond to an event. During Cold Shutdown and Refueling modes, stations typically have a large contingent of operations and technical staff onsite 24/7 to work the outage. This means the staff needed to respond to an event are availab le to take prompt actions. The event would not create any impediments to activation of the ERO or performance of security plan-related functions.

An appropriate lower bound for declaring an emergency would be if the event persisted for a time greater than that specified in Table CA3-1; in that case, it would be classified as an Alert under IC CA3, Inability to maintain the plant in cold shutdown.

IC CU3 (2) Loss of ALL RCS IC CU3 (1) Loss of ALL RCS Renumbered EAL based on the change discussed above.

EAL #2 temperature and EAL #1 temperature and (reactor (reactor vessel/RCS vessel/RCS [PWR] or

[PWR] or RPV [BWR ]) RPV [BWR]) level level indications for 15 indications for 15 minutes or longer. minutes or longer.

IC CU4 Loss of Vital DC power for IC CU4 Loss of Vital DC power for No change to IC or EAL. Deleted Developer Note on EAL #1 15 minutes or longer. EAL #1 15 minutes or longer. battery voltage -information was judged to be unnecessary since site-specific values should be considered.

IC CU5 Loss of all onsite or offsite IC CU5 Loss of all onsite or offsite No change to IC or EAL. Added Developer Note EAL #1 communications EAL #1 communications guidance to address operating experience with

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis EAL #2 capabilities. EAL #2 capabilities. electronic/internet-based notification methods (e.g., ROP EAL #3 EAL #3 FAQ 20-04).

IC CA1 (1) Loss of (reactor IC CA1 (1) Loss of (reactor Added a note and basis information to clarify EAL #1 vessel/RCS [PWR] or EAL #1 vessel/RCS [PWR] or classification expectations if the point of the leakage is EAL #2 RPV [BWR]) inventory EAL #2 RPV [BWR]) inventory above the vessel flange.

as indicated by level as indicated by level less less than (site-specific than (site-specific level). In EAL #2.a, added a provision for BWRs to use the term level). (2) a. (Reactor vessel/RCS determined per EPFAQ 2019 -04.

(2) a. (Reactor vessel/RCS [PWR] or RPV [BWR ])

[PWR] or RPV [BWR ]) level cannot be Changed the 15 minutes criterion in EAL #2.a to 30 level cannot be (monitored [PWR] or minutes to align the EAL more closely with the definition monitored for 15 determined [BWR]) for of an Alert (i.e., it was determined that 15 minutes was not minutes or longer 30 minutes or longer. long enoughto say there was a potential substantial AND AND reduction in the level of plant safety). This is appropriate

b. UNPLANNED b. EITHER of the given the RCS conditions during shutdown, available large increase in (site-specific following: water volumes, large on -site staff during outages, and sump and/or tank) 1. UNPLANNED bounding for escalation provided by IC CS1.

levels due to a loss of increase in (site-specific (reactor vessel/RCS sump and/or tank) levels Added EAL statement (2).b.2 since visual observation

[PWR] or RPV [BWR ]) due to a loss of (reactor could also identify unisolable leakage.

inventory. vessel/RCS [PWR] or RPV [BWR]) inventory.

OR

2. Visual observation of UNISOLABLE RCS leakage.

IC CA2 Loss of all offsite and all CA2 Loss of all offsite and all No change to IC or EAL. Added a note and basis EAL #1 onsite AC power to EAL #1 onsite AC power to information on credit for non-safety-related power

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis emergency buses for 15 emergency buses for 15 sources; this addition addressed EPFAQ 2015-15. Added minutes or longer. minutes or longer. information to Developer Note section on the basis for the 15 minutes used in the EAL.

IC CA3 (1) UNPLANNED increase IC CA3 (1) UNPLANNED increase To address operating experience, added two notes and EAL #1 in RCS temperature to EAL #1 in RCS temperature to basis information on:

greater than (site-greater than (site-1) How to assessa temperature excursion if the decay specific Technical specific Technical heat removal function is available, and Specification cold Specification cold 2) Sources to use for RCS temperature information if shutdown temperature shutdown temperature reliable RCS indications are not available.

limit) for greater than limit) for greater than Also added the table number into the EAL wording.

the duration specified in the duration specified in the following table. the Table CA3-1, RCS Heatup Duration Thresholds.

IC CA3 (2) UNPLANNED RCS N/A None -deleted. This EAL was removed because theassociated event EAL #2 pressure increase represents a minor loss of pressure control, and thus poses greater than (site-a safety risk low enough as to not reasonably require an specific pressure emergency declaration. In addition, the assessment of the reading). (This EAL EAL is problematic during the specified modes because does not apply during there may be periods where 1) the instrumentation needed water-solid plant to measure RCS pressure is not available and 2) the RCS conditions. [PWR]) is not intact. Further, many plants are challenged to accurately read small changes in RCS pressure during shutdown conditions with available instrumentation. RCS temperature indications are diverse and highly reliable, and sufficient to identify and assess an RCS temperature increase(which is the focus of IC CA3). Should an issue occur with temperature indications during the Cold Shutdown and Refueling mode, it would be resolved promptly since stations typically have a large contingent

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis of operations and technical staff onsite 24/7 to work the outage.

IC CA6 Hazardous event affecting a IC CA6 Hazardous event affecting The IC and EAL were revised to incorporate lessons EAL #1 SAFETY SYSTEM needed EAL #1 two or more SAFETY learned from operating experience and feedback from the for the current operating SYSTEM trains. NRC staff. The IC is focused on an event impacting two mode. (1) a. The occurrence of or more safety system trains, whether they be on the same (1) a. The occurrence of ANY of the following system or different systems, and regardless of whether ANY of the hazardous events: their operation is required in the current operating mode.

following hazardous

Seismic event The logic requires degraded performance on one system events: (earthquake) train and either degraded performance or VISIBLE

Seismic event

Internal or external DAMAGE on another system train. The qualifiers (earthquake) flooding event concerning indications of degraded performance and

Internal or external V ISIBLE DAMAGE are built into the EAL and explicated flooding event

High winds or in the Basis. If an event causes indications of degraded tornado strike performance on an operating train of a safety system, then

High winds or

FIRE the assessment of the second train is independent of its tornado strike

EXPLOSION operability status.

FIRE * (site-specific

EXPLOSION hazards)

(site-specific

Other events with hazards) similar hazard

Other events with characteristics as similar hazard determined by the characteristics as Shift Manager determined by the AND Shift Manager b. The event has resulted AND in BOTH of the

b. EITHER of the following:

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis following: 1. Indications of

1. Event damage has degraded performance caused indications of on a SAFETY degraded performance SYSTEM train.

in at least one train of a AND SAFETY SYSTEM 2. EITHER of the needed for the current following:

operating mode. a) V ISIBLE OR DAMAGE to a

2. The event has caused second SAFETY VISIBLE DAMAGE to SYSTEM train.

a SAFETY SYSTEM OR component or structure b) Indications of needed for the current degraded operating mode. performance to a second SAFETY SYSTEM train.

N/A N/A IC CA7 Control Room evacuation This IC and EAL were relocated from the H Recognition EAL #1 resulting in transfer of plant Category to the C and S Recognition Categories.

control to alternate locations.

IC CS1 (1) a. CONTAINMENT IC CS1 (1) a. CONTAINMENT For the PWR portion of EAL #1.b, replaced Reactor EAL #1 CLOSURE not EAL #1 CLOSURE not vessel/RCS level less than (site-specific level) with A EAL #2 established. EAL #2 established. decrease in reactor vessel/RCS inventory has caused a loss EAL #3 AND EAL #3 AND of RHR flow for greater than 30 minutes. EAL 1.b is

b. (Reactor vessel/RCS b. (A decrease in reactor concerned with a loss of RHR flow due to reduced water

[PWR] or RPV vessel/RCS inventory inventory. The R6 EAL used a loss of level in a loop leg

[BWR]) level less has caused a loss of as the threshold indication since the water in a loop is the pump suction source when RHR is in recirculation mode.

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis than (site-specific RHR flow for greater The R6 EAL has been problematic for many sites because level). than 30 minutes the temporary instrumentation used to measure loop level, (2) a. CONTAINMENT [PWR] or RPV level installed to support an outage, either does not have the CLOSURE less than (site-necessary range to indicate the level called-out in the R6 established. specific level) developer note or becomes unreliable in the lower end of AND [BWR]). the range. In addition, the IC is applicable in Modes 5 and

b. (Reactor vessel/RCS (2) a. CONTAINMENT 6, but the level instrumentation may be available only in

[PWR] or RPV CLOSURE certain plant configurations during these Modes.

[BWR]) level less established. Recognizing these challenges, the R6 developer notes than (site-specific AND instructs sites encountering one or more of the problems to level). b. (Reactor vessel/RCS not include EAL #1 (classification will be accomplished level less than (site-in accordance with EAL #3). Since the time between (3) a. (Reactor vessel/RCS specific level) [PWR] losing pump suction due to low loop level and a loss of

[PWR] or RPV or Adequate core RHR flow is very short, a decision was made to focus the

[BWR]) level cannot cooling cannot be EAL on the loss of RHR flow instead of the precursor be monitored for 30 assured [BWR)]). indication (i.e., replaced the cause [low loop level leading minutes or longer. to RHR suction loss] with the effect [lost RHR flow]).

AND (3) a. (Reactor vessel/RCS Indications of a loss of RHR flow are available in the

b. Core uncovery is [PWR] or RPV Control Room and would be readily recognized by indicated by ANY of [BWR]) level cannot operators. As noted in the IC basis, 30 minutes was the following: be (monitored [PWR] selected as a reasonable amount of time for plant operators

(Site-specific or determined to recognize the problem, verify that the affected train radiation monitor) [BWR]) for 30 cannot be restored (i.e., not a transient condition) and reading greater than minutes or longer. secure it, and place another train into service, if available.

(site-specific value) AND In summary, this change replaces an EAL that some plants

b. Core uncovery is cannot assess with one that all plants can use, thus

Erratic source range indicated by ANY of enhancing the effectiveness of a classification scheme.

monitor indication the following:

[PWR] * (Site-specific For EAL 2.b, replaced RPV level criterion with Adequate

UNPLANNED radiation monitor) core cooling cannot be assured. This change incorporates increase in (site-

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis specific sump and/or reading greater than concepts first captured in EPFAQ 2019-04. Although the tank) levels of (site-specific value) EPFAQ was a starting point, the information was evolved sufficient magnitude

Erratic source range during the development of Revision 7. The key point is to indicate core monitor indication that operators would use whatever core cooling methods uncovery [PWR] are specified in EOPs (which are developed appropriate to

(Other site-specific

UNPLANNED the plant design) and would make the declaration if it was indications) increase in (site-determined that adequate core cooling cannot be specific sump and/or assured. This approach is consistent with BWROG tank) levels of guidance for the development of EOPs.

sufficient magnitude to indicate core In EAL #3.a, added a provision for BWRs to use the term uncovery determined per EPFAQ 2019 -04.

Visual observation of UNISOLABLE Added a bullet to EAL (3).b since visual observation could RCS leakage of also identify unisolable leakage.

sufficient magnitude to make core uncovery likely

(Other site-specific indications)

N/A N/A IC CS7 Challenge to core cooling This is the relocated IC and EAL from IC HS6. See EAL #1 safety function with Control discussion below for IC HS6.

Room evacuated.

IC CG1 Loss of (reactor vessel/RCS IC CG1 Extended loss of core decay This IC and the associated EALs were revised to address EAL #1 [PWR] or RPV [BWR ]) EAL #1 heat removal capability. issues with the current wording. The goal was to reduce EAL #2 inventory affecting fuel challenges posed by the existing wording associated with clad integrity with assessing core and containment conditions while shut containment challenged. down. For example:

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis

Some Containment Closure measures may be temporary and may not have remote indications

Instrumentation may be out-of-service for maintenance or repair

Reliance on judgment calls concerning the magnitude of changes to tank or sump levels

Radiation monitor readings were calculated based on assumed conditions and these may be different than actual conditions The revised wording should promote more timely and accurate emergency classifications. Additional supporting information is contained in the Basis and Developer Notes of the revised IC.

IC E -HU1 Damage to a loaded cask IC E -HU1 Damage to a loaded spent This IC and EAL were revised to address operating EAL #1 CONFINEMENT EAL #1 fuel cask. experience. For many sites, the EAL described in Rev. 6 BOUNDARY. was challenging to assess and to maintain as different cask (1) A closed window survey technologies were placed into service. The revised (1) Damage to a loaded indicates EITHER of the wording eliminates the technical specification criterion cask CONFINEMENT following: (the source of the issues with the Rev. 6 EAL) and focuses BOUNDARY as a. For a loaded spent instead on a measured dose rate. This approach is used in indicated by an on-fuel cask on the ISFSI other EALs (e.g., IC AU3), and should promote more contact radiation pad - A general area timely and accurate emergency classifications. Additional reading greater than (2 dose rate greater than supporting information in contained in the Basis and times the site-specific 10x normal radiation Developer Notes.

cask specific technical levels at any point along specification allowable the pad boundary.

radiation level) on the OR surface of the spent fuel b. For a loaded spent

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis cask. fuel cask in transit to the IS FSI p ad -A cask dose rate greater than 10x the dose rate measured at the time the cask was sealed, at approximately the same distance.

FPB Table N/A FPB Table N/A Editorial change -removed the 9 from all instances of 9-F-1, 9-F-2 F-1, F-2 and 9 -F-x to make consistent with how other tables in NEI and 9-F-3 F-3 99- 01 are identified (i.e., only the Recognition Category letter is used).

FPB Table (Site-specific indications FPB Table (Site-specific indications of Changed the basis for the threshold from 300 uCi/cc Dose 9-F-2 that reactor coolant activity F-2 reactor coolant activity Equivalent Iodine (DEI) to 2% cladding failure, which is Fuel Clad is greater than 300 Ci/gm Fuel Clad corresponding to greater the lower end of the clad failure range that corresponds to Barrier Loss dose equivalent I-131). Barrier Loss than 2% fuel clad failure) 300 uCi/cc DEI. The revised basis will promote a more 1.A 1.A standardized approach to the calculation of a monitor reading because most licensee core damage assessment tools deal in percents of fuel cladding damage, not DEI concentrations.The legacy 300 uCi/cc DEI threshold basis was kept as an option for sites that want to use it.

FPB Table Primary containment FPB Table SAG entry required. This threshold was changed to align with the decision -

9-F-2 flooding required. F-2 making guidance in the Emergency Procedure and Severe Fuel Clad Fuel Clad Accident Guidelines (EPG/SAGs), issued by the BWROG.

Barrier Loss Barrier Loss The EPG/SAGs are used by BWR licensees to create their 2.A 2.A site-specific EOPs and SAGs. Changes made in EPG/SAGs Revision 3 necessitated this threshold change

-refer to EPFAQ 2015 -04. The threshold remains appropriate for the guidance in EPG/SAGs Revision 4.

FPB Table RPV water level cannot be FPB Table RPV water level cannot be No change to the threshold.

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis 9-F-2 restored and maintained F-2 restored and maintained Fuel Clad above (site-specific RPV Fuel Clad above (site-specific RPV Barrier water level corresponding Barrier water level corresponding to Potential to the top of active fuel) or Potential the top of active fuel) or Loss 2.A cannot be determined. Loss 2.A cannot be determined.

FPB Table Primary containment FPB Table Primary containment Changed the basis for the threshold from 300 uCi/cc Dose 9-F-2 radiation monitor reading F-2 radiation monitor reading Equivalent Iodine (DEI) to 2% cladding failure, which is Fuel Clad greater than (site-specific Fuel Clad greater than (site-specific the lower end of the clad failure range that corresponds to Barrier Loss value). Barrier Loss value). 300 uCi/cc DEI. The revised basis will promote a more 4.A 4.A standardized approach to the calculation of a monitor reading because most licensee core damage assessment tools deal in percents of fuel cladding damage, not DEI concentrations.The legacy 300 uCi/cc DEI threshold basis was kept as an option for sites that want to use it.

Added a paragraph to the basis to alert classification decision-makers that due to differences between the assumed conditions used to calculate the reading and the actual conditions at the time of the event, the actual percentage of fuel clad damage during an event could be higher or lower than that used to calculate the monitor reading.

FPB Table See wording in Rev. 6. FPB Table See wording in Rev. 7. The Other Indications row was deleted because 9-F-2 F-2 experience has indicated that this row is seldom used. If a Row 5, Row 5, site has an indicator that is readily available to assess the Other Emergency status of a fission product barrier, then it is included in one Indications, Director of the thresholds in rows 1 through 4. The deletion of the and Row 6, Judgment Other Indications row moved up the Emergency Emergency Director Judgment row (from 6 to 5), so the associated Director thresholds were renumbered as 5.A and 5.B.

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis Judgment

- This change affects all 6 columns in Table F -2.**

FPB Table Primary containment FPB Table Primary containment No change to the threshold.

9-F-2 pressure greater than (site-F-2 pressure greater than (site-RCS Barrier specific value) due to RCS RCS Barrier specific value) due to RCS Loss 1.A leakage. Loss 1.A leakage.

FPB Table RPV water level cannot be FPB Table RPV water level cannot be No change to the threshold.

9-F-2 restored and maintained F-2 restored and maintained RCS Barrier above (site-specific RPV RCS Barrier above (site-specific RPV Loss 2.A water level corresponding Loss 2.A water level corresponding to to the top of active fuel) or the top of active fuel) or cannot be determined. cannot be determined.

FPB Table UNISOLABLE break in FPB Table UNISOLABLE break in No change to the threshold. The Basis section was revised 9-F-2 ANY of the following: F-2 ANY of the following: to incorporate information from EPFAQ 2018 -02.

RCS Barrier (site-specific systems with RCS Barrier (site-specific systems with Loss 3.A potential for high-energy Loss 3.A potential for high-energy line breaks). line breaks).

FPB Table Emergency RPV FPB Table Emergency RPV No change to the threshold. The Basis section was revised 9-F-2 Depressurization. F-2 Depressurization. to incorporate information from EPFAQ 2015 -03.

RCS Barrier RCS Barrier Loss 3.B Loss 3.B FPB Table UNISOLABLE primary FPB Table UNISOLABLE primary No change to the threshold.

9-F-2 system leakage that results F-2 system leakage that results RCS Barrier in exceeding EITHER of RCS Barrier in exceeding EITHER of Potential the following: Potential the following:

Loss 3.A 1. Max Normal Operating Loss 3.A 1. Max Normal Operating

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis Temperature Temperature OR OR

2. Max Normal Operating 2. Max Normal Operating Area Radiation Level. Area Radiation Level.

FPB Table Primary containment FPB Table A. 1. Containment radiation No change to the first threshold condition. A second 9-F-2 radiation monitor reading F-2 monitor reading greater threshold condition was added because the primary RCS Barrier greater than (site-specific RCS Barrier than (site-specific containment monitors can see radioactive shine from Loss 4.A value). Loss 4.A value). RCS piping sources and therefore display elevated AND readings in the absence of any RCS leakage. Threshold 2.Increase in primary 4.A.2 is intended to prevent an unwarranted emergency containment sump declaration when the radiation monitor threshold is met, level. but there is no containment sump level increase indicative of RCS leakage beyond normally expected amounts.

Added a paragraph to the basis to alert classification decision-makers that due to differences between the assumed conditions used to calculate the reading and the actual conditions at the time of the event, the actual percentage of fuel clad damage during an event could be higher or lower than that used to calculate the monitor reading.

FPB Table UNPLANNED rapid drop FPB Table UNPLANNED rapid drop No change to the threshold.

9-F-2 in primary containment F-2 in primary containment CNMT pressure following primary CNMT pressure following primary Barrier containment pressure rise. Barrier containment pressure rise.

Loss 1.A Loss 1.A FPB Table Primary containment FPB Table Primary containment No change to the threshold.

9-F-2 pressure response not F-2 pressure response not CNMT consistent with LOCA CNMT consistent with LOCA

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis Barrier conditions. Barrier conditions.

Loss 1.B Loss 1.B FPB Table Primary containment FPB Table Primary containment No change to the threshold.

9-F-2 pressure greater than (site-F-2 pressure greater than (site-CNMT specific value). CNMT specific value).

Barrier Barrier Potential Potential Loss 1.A Loss 1.A FPB Table (site-specific explosive FPB Table (site-specific deflagration Changed explosive to deflagration to incorporate 9-F-2 mixture) exists inside F-2 mixture) exists inside information from EPFAQ 2019- 04.Deflagration is the CNMT primary containment. CNMT primary containment. concentration of concern in BWR EOPs/SAGs. Revised Barrier Barrier the Basis accordingly.

Potential Potential Loss 1.B Loss 1.B FPB Table HCTL exceeded. FPB Table HCTL exceeded. No change to the threshold but revised the Basis to remove 9-F-2 F-2 a reference to Primary Containment Pressure Limit A to CNMT CNMT reflect information in EPFAQ 2019- 04. Limit A is no Barrier Barrier longer used in BWR EPG/SAGs. Also revised the Potential Potential Developer Note to incorporate information from EPFAQ Loss 1.C Loss 1.C 2019- 04; again the goal was to maintain alignment with BWR EPG/SAGs.

FPB Table Primary containment FPB Table It cannot be determined that Changed the threshold to incorporate the wording 9-F-2 flooding required. F-2 core debris will be retained discussed in EPFAQ 2019- 04. The change aligns the CNMT CNMT in the RPV. threshold with the appropriate diagnostic decision point

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis Barrier Barrier described in the BWROG EPG/SAGs Revision 4. The Potential Potential Basis was revised accordingly.

Loss 2.A Loss 2.A FPB Table UNISOLABLE direct FPB Table UNISOLABLE direct No change to the threshold but revised the Basis to 9-F-2 downstream pathway to the F-2 downstream pathway to the incorporate information from EPFAQ 2015- 06. The new CNMT environment exists after CNMT environment exists after information provides clarity on the term direct path.

Barrier primary containment Barrier primary containment Loss 3.A isolation signal. Loss 3.A isolation signal.

FPB Table Intentional primary FPB Table Intentional primary Added the term SAGs per EPFAQ 2019 -04since 9-F-2 containment venting per F-2 containment venting per venting could be directed in SAG steps as well. Also CNMT EOPs. CNMT EOPs/SAGs. revised the Basis to add information from EPFAQ 2019-Barrier Barrier 04dealing with releases due to intentional containment Loss 3.B Loss 3.B venting.

FPB Table UNISOLABLE primary FPB Table UNISOLABLE primary No change to the threshold.

9-F-2 system leakage that results F-2 system leakage that results CNMT in exceeding EITHER of CNMT in exceeding EITHER of Barrier the following: Barrier the following:

Loss 3.C 1. Max Safe Operating Loss 3.C 1. Max Safe Operating Temperature. Temperature.

OR OR

2. Max Safe Operating 2. Max Safe Operating Area Area Radiation Level. Radiation Level.

FPB Table Primary containment FPB Table Primary containment No change to the threshold.Added a paragraph to the 9-F-2 radiation monitor reading F-2 radiation monitor reading basis to alert classification decision -makers that due to CNMT greater than (site-specific CNMT greater than (site-specific differences between the assumed conditions used to Barrier value). Barrier value). calculate the reading and the actual conditions at the time of the event, the actual percentage of fuel clad damage

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis Potential Potential during an event could be higher or lower than that used to Loss 4.A Loss 4.A calculate the monitor reading.

N/A N/A FPB Table A. RCS/reactor vessel level Thesenew thresholds w ere included to provide a diverse F-3 less than or equal to method for assessing a loss of the Fuel Clad Barrier, i.e.,

Fuel Clad (site-specific level) for separate from assessments based on core exit Barrier Loss greater than (site-thermocouple readings. The conditionindicate s a reactor 1.A and 1.B specific minutes) with vessel water level low enough to potentially allow no injection flow. significant superheating of reactor coolant.See the OR Developer Notes for additional basis information.

B. Hot leg level less than or equal to(site -specific level) for greater than 60 minutes with no injection flow.[ B&W plants only]

FPB Table A. RCS/reactor vessel level FPB Table A. RCS/reactor vessel level The existing threshold was revised to support the addition 9-F-3 less than (site-specific F-3 less than or equal to of the new Fuel Clad Barrier Loss thresholds 1.A and 1.B Fuel Clad level). Fuel Clad (site-specific level) for (see above). The revised thresholds will also better Barrier Barrier greater than 15 minutes accommodate the RVLIS systems developed by CE and Potential Potential with no injection flow. B&W, neither of which have full core height coverage.

Loss 1.A Loss 1.A OR The conditionindicate s a reactor vessel water level low and 1.B B. Hot leg level less than enough to potentially allow the onset of localized damage or equal to (site -specific to fuel cladding. See the Develop er Notes for additional level) for greater than basis information.

15 minutes with no injection flow.[ B&W plants only]

FPB Table A. Core exit thermocouple FPB Table A. Core exit thermocouple No change to the threshold.

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis 9-F-3 readings greater than F-3 readings greater than (site-Fuel Clad (site-specific Fuel Clad specific temperature value).

Barrier Loss temperature value). Barrier Loss 2.A 2.A FPB Table A. Core exit thermocouple FPB Table A. Core exit thermocouple No change to the threshold.

9-F-3 readings greater than F-3 readings greater than (site-Fuel Clad (site-specific Fuel Clad specific temperature value).

Barrier temperature value). Barrier Potential Potential Loss 2.A Loss 2.A FPB Table B. Inadequate RCS heat FPB Table B. Inadequate RCS heat No change to the threshold.Based on operating 9-F-3 removal capability via F-3 removal capability via experience, added a developer note to assist developers at Fuel Clad steam generators as Fuel Clad steam generators as sites using EOP guidance f or Combustion Engineering Barrier indicated by (site-Barrier indicated by (site-specific NSSSs.

Potential specific indications). Potential indications).

Loss 2.B Loss 2.B

FPB Table A. Containment radiation FPB Table Containment radiation Changed the basis for the threshold from 300 uCi/cc Dose 9-F-3 monitor reading greater F-3 monitor reading greater than Equivalent Iodine (DEI) to 2% cladding failure, which is Fuel Clad than (site-specific Fuel Clad (site-specific value). the lower end of the clad failure range that corresponds to Barrier Loss value). Barrier Loss 300 uCi/cc DEI. The revised basis will promote a more 3.A 3.A standardized approach to the calculation of a monitor reading because most licensee core damage assessment tools deal in percents of fuel cladding damage, not DEI concentrations.The legacy 300 uCi/cc DEI threshold basis was kept as an option for sites that want to use it.

Added a paragraph to the basis to alert classification decision-makers that due to differences between the

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis assumed conditions used to calculate the reading and the actual conditions at the time of the event, the actual percentage of fuel clad damage during an event could be higher or lower than that used to calculate the monitor reading.

FPB Table B. (Site-specific indications FPB Table B. (Site -specific indications Changed the basis for the threshold from 300 uCi/cc Dose 9-F-3 that reactor coolant F-3 of reactor coolant activity Equivalent Iodine (DEI) to 2% cladding failure, which is Fuel Clad activity is greater than Fuel Clad corresponding to greater the lower end of the clad failure range that corresponds to Barrier Loss 300 Ci/gm dose Barrier Loss than 2% fuel clad failure) 300 uCi/cc DEI. The revised basis will promote a more 3.B equivalent I-131). 3.B standardized approach to the calculation of a monitor reading because most licensee core damage assessment tools deal in percents of fuel cladding damage, not DEI concentrations.The legacy 300 uCi/cc DEI threshold basis was kept as an option for sites that want to use it.

FPB Table See wording in Rev. 6. FPB Table See wording in Rev. 7. The Other Indications row was deleted because 9-F-3 F-3 experience has indicated that this row is seldom used. If a Row 5, Row 5, site has an indicator that is readily available to assess the Other Emergency status of a fission product barrier, then it is included in one Indications, Director of the thresholds in rows 1 through 4. The deletion of the and Row 6, Judgment Other Indications row moved up the Emergency Emergency Director Judgment row (from 6 to 5), so the associated Director thresholds were renumbered as 5.A and 5.B.

Judgment

- This change affects all 6 columns in Table F-3. **

FPB Table A. An automatic or manual FPB Table A. RCS subcooling has This threshold was revised based on operating experience.

9-F-3 ECCS (SI) actuation is F-3 been lost. A loss of subcooling is the fundamental indication that the RCS Barrier required by EITHER of RCS Barrier available inventory control /makeup systems cannot Loss 1.A the following: Loss 1.A adequately maintain RCS pressure and inventory against

1. UNISOLABLE RCS the mass loss through the leak. This condition represents a

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis leakage loss of the RCS Barrier.

OR

2. SG tube RUPTURE.

FPB Table A. Operation of a standby FPB Table A. An automatic or manual This threshold was revised based on operating experience.

9-F-3 charging (makeup) F-3 ECCS (SI) actuation is Given the change above, it was determined that the ECCS RCS Barrier pump is required by RCS Barrier required by EITHER of (SI) actuation threshold would more appropriately define a Potential EITHER of the Potential the following: potential loss of the RCS Barrier. The change also Loss 1.A following: Loss 1.A 1. UNISOLABLE RCS provides a threshold with better alignment to the definition

1. UNISOLABLE RCS leakage and risk level of an Alert (because a potential loss of the leakage OR RCS will lead to an Alert declaration).

OR 2. SG tube RUPTURE.

2. SG tube leakage.

FPB Table B. RCS cooldown rate FPB Table B. RCS cooldown rate No change to the threshold.

9-F-3 greater than (site-F-3 greater than (site-specific RCS Barrier specific pressurized RCS Barrier pressurized thermal shock Potential thermal shock Potential criteria/limits defined by Loss 1.B criteria/limits defined Loss 1.B site-specific indications).

by site-specific indications).

FPB Table A. Inadequate RCS heat FPB Table A. Inadequate RCS heat No change to the threshold.Based on operating 9-F-3 removal capability via F-3 removal capability via experience, added a developer note to assist developers at RCS Barrier steam generators as RCS Barrier steam generators as sites using EOP guidance for Combustion Engineering Potential indicated by (site-Potential indicated by (site-NSSSs.

Loss 2.A specific indications). Loss 2.A specific indications).

FPB Table A. Containment radiation FPB Table A. 1. Containment radiation No change to the first threshold condition. A second 9-F-3 monitor reading greater F-3 monitor reading greater thresholdcondition was added because the containment

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis RCS Barrier than (site-specific RCS Barrier than (site-specific monitors can see radioactive shine from RCS piping Loss 3.A value). Loss 3.A value). sources and therefore display elevated readings in the AND absence of any RCS leakage. Threshold 3.A.2 is intended 2.Uncontrolled decrease to prevent an unwarranted emergency declaration when in Pressurizer level. the radiation monitor threshold is met, but there is no uncontrolled decrease in pressurizer level indicative of RCS leakage beyond normally expected amounts.

Added a paragraph to the basis to alert classification decision-makers that due to differences between the assumed conditions used to calculate the reading and the actual conditions at the time of the event, the actual percentage of fuel clad damage during an event could be higher or lower than that used to calculate the monitor reading.

FPB Table A. A leaking or FPB Table A 1. There is a Potential Revised the threshold to clearly state that the SG leakage 9-F-3 RUPTURED SG is F-3 Loss or Loss of the or RUPTURE condition must be associated with RCS CNMT FAULTED outside of CNMT RCS Barrier due to a leakage meeting the threshold for either RCS Barrier Loss Barrier Loss containment. Barrier Loss leaking or RUPTURED 1.A or RCS Barrier Potential Loss 1.A. It was always the 1.A 1.A SG. intent that the RCS leakage must be to a leaking or AND RUPTURED SG before an SAE is warranted, but now the

2. The leaking or expectation is explicit.

RUPTURED SG is FAULTED outside of containment.

FPB Table A. 1. (Site-specific criteria FPB Table A. 1. (Site-specific criteria No change to the threshold.

9-F-3 for entry into core F-3 for entry into core CNMT cooling restoration CNMT cooling restoration Barrier procedure) Barrier procedure)

Potential AND Potential AND

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis Loss 2.A 2. Restoration Loss 2.A 2. Restoration procedure not effective procedure not effective within 15 minutes. within 15 minutes.

FPB Table A. Containment radiation FPB Table A. Containment radiation No change to the threshold.Added a paragraph to the 9-F - 3 monitor reading greater F - 3 monitor reading greater basis to alert classification decision - makers that due to CNMT than (site - specific CNMT than (site - specific differences between the assumed conditions used to Barrier value). Barrier value). calculate the reading and the actual conditions at the time Potential Potential of the event, the actual percentage of fuel clad damage Loss 3.A Loss 3.A during an event could be higher or lower than that used to calculate the monitor reading.

FPB Table A. Containment isolation is FPB Table A. Containment isolation is Added the word atmosphere to improve clarity; this was 9-F - 3 required F - 3 required a non-intent change. The releases of interest are sourced CNMT AND CNMT AND from gaseous radioactivity in the containment atmosphere.

Barrier Loss EITHER of the following: Barrier Loss EITHER of the 4.A 1. Containment 4.A following:

integrity has been lost 1. Containment integrity based on Emergency has been lost based on Director judgment. Emergency Director OR judgment.

2. UNISOLABLE OR pathway from the 2. UNISOLABLE containment to the pathway from the environment exists. containment atmosphere to the environment exists.

FPB Table B. Indications of RCS FPB Table B. 1. There is a Potential Revised the threshold to clearly state that the leakage 9-F - 3 leakage outside of F - 3 Loss or Loss of the RCS outside containment condition must be associated with CNMT containment. CNMT Barrier due to RCS leakage meeting the threshold for either RCS Barrier

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis Barrier Loss Barrier Loss UNISOLABLE RCS Loss 1.A or RCS Barrier Potential Loss 1.A. It was 4.B 4.B leakage. always the intent that the leak path must be from the RCS AND to a location outside containment before an SAE is

2. The leakage is to a warranted, but now the expectation is explicit.

location outside of containment.

FPB Table A. Containment pressure FPB Table A. Containment pressure No change to the threshold.

9-F-3 greater than (site-F-3 greater than (site-CNMT specific value) CNMT specific value)

Barrier Barrier Potential Potential Loss 4.A Loss 4.A FPB Table B. Explosive mixture exists FPB Table B. Flammable mixture in Changed explosive to flammable as this is the term 9-F-3 inside containment F-3 containment atmosphere used for the mixture of concern in PWR EOPs/SA MGs.

CNMT CNMT Revised the Basis accordingly.

Barrier Barrier Potential Potential Loss 4.B Loss 4.B FPB Table C. 1. Containment pressure FPB Table C. 1. Containment pressure Containments are designed to accommodate the pressures 9-F-3 greater than (site-F-3 greater than (site-associated with a loss of coolant accident by having either CNMT specific pressure CNMT specific pressure large volumes, as in a large dry or subatmospheric Barrier setpoint) Barrier setpoint) containment, or by utilizing a pressure suppression Potential AND Potential AND system to reduce the volume, like an ice-condenser Loss 4.C 2. Less than one full Loss 4.C 2. Less than one full train containment. The latter type has a containment design train of (site-specific of (site-specific pressure typically in the range of 12 to 15 psig, compared system or equipment) system or equipment) to pressures 45 psig for large volume designs. Because is operating per is operating per design of their reliance on pressure suppression (heat removal) design for 15 minutes for 15 minutes or systems to prevent early failure of the containment, this

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis or longer. longer. [Ice condenser threshold was revised to apply only to plants with an ice plants only] condenser containment. For large volume containments, pressure-related challenges to containment are appropriately bounded by Containment Barrier Potential Loss threshold 4.A (i.e., would yield more appropriate timing of a General Emergency declaration). For additional information, refer to NUREG/CR-5589, Assessment of Ice-Condenser Containment Performance Issues, and NUREG/CR -6906, Containment Integrity Research at Sandia National Laboratories(as well as numerous other NRC documents on this topic).

IC HU1 Confirmed SECURITY IC HU1 Confirmed SECURITY No change to the IC or EALs. Added a basis statement to EAL #1 CONDITION or threat. EAL #1 CONDITION or threat. clarify that a site ISFSI is also within the scope of the IC.

EAL #2 EAL #2 Updated basis references to address new NRC notification EAL #3 EAL #3 requirements in 10 CFR Part 73.

Deleted a paragraph in the Basis section because it duplicated a paragraph in the Developer Notes section; the information is actually for developer usage.

IC HU2 Seismic event greater than IC HU2 Seismic event greater than The IC was revised to add a second EAL (#2). This EAL EAL #1 OBE levels. EAL #1 OBE levels. is used when the sites seismic monitoring instrumentation (1) Seismic event greater EAL #2 (1) Seismic event greater is out-of-service (i.e., a backup EAL). Use of a backup than Operating Basis than Operating Basis seismic event EAL was discussed in NEI 99-01, Revision Earthquake (OBE) as Earthquake (OBE) as 6, but a decision was made to take the information from indicated by: indicated by: the Developer Notes and turn it into a separate EAL.EAL (site-specific indication (site-specific indication #2 will allow operators to make timely and accurate that a seismic event met that a seismic event met or emergency classifications during periods when EAL #1 or exceeded OBE limits) exceeded OBE limits) cannot be assessed.

OR (2) a. Seismic monitoring

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis instrumentation is unavailable to the extent that an OBE cannot be determined (e.g., out-of-service for testing or maintenance).

AND

b. Control Room personnel feel an actual or potential seismic event.

AND

c. The occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager or Emergency Director.

IC HU3 Hazardous Event IC HU5 Hazardous Event EALs #1 and #3 were removed because the associated EAL #1 (1) A tornado strike within EAL #1 (1) Internal room or area events, by themselves, present a safety risk low enough as EAL #2 the PROTECTED EAL #2 flooding of a magnitude to not reasonably require an emergency declaration.

EAL #3 AREA. EAL #3 sufficient to require Should either event result in significant consequences, (2) Internal room or area manual or automatic then the appropriate ECL will be declared based on EAL #4 flooding of a magnitude electrical isolation of a another IC/EAL (e.g., if a tornado strike caused a loss of EAL #5 sufficient to require SAFETY SYSTEM offsite power, then an Unusual Event would be declared manual or automatic component needed for per IC SU1). Absent a consequence, there is no potential electrical isolation of a the current operating degradation of plant safety. Activation of a site

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis SAFETY SYSTEM mode. emergency plan and partial ERO mobilization would not component needed for (2) A hazardous event that be necessary to respond to an event. A site would have the current operating results in on-site sufficient protocols and capabilities to respond without mode. conditions sufficient to declaring an emergency (e.g., use of procedures and (3) Movement of personnel prohibit the plant staff resources for responding to severe weather or a hazardous within the from accessing the site material release). This includes performance of post-event PROTECTED AREA is via personal vehicles. assessments and implementation of corrective/

impeded due to an (3) (Site -specific list of compensatory measures (e.g., by staffing an outage control offsite event involving natural or technological center). Depending on the circumstances of the event, hazardous materials hazard events) some plant response actions may also be required by (e.g., an offsite Technical Specifications.

chemical spill or toxic gas release). A Note was added to the example EALs -EAL #2 does (4) A hazardous event that not apply if the ERO members needed to staff emergency results in on-site response facilities are prepositioned onsite prior to the conditions sufficient to event. This note precludes a declaration during events prohibit the plant staff anticipated in advance and for which the site has from accessing the site prepositioned ERO responders (e.g., prior to the arrival of via personal vehicles. a hurricane, significant rain event or winter storm, (5) (Site-specific list of wildfire, etc.).

natural or technological hazard events)

N/A N/A IC HU3 Gaseous release impeding This IC is a relocation of IC HA5. See discussion below EAL #1 access to equipment for IC HA5.

necessary for normal plant operations, cooldown,or shutdown.

IC HU4 FIRE potentially degrading IC HU4 FIRE potentially degrading Rev. 6 EALs #1 & #2 were removed because the EAL #1 the level of safety of the EAL #1 the level of safety of the associated events represent conditions that pose a safety

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis EAL #2 plant. EAL #2 plant. risk low enough as to not reasonably require an emergency EAL #3 EAL #1 (previous EAL #3) declaration. Activation of a site emergency plan and EAL #4 EAL #2 (previous EAL #4) partial ERO mobilization would not be necessary to respond to the event. A site would have sufficient procedures and capabilities to respond to these events without declaring an emergency (e.g., use of procedures and equipment described in the site Fire Protection Program). This includes performance of firefighting and post-event damage assessments, and identification and implementation of corrective/compensatory measures.

Depending on the circumstances of the event, some plant response actions may also be required by Technical Specifications. Should the event have a more than minor impact, the resulting indications and reports would be assessed, and an emergency declared under another IC.

EALs #3 and #4 were retained and renumbered as EAL #1 and EAL #2. In response to operating experience, the basis for EAL #2 was revised to make the condition requiring declaration clearer -the intent of the EAL and basis was not changed.

IC HU7 Other conditions exist IC HU6 Other conditions exist Renumbered the IC based on other changes. Added Shift EAL #1 which in the judgment of EAL #1 which in the judgment of Manager for clarity.

the Emergency Director the Shift Manager/

warrant declaration of a Emergency Director (NO)UE. warrant declaration of a (NO)UE.

IC HA1 HOSTILE ACTION within IC HA1 HOSTILE ACTION within No change to the IC or EALs. Pulled the definition of EAL #1 the OWNER EAL #1 the OWNER Owner Controlled Area into the Developer Notes (from

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis EAL #2 CONTROLLED AREA or EAL #2 CONTROLLED AREA or Appendix B) based on user feedback. Updated basis EAL #3 airborne attack threat EAL #3 airborne attack threat within references to address new NRC notification requirements within 30 minutes. 30 minutes. in 10 CFR Part 73 Deleted a paragraph in the Basis section because it duplicated a paragraph in the Developer Notes section; the information is actually for developer usage.

IC HA5 Gaseous release impeding IC HU3 Gaseous release impeding This IC and EAL were relocated from the Alert level to EAL #1 access to equipment EAL #1 access to equipment the Unusual Event level; no changes were made to the IC necessary for normal plant necessary for normal plant or EAL wording. The change was made based on a operations, cooldown or operations, cooldown or reassessment of the potential impact of the event and shutdown. shutdown. associated operating experience. Sites have plans and resources for responding to a hazardous materials event (e.g., those needed to meet OSHA or State requirements).

A hazardous materials response does not require a full activation of the site ERO, which would occur following an Alert declaration. The declaration of an Unusual Event would ensure that key ERO managers are made aware of the event and available to support the response if needed.

Should the event have significant operational or radiological consequences, enough to warrant an Alert or higher classification, then the emergency declaration would be based on another IC.

IC HA6 Control Room evacuation IC CA7 Control Room evacuation No change to the IC or EAL; however, the IC and EAL EAL #1 resulting in transfer of plant EAL #1 resulting in transfer of plant were relocated from the H Recognition Category to the C control to alternate IC SA3 control to alternate and S Recognition Categories.The new locations were locations. EAL #1 locations. determined to be a more logical fit.

(1) An event has resulted in (1) An event has resulted in plant control being plant control being transferred from the transferred from the Control

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis Control Room to (site-Room to (site-specific specific remote shutdown remote shutdown panels and panels and local control local control stations).

stations).

IC HA7 Other conditions exist IC HA6 Other conditions exist Renumbered the IC based on other changes. Added Shift EAL #1 which in the judgment of EAL #1 which in the judgment of Manager for clarity.

the Emergency Director the Shift Manager/

warrant declaration of an Emergency Director Alert. warrant declaration of an Alert.

IC HS1 HOSTILE ACTION within IC HS1 HOSTILE ACTION within No change to the IC or EAL.Updated basis references to EAL #1 the PROTECTED AREA. EAL #1 the PROTECTED AREA. address new NRC notification requirements in 10 CFR (1) A HOSTILE ACTION (1) A HOSTILE ACTION Part 73 is occurring or has is occurring or has Deleted a paragraph in the Basis section because it occurred within the occurred within the duplicated a paragraph in the Developer Notes section; the PROTECTED AREA PROTECTED AREA as information is actually for developer usage.

as reported by the (site-reported by the (site-specific security shift specific security shift supervision). supervision).

IC HS6 Inability to control a key IC CS7 Challenge to core cooling This IC and EAL were relocated from the H Recognition EAL #1 safety function from EAL #1 safety function with Control Category to the C and S Recognition Categories. The new outside the Control Room. Room evacuated. locations were determined to be a more logical fit.

(1) a. An event has resulted (1) a. Plant control has in plant control being been transferred to Simplified the wording in EAL 1.a; there was no change transferred from the locations outside the to the intent.

Control Room to (site-Control Room.

specific remote AND Changed EAL 1.b to provide escalation criteria that shutdown panels and b. EITHER of the reflects the intent of the previous criteria but is more local control stations).

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis AND following Initiating appropriate for shutdown conditions. If IC CA1 or CA3

b. Control of ANY of the Conditions is met. are met, then there is a challenge to removing heat from following key safety

IC CA1, Loss of the RCS, and an Alert would be declared. Should this functions is not (reactor vessel/RCS condition exist with the Control Room evacuated, then reestablished within [PWR] or RPV there may be additional challenges to controlling plant (site-specific number of [BWR]) inventory safety functions/equipment and escalation to a Site Area minutes).

IC CA3, Inability to Emergency is appropriate.

Reactivity control maintain the plant in

Core cooling cold shutdown

[PWR] / RPV water level [BWR]

RCS heat removal IC HS6 Inability to control a key IC SS3 Challenge to a fission This IC and EAL were relocated from the H Recognition EAL #1 safety function from EAL #1 product barrier with Control Category to the C and S Recognition Categories. The new outside the Control Room. Room evacuated. locations were determined to be a more logical fit.

(1) a. An event has resulted (1) a. Plant control has in plant control being been transferred to Simplified the wording in EAL 1.a; there was no change transferred from the locations outside the to the intent.

Control Room to (site-Control Room.

specific remote AND Changed EAL 1.b to provide escalation criteria that shutdown panels and b. ANY of the reflects the intent of the previous criteria but is more local control stations). following conditions clearly defined. The new wording also promotes timely AND exist: and accurate emergency declarations since operators will

b. Control of ANY of the

The reactor is not already be monitoring the status of the fission product following key safety shutdown with barrier table thresholds and associated indications.

functions is not adequate shutdown First bullet -a reactivity control problem is indicated reestablished within margin verified. if the The reactor is not shutdown with adequate (site-specific number of

A loss or potential shutdown margin verified.

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC and EAL# Rev. 6 Wording Rev. 7 IC and EAL# Rev. 7 Wording Change Summary/Basis minutes). loss of Fuel Clad Second bullet - if the Fuel Clad Barrier is potentially

Reactivity control Barrier (per the lost or lost, then there is a challenge to core cooling.

Core cooling Fission Product Third bullet - if the RCS Barrier is potentially lost or

[PWR] / RPV water Barrier Table). lost, then there is a challenge to RCS heat removal.

level [BWR]

A loss or potential

RCS heat removal loss of RCS Barrier If either the Fuel Clad or RCS Barrier is lost, then an Alert (per the Fission would be declared. Should this condition exist with the Product Barrier Control Room evacuated, then there may be additional Table). challenges to controlling plant safety functions/equipment and escalation to a Site Area Emergency is appropriate.

IC HS7 Other conditions exist IC HS6 Other conditions exist Renumbered the IC based on other changes. Added Shift EAL #1 which in the judgment of EAL #1 which in the judgment of Manager for clarity.

the Emergency Director the Shift Manager/

warrant declaration of a Emergency Director Site Area Emergency. warrant declaration of a Site Area Emergency.

IC HG1 HOSTILE ACTION N/A N/A The IC and EAL were deleted based on the resolution of EAL #1 resulting in loss of physical EPFAQ 2015-13 (ML16166A366). This EPFAQ control of the facility. addressed the application of lessons learned from the first cycle of Hostile Action -Based (HAB) drills and exercises to IC HG1. NEI and the industry had an opportunity to comment on the EPFAQ, and a public meeting was held to discuss and agree upon the resolution. The key point from the EPFAQ resolution is:

Based on these considerations and given the confusion these redundant EALs had on EAL decision-making at the GE level, consideration can be given to not include EAL HG1 in a site-specific EAL scheme. However, EALs AA2, AS2, AG2, AS1, AG1, HS1, HS6, HS7, and HG7 shall be

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis as provided in NEI 99-01, Revision 6 (ADAMS Accession No. ML12326A805) to ensure the intended event is appropriately bound at the correct ECL. Although some were renumbered, all the cited EALs have been retained in Revision 7.

IC HG7 Other conditions exist IC HG6 Other conditions exist Renumbered the IC based on other changes. Added Shift EAL #1 which in the judgment of EAL #1 which in the judgment of Manager for clarity.

the Emergency Director the Shift Manager/

warrant declaration of a Emergency Director General Emergency. warrant declaration of a General Emergency.

IC SU1 Loss of all offsite AC IC SU1 Loss of all offsite AC power No change to the IC or EAL.

EAL #1 power capability to EAL #1 capability to emergency emergency buses for 15 buses for 15 minutes or minutes or longer. longer.

(1) Loss of ALL offsite AC (1) Loss of ALL offsite AC power capability to power capability to (site-specific (site-specific emergency emergency buses) for buses) for 15 minutes or 15 minutes or longer. longer.

IC SU2 UNPLANNED loss of N/A None -deleted. The IC and EAL were removed because the associated EAL #1 Control Room indications event poses a safety risk low enough as to not reasonably for 15 minutes or longer. require an emergency declaration. Sites have sufficient procedures and capabilities to respond to this condition without the need to activate an emergency plan (e.g., use of protocols and resources for responding to a loss of operationally significant indications). In particular, a site can assess the equipment failure(s) and identify and implement any necessary corrective/compensatory

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis measures without needing to activate the emergency plan.

The appropriate lower bound for declaring an emergency due to a loss of indication condition is if it occurs during an event causing significant parameter changes affecting multiple safety systems. That condition is addressed by IC SA2, i.e., if a loss of indication condition occur s in conjunction with a reactor trip or ECCS (SI) actuation, then an Alert would be declared in accordance with IC SA2. More broadly, if activation of the emergency plan is warranted (e.g., an escalation in conditions), there are other ICs/EALs that would be considered for declaring an emergency.

IC SU3 Reactor coolant activity N/A None -deleted. The IC and EALs were removed because the associated EAL #1 greater than Technical event poses a safety risk low enough as to not reasonably EAL #2 Specification allowable require an emergency declaration. Activation of a site limits. emergency plan and partial ERO mobilization would not be necessary to respond to the event. A site would have sufficient capabilities to respond to this condition without declaring an emergency (e.g., procedures and resources described in Operations, Radiation Protection and Chemistry Programs). A ctions to lower RCS activity and/or shut down the plant would be driven by requirements in the sites Technical Specifications and AOPs/EOPs. This event would not create any impediments to activation of the ERO or performance of security plan-related functions. The appropriate lower bound for declaring an emergency due to RCS radioactivity levels are the thresholds presented in the fission product barrier tables.

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis IC SU4 RCS leakage for 15 minutes N/A None -deleted. The IC and EALs were removed because the associated EAL #1 or longer. event poses a safety risk low enough as to not reasonably EAL #2 require an emergency declaration. Activation of a site EAL #3 emergency plan and partial ERO mobilization would not be necessary to respond to the event. A site would have sufficient capabilities to respond to this condition without declaring an emergency (e.g., procedures and resources described in Operations, Radiation Protection and Chemistry Programs). Actions to i solate the RCS leakage and/or shut down the plant would be driven by requirements in the sites Technical Specifications and AOPs/EOPs.This event would not create any impediments to activation of the ERO or performance of security plan-related functions. The appropriate lower bounds for declaring an emergency due to RCS leakage are the thresholds presented in the fission product barrier tables.

IC SU5 Automatic or manual (trip N/A None -deleted. The IC and EALs were removed because the associated EAL #1 [PWR] / scram [BWR]) event poses a safety risk low enough as to not reasonably EAL #2 fails to shutdown the require an emergency declaration. Activation of a site reactor. emergency plan and partial ERO mobilization would not be necessary to respond to the event. A site would have sufficient procedures and capabilities to respond to an unsuccessful reactor trip/scram without declaring an emergency (e.g., following instructions in EOPs). It is worth noting that light water power reactor facilities are required to have ATWS mitigation equipment and strategies per 10 CFR 50.62 (which helps maintain very low safety risk), and that the associated mitigation equipment is subject to the maintenance requirements in

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis 10 CFR 50.65 (thus ensuring high reliability). For this IC, although there was an issue with the RPS, the reactor was promptly shutdown following the initial trip/scram failure (through an alternative method) and no fission product barrier was challenged. The RPS issue would be addressed by the stations corrective action program. In addition, some plant response actions would be required by Technical Specifications. Finally, t his conditionwould not create any impediments to activation of the ERO or performance of security plan-related functions.

IC SU6 Loss of all onsite or offsite IC SU4 Loss of all onsite or offsite No change to IC or EALs. Renumbered the IC based on EAL #1 communications EAL #1 communications other changes. Added Developer Note guidance to EAL #2 capabilities. EAL #2 capabilities. address operating experience with electronic/internet-EAL #3 EAL #3 based notification methods (e.g., ROP FAQ 20-04).

IC SU7 Failure to isolate IC SU5 Failure to isolate Renumbered the IC based on other changes.

EAL #1 containment or loss of EAL #1 containment [PWR] or loss EAL #2 containment pressure EAL #2 of containment pressure No change to EAL #1.

control. [PWR] control. [Ice Condenser PWR]

(1) a. Failure of Revised IC statement and EAL #2 so that a loss of containment to (1) a. Failure of containment heat removal systems appl ies only to PWRs isolate when required containment to isolate with ice condenser containments. This change maintains by an actuation when required by an consistency with the revised threshold for PWR FPB signal. actuation signal. Containment Potential Loss 4.C (see the change basis AND AND above for the potential loss threshold).

b. ALL required b. ALL required penetrations are not penetrations are not closed within 15 closed within 15

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis minutes of the minutes of the actuation signal. actuation signal.

(2) a. Containment pressure (2) a. Containment pressure greater than (site-greater than (site-specific pressure). specific pressure).

AND [Ice condenser plants

b. Less than one full only]

train of (site-specific AND system or equipment) b. Less than one full is operating per train of (site-specific design for 15 minutes system or equipment) or longer. is operating per design for 15 minutes or longer. [Ice condenser plants only]

N/A N/A IC SU8 Automatic or manual (trip This is the relocated IC and EAL #1 from IC SA5; see EAL #1 [PWR] / scram [BWR]) fails change description below for IC SA5.

to shut down the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.

(1) a. An automatic or manual (trip [PWR]

/ scram [BWR]) fails to shut down the

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis reactor.

AND

b. Subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.

IC SA1 Loss of all but one AC IC SA1 Loss of all but one AC No change to IC statement. Revised EAL #1 to simplify EAL #1 power source to emergency EAL #1 power source to emergency the wording; no change to the intent (i.e., the EALs are buses for 15 minutes or buses for 15 minutes or functionally equivalent). Also added a provision to list longer. longer. credited power sources in the EAL (in Table SA1-1) per (1) a. AC power capability (1) Only one power source EPFAQ 2015-15.

to (site-specific listed in Table SA1-1 is emergency buses) is available to supply reduced to a single power to (site-specific power source for 15 emergency buses) for 15 minutes or longer. minutes or longer.

AND Table SA1-1: AC Power

b. Any additional single Sources power source failure Offsite will result in a loss of

Source #1 all AC power to

Source #2, etc.

SAFETY SYSTEMS. Onsite

Source #1

Source #2, etc.

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis IC SA2 UNPLANNED loss of IC SA2 UNPLANNED loss of Added alternative EAL 1.a with a provision for BWRs to EAL #1 Control Room indications EAL #1 Control Room indications use the term determined per EPFAQ 2019 -04.

for 15 minutes or longer for 15 minutes or longer with a significant transient with a significant transient Added provision for developers to specify the number of in progress. in progress. steam generators for which auxiliary or emergency fe ed (1) a. An UNPLANNED (1) a. An UNPLANNED water f low must be available. This allows the EAL to be event results in the event results in the more closely aligned with plant EOP requirements.

inability to monitor inability to monitor one or more of the one or more of the Deleted three of the listed transient events because their following parameters following parameters occurrence is not risk-significant enough to warrant an from within the from within the Alert declaration. These events would become Control Room for 15 Control Room for 15 sufficiently risk-significant if they lead to a reactor scram minutes or longer. minutes or longer. [BWR] / trip [PWR] or an ECCS (SI) actuation -these are ANY of the following [PWR] the two transient events that have been retained. In transient events in progress. a. One or more of the addition, the three deleted events can challenge a Control

Automatic or manual following parameters Room staffs ability to determine the start time of the runback greater than cannot be determined event. In many cases, a detailed review of computer logs 25% thermal reactor from within the or analog recorders would be required; these reviews power Control Room for 15 could likely not be completed in time to support a

Electrical load rejection minutes or longer due required emergency declaration and notification.

greater than 25% full to an UNPLANNED electrical load event. [BWR]

Reactor scram [BWR] / ANY of the following trip [PWR] transient events in progress.

ECCS (SI) actuation

Reactor scram [BWR] /

trip [PWR]

Thermal power

ECCS (SI) actuation oscillations greater than 10% [BWR]

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis N/A N/A IC SA3 Control Room evacuation This IC and EAL were relocated from IC HA6. No EAL #1 resulting in transfer of plant change to IC or EAL.

control to alternate locations.

(1) An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control stations).

IC SA5 Automatic or manual (trip IC SU8 Automatic or manual (trip This IC and EAL were relocated from the Alert level to EAL #1 [PWR] / scram [BWR]) EAL #1 [PWR] / scram [BWR]) the Unusual Event level. Also made minor wording fails to shutdown the fails to shut down the changes to the IC and EAL -no changes to the intent.

reactor, and subsequent reactor, and subsequent The relocation change was made based on a reassessment manual actions taken at the manual actions taken at the of the potential event risk and consequences, and reactor control consoles are reactor control consoles are associated operating experience. Activation of a site not successful in shutting not successful in shutting emergency plan and partial ERO mobilization would not down the reactor. down the reactor. be necessary to respond to the event. A s ite wouldhave

1) a. An automatic or procedures and capabilities to respond to an unsuccessful (1) a. An automatic or manual (trip [PWR] / reactor trip/scram (e.g., strategies and equipment to meet manual (trip [PWR] / scram [BWR]) fails to 10 CFR 50.62), including the use of alternative measures scram [BWR]) did not shut down the to shut down the reactor before a fission product barrier is shutdown the reactor. reactor. challenged (e.g., prompt local opening of reactor trip AND breakers). In addition, some plant response actions would AND b. Subsequent manual be required by Technical Specifications. If the failure to actions taken at the shut down the reactor is prolonged enough to challenge to reactor control the core cooling [PWR] / RPV water level [BWR] or RCS

b. Manual actions taken at consoles are not heat removal safety functions, the emergency the reactor control successful in shutting classification level will escalate to a n Alert (or higher) via consoles are not the thresholds in the Fission Product Barrier (FPB) Matrix,

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis successful in shutting down the reactor. or to a Site Area Emergency via IC SS8. Absent plant down the reactor. conditions that exceed an Alert or higher threshold/EAL,

an Unusual Event declaration is appropriate for this event.

IC SA9 Hazardous event affecting a IC SA7 Hazardous event affecting The IC and EAL were revised to incorporate lessons EAL #1 SAFETY SYSTEM needed EAL #1 two or more SAFETY learned from operating experience and feedback from the for the current operating SYSTEM trains. NRC staff. The IC is focused on an event impacting two mode. (1) a. The occurrence of or more safety system trains, whether they be on the same (1) a. The occurrence of ANY of the following system or different systems, and regardless of whether ANY of the hazardous events: their operation is required in the current operating mode.

following hazardous

Seismic event The logic requires degraded performance on one system events: (earthquake) train and either degraded performance or VISIBLE

Seismic event

Internal or external DAMAGE on another system train. The qualifiers (earthquake) flooding event concerning indications of degraded performance and

Internal or external V ISIBLE DAMAGE are built into the EAL and explicated flooding event

High winds or in the Basis. If an event causes indications of degraded tornado strike performance on an operating train of a safety system, then

High winds or

FIRE the assessment of the second train is independent of its tornado strike

EXPLOSION operability status.

FIRE * (site-specific

EXPLOSION hazards)

(site-specific

Other events with hazards) similar hazard

Other events with characteristics as similar hazard determined by the characteristics as Shift Manager determined by the AND Shift Manager b. The event has resulted AND in BOTH of the

b. EITHER of the

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis following: following:

1. Event damage has 1. Indications of caused indications of degraded performance degraded performance on a SAFETY in at least one train of a SYSTEM train.

SAFETY SYSTEM AND needed for the current 2. EITHER of the operating mode. following:

OR a) V ISIBLE

2. The event has caused DAMAGE to a VISIBLE DAMAGE to a second SAFETY SAFETY SYSTEM SYSTEM train.

component or structure OR needed for the current b) Indications of operating mode. degraded performance to a second SAFETY SYSTEM train.

IC SS1 Loss of all offsite and all IC SS1 Loss of all offsite and all No change to IC or EAL. Added a note and basis EAL #1 onsite AC power to EAL #1 onsite AC power to information to allow credit for non-safety-related power emergency buses for 15 emergency buses for 15 sources; this addition addressed EPFAQ 2015-15.

minutes or longer. minutes or longer.

N/A N/A IC SS3 Challenge to a fission This IC and EAL were relocated from IC HS6. See product barrier with Control discussion above for HS6.

Room evacuated.

IC SS5 Inability to shutdown the IC SS8 Inability to shut down the Renumbered the IC in support of other changes. Minor reactor causing a challenge reactor causing a challenge wording changes to IC and EALs -no changes in intent.

to (core cooling [PWR] / to (core cooling [ PWR] /

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis RPV water level [BWR]) or RPV water level [BWR]) or RCS heat removal. RCS heat removal.

(1) a. An automatic or (1) a. An automatic or manual (trip [PWR] / manual (trip [PWR] /

scram [BWR]) did not scram [BWR]) fails to shutdown the reactor. shut down the reactor.

AND AND

b. All manual actions to b. All subsequent shutdown the reactor manual actions to shut have been down the reactor have unsuccessful. been unsuccessful.

AND AND

c. EITHER of the c. EITHER of the following conditions following conditions exist: exist:

(Site-specific * (Site-specific indication of an indication of an inability to adequately inadequate core remove heat from the cooling) core)

Site-specific

(Site -specific indication indication of of an inability to inadequate RCS adequately remove heat removal heat from the RCS) [PWR] or a challenge to the Heat Capacity Temperature Limit

[BWR].

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis IC SS8 Loss of all Vital DC power IC SS6 Loss of all Vital DC power Renumbered the IC based on other changes. No change to for 15 minutes or longer. for 15 minutes or longer. IC or E AL.

(1) Indicated voltage is less (1) Indicated voltage is less than (site-specific bus than (site-specific bus Deleted Developer Note on battery voltage -information voltage value) on ALL voltage value) on ALL was judged to be unnecessary since site-specific values (site-specific Vital DC (site-specific Vital DC should be considered.

busses) for 15 minutes busses) for 15 minutes or longer. or longer.

IC SG1 Prolonged loss of all offsite IC SG1 Extended loss of all AC This IC and EAL were revised to remove to the loss of AC EAL #1 and all onsite AC power to EAL #1 power to emergency buses. power coping time assessment as it is no longer relevant emergency buses. (1) a. Loss of ALL offsite given the requirements in 10 CFR 50.155 (and the (1) a. Loss of ALL offsite and ALL onsite AC associated capabilities at each site). The new wording and ALL onsite AC power to (site-specific places the focus on indications of potential or actual core power to (site-specific emergency buses). damage (i.e., inadequate core cooling). This condition emergency buses). AND challenges the RCS and Fuel Clad Barriers and, if further AND b. (Site-specific mitigation actions are unsuccessful, the Containment

b. EITHER of the indication of Barrier.

following: inadequate core

Restoration of at cooling) least one AC emergency bus in less than (site-specific hours) is not likely.

(Site -specific indication of an inability to adequately remove heat from the core)

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis IC SG8 Loss of all AC and Vital IC SG6 Loss of all AC and Vital Renumbered the IC based on other changes. No change to DC power sources for 15 DC power sources for 15 IC or E AL.

minutes or longer. minutes or longer.

(1) a. Loss of ALL offsite (1) a. Loss of ALL offsite Added a note and basis information to address credit for and ALL onsite AC and ALL onsite AC non-safety-related power sources; this addition addressed power to (site-specific power to (site-specific EPFAQ 2015-15.

emergency buses) for emergency buses) for 15 minutes or longer. 15 minutes or longer. Deleted Developer Note on battery voltage -information AND AND was judged to be unnecessary since site-specific values

b. Indicated voltage is b. Indicated voltage is should be considered.

less than (site-specific less than (site-specific bus voltage value) on bus voltage value) on ALL (site-specific ALL (site-specific Vital Vital DC busses) for DC busses) for 15 15 minutes or longer. minutes or longer.

Appendix A Acronyms and Appendix A Acronyms and Added a few new abbreviations.

Abbreviations Abbreviations Appendix B Definitions Appendix B Definitions

Deleted the term CONFINEMENT BOUNDARY since it is no longer used in the scheme.

Deleted the term IMMINENT since it is no longer used in the scheme; determined there is no case where a definition beyond that commonly used and understood is necessary.

Deleted the term NORMAL LEVELS since it is no longer used in the scheme.

Moved the term OWNER CONTROLLED AREA to the Developer Notes of IC HA1 where it is used and can be more easily referenced.

Summary of IC and EAL Changes in NEI 99 -01 Revision 7

Rev. 6 IC Wording Rev. 7 IC Wording and EAL# Rev. 6 and EAL# Rev. 7 Change Summary/Basis

Revised the term PROJECTILE to incorporate the NRCs definition.

Updated the term UNISOLABLE to incorporate EPFAQ 2018- 01.

Revised the term VISIBLE DAMAGE to better align with changes made to IC CA6 or SA7.

Added a provision for BWR licensees to include definitions of cannot be maintained above/below and cannot be restored above/below, from EPG/SAG, Revision 4, to their emergency classification scheme, if those definitions appear in the site-specific EOPs and/or controlling development procedures.This change addressed information in EPFAQ 2019- 04.

Appendix C All ICs and EAL in N/A None -deleted. This Recognition Category was deleted. Licensees can Recognition Category PD, continue to follow the decommissioning scheme guidance Permanently Defueled in NEI 99-01, Revision 6, which is endorsed in Regulatory Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors, Revision 6. Future changes to decommissioning schemes will be addressed in guidance issued with the Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning rule. E.g., DG-1346, Emergency Planning for Decommissioning Nuclear Power Reactors

[proposed new Regulatory Guide 1.235].

ML24274A313

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