ML14164A056
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Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU76 Initiating Condition:
Loss of all On-site or Off-site communications capabilities.
Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): 1. Loss of ALL Table M3 Onsite communications capability affecting the ability to perform routine operations.
OR 2. Loss of ALL Table M3 Offsite communication capability affectina the abilitv to perform offsite notifications.
OR 3. Loss of ALL Table M3 NRC communication capability affecting the ability to perform NRC notifications.
Table M3 Communications CaDabilitv System Onsite Offsite NRC Radios X Plant page X Plant Telephone System X Sound Powered Phones X Commercial Telephones X X X NARS X ENS X X HPN X X Satellite phones _ X X 1. Loss of ALL of tho following oncito communication mIothods:*
v (sito spocific_
list of coemmunications mcthed+-6^ f4o-_s--I Month 20XX TMI 3-80 EP-AA-1009 (Revision XX)
Exelon Nuclear Three Mile Island Station Annex Exellon NuceIar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS (cito spocific list Of communUi~cations mcthodG)3. Loss of ALL o tho foloi the NRC comuic. ations methods'(site spocif ic list. of coammunications methods)Basis: I This IC addresses a significant loss of on-site-, offsite, or NRC OFeffske communications capabilities.
While not a direct challenge to plant or personnel safety, I this event warrants prompt notifications to Offsite Response Organizations (OROs. and the NRC.This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).EAL #1 Basis aAddresses a total loss of the communications methods used in support of routine plant operations.
EAL #2 Basis aAddresses a total loss of the communications methods used to notify all OROs of an emergency declaration.
The OROs referred to here are listed in procedure EP-MA-1 14-1 00-F-01, State / Local Event Notification Form. (coo EAL #3 basis aAddresses a total loss of the communications methods used to notify the NRC of an emergency declaration.
Basis Reference(s):
- 1. NEI 99-01 Rev 6, SU6 2. 1105-12 Communications System 3. FSAR Section 7.4.4, Communication Month 20XX TMI 3-81 EP-AA-1009 (Revision XX)
Throm Uila Wa6nd Qtatinn Annov I=Yalnn TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU87 Initiating Condition:
Failure to isolate containment or loss of containment pressure control.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): 1. a. Failure of containment to isolate when required by an actuation signal.AND b. ANY required penetration remains open > 15 minutes of the actuation signaL.ALL required penetrations aro not Glosod within 15 minutes ofth aGuaten signal.OR 2. a. Reactor Buildina pressure > 30 DSia AND b. Reactor Building Emergency cooling is less than ANY one of the following conditions
> 15 minutes: SPRAY COOLERS 2 0 0 3 1 1 a. Gontainment wersesr grcater man (Site S~eGITIG wroccurci.
lAND L- I I-W.. ...utit. I.~I _R"~ -ui; -w.U-1 1-0.i VI! tbi.,,,b 't-iPH ~~V Id UttK1iW~t 1b~;~u~ IddIK1t V.., A ai~r f ir, I + i~ ~rI~i~I I Uzi birl %7r m Hxx quo %7r x7ritit7r.
Basis: This IC addresses a failure of one Or any containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems. Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant.Month 20XX TMI 3-82 EP-AA-1009 (Revision XX)
Tkriags Uild li@Innr Qfc*irtun Auingv IP:v-alfn Nimdlach TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Fer-EAL #1 Basis ,-The containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure);
a failure resulting from testing or maintenance does not warrant classification.
The determination of containment and penetration status -isolated or not isolated -should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute criterion is included to allow operators time to manually isolate the required penetrations, if possible.EAL #2 Basis aAddresses a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design.The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible.
The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g., containment sprays or ice condenser fans) are either lost or performing in a degraded manner.This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers.Basis Reference(s):
- 1. NEI 99-01 Rev 6, SU7 2. FSAR Section 6.6 Reactor Building Pressure-Time Response 3. Technical Specifications 3.5.3, Engineered Safeguards Protection System Actuation Setpoints 4. FSAR Section 6.3.3, Actuation 5. FSAR Section 6.5.3, Hydrogen Generation
- 6. OP-TM-EOP-006, LOCA Cooldown 7. 1302-5.25 Reactor Building Sump Level 8. FSAR Section 5.2 Reactor Building 9. FSAR Section 9.2, Chemical Addition and Sampling System 10. OP-TM-EOP-002, Loss of 25 0 F Subcooling Margin 11. OP-TM-EOP-006, LOCA Cooldown 12. OP-TM-EOP-01 0, Emergency Procedure Rules, Guides and Graphs 13. OP-TM-MAP-D0301, High Make-up Flow Month 20XX TMI 3-83 EP-AA-1 009 (Revision XX) hrgo Uila lalzonel Qtafietn Annov I:vallnn KI%: : arh r Tkraa Mum 1e6nr4 ~tmtir~n Annmv Fvmlnn M..ri.mr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA12 Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.Operating Mode Applicability:
5,6, D Emergency Action Level (EAL): Note: The Emergency Director should declare the promptly upon determining that the applicable time 15 minutec time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to Emergency 4KV buses.AND 2. Failure of EG-Y-1A, EG-Y-11B Emergency Diesel Generators and EG-Y-4 SBO Diesel Generator to supply power to Emergency 4KV buses.AND 3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutes from the time of loss of both offsite and onsite AC power.Loes of ALL offsite and ALL onsite AC Powor to (site specific emergency buses) for 15 minuto Or Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an emergency bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, Month 20XX TMI 3-84 EP-AA-1009 (Revision XX)
Thrdaim Uilgh lalanri -Qfnfifn Annov I::gslnn hle ar~l~Tkrna MiI~ IeI~nrI Qt~tir~n Annn~w Fv.inn NI. .i-I~ar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.I Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via IC CS6 or RASI.Basis Reference(s):
- 1. NEI 99-01 Rev 6, CA2 2. FSAR Section 8.2.2, Unit Distribution System 3. FSAR Section 8.2.3, Sources of Auxiliary Power 4. Technical Specification Section 3.7, Unit Electric Power System 5. 1107-1 Normal Electrical System 6. 11 07-2A Emergency Electrical
-4KV and 480 Volt 7. OP-TM-AOP-020 Loss Of Station Power 8. 1107-3 Diesel Generator 9. 1107-9 SBO Diesel Generator 10. FSAR Section 8.5, Station Blackout Month 20XX TMI 3-85 EP-AA-1009 (Revision XX)
ExAIon Nuclear Ihri Win Is landl Station Annex EIxelln Nu!leIsar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU12 Initiating Condition:
Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:
5,6, D Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Eivontevent promptly upon determining that the applicable time 5--minute6-has been exceeded, or will likely be exceeded.1. AC power capability to Emergency 4KV buses reduced to only one of the following power sources for > 15 minutes.* Auxiliary Transformer 1A* Auxiliarv Transformer 1 B* Emergency Diesel Generator EG-Y-1A" Emergency Diesel Generator EG-Y-1 B* SBO Diesel Generator EG-Y-4 AND 2. Any additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.plwer courco for 15 minut cI Ior Inge.AND b. Any additional singlo power source failuro will result in leos of all AG power to SAFETY SYSTEMS.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or Dlacina it in the cold shutdown condition.
includina the EGCS.These are typically systems classified as safety-related.
This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.
Month 20XX TMI 3-86 EP-AA-1009 (Revision XX)
ExAIon Nuclear Thrpa Mill IslandI Rtation Annexr Exelon Nuclanr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS I When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased time available to restore another power source to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.I
- A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).
I
- A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.
- A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA1_.Basis Reference(s):
- 1. NEI 99-01 Rev 6 CU2 2. FSAR Section 8.2.2, Unit Distribution System 3. FSAR Section 8.2.3, Sources of Auxiliary Power 4. Technical Specification Section 3.7, Unit Electric Power System 5. 1107-1 Normal Electrical System 6. 11 07-2A Emergency Electrical
-4KV and 480 Volt 7. OP-TM-AOP-020 Loss Of Station Power 8. 1107-3 Diesel Generator 9. 1107-9 SBO Diesel Generator 10. FSAR Section 8.5, Station Blackout Month 20XX TMI 3-87 EP-AA-1009 (Revision XX)
Tknaft RA16% lalonA totinn Anndav I::valnn N"Aaarl Tkr~a Ilila lalauiri ~*a*kirm Ann~v Fvm Inn F'Juuir~Ia~v U III~~ 1U5h1 *OUE 1 tSSuu U UE SE 1fl ~ * * ~TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CA26 Initiating Condition:
Hazardous event affecting SAFETY SYSTEM needed-required for the current operating mode.Operating Mode Applicability:
5,6 Emergency Action Level (EAL): 1. a, The occurrence of ANY of the following hazardous events: " Seismic event (earthquake)" Internal or external flooding event" High winds or tornado strike" FIRE" EXPLOSION" (site sepocfic hazar~ds)" Other events with similar hazard characteristics as determined by the Shift Manager AND 2.b. EITHER of the following:
a.__,. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed-required by Technical Specifications for the current operating mode.ORThe event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure Reeded-required by Technical Specifications for the current operating mode.Basis: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.EXPLOSION:
A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization.
A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion.
Such Month 20XX TMI 3-88 EP-AA-1009 (Revision XX) hrom Uila Wand Qtafinn Annoy F:yalnn haPl"Aar Three Mile l@kanrl Qtntinn Anney Fvelnn Mm .r~lear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS events may require a post-event inspection to determine if the attributes of an explosion are present.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placinq it in the cold shutdown condition, includinq the ECOS. These are typically systems classified as safety-related.
VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis.
The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.
This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components,-
neededrequired for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL 1-b42.a Basis-aAddresses damage to a SAFETY SYSTEM train that is- required to be operable by Technical Specifications for the current operating mode, and is in 6e:VGe/operation since indications for it will be readily available.
The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.EAL 4-b-22.b Basis-aAddresses damage to a SAFETY SYSTEM component that is -required to be operable by Technical Specifications for the current operating mode, and is not in ewe peration or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components.
Operators will make this determination based on the totality of available event and damage report information.
This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6 or RAS1.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):
- 1. NEI 99-01 Rev 6, CA6 Month 20XX TMI 3-89 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU34 Initiating Condition:
Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Eventevent promptly upon determining that the applicable time 15 m..utcs time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on required 125 VDC Distribution Systems 1 A and 1 B for > 15 minutes.Indicated v,,oltage is loss than (site specific bus voltage v.. alue) On required Vita! DG h15buses forF 16 min*utes Or !onger.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC addresses a loss of Vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions Ii, Feaseraise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.
For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Depending upon the event, escalation of the emergency classification level would be via IC CA6 or CA5_, or an IC in Recognition Category BA.Month 20XX TMI 3-90 EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):
- 1. NEI 99-01 Rev 6, CU4 2. FSAR Section 8.2.2.6, 250/125 VDC System 3. 1107-2C Vital DC Electrical System 4. OP-TM-AOP-023, A DC System Failure 5. OP-TM-AOP-024, B DC System Failure Month 20XX TMI 3-91 EP-AA-1 009 (Revision XX)
Fxelon Nuclear Three Mile Isla~nd Station Annex ExeIon Nuclanr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4" Initiating Condition:
Loss of all onsite or offsite communications capabilities.
Operating Mode Applicability:
5,6, D Emergency Action Level (EAL): 1. Loss of ALL Table C1 Onsite communications capability affecting the ability to perform routine operations.
OR 2. Loss of ALL Table C1 Offsite communication capability affecting the ability to perform offsite notifications.
OR 3. Loss of ALL Table Cl NRC communication capability affecting the ability to perform NRC notifications.
Table Cl Communications Capabilitv System Onsite Offsite NRC Radios X Plant pagqe X Plant Telephone System X Sound Powered Phones X Commercial Telephones X X X NARS X ENS X X HPN X X Satellite phones X X 1. Loss of ALL ofth f10 ollowing GAsito communication motnode: (site 6pocific list Of communications moethods)2. Loess of ALL of tho following ORO comAmunications moethods:;(r.ite snnfoifi list of Gammus acat a nS mo~thnds\ .... -If............
I Month 20XX TMI 3-92 EP-AA-1009 (Revision XX)
ExAIon Nuclear Three Mile Islsand Stamtion Annex ExeIon Nucleasr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS
- 3. Loss of ALL of the following NRC communications mr.thods: (site -specific list of communications mnethods)Basis: I This IC addresses a significant loss of on-site-, offsite, or NRC --ffeie communications capabilities.
While not a direct challenge to plant or personnel safety, I this event warrants prompt notifications to Offsite Response Organizations (OROs. and the NRC.This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).EAL #1 Basis aAddresses a total loss of the communications methods used in support of routine plant operations.
EAL #2 Basis aAddresses a total loss of the communications methods used to notify all OROs of an emergency declaration.
The OROs referred to here are listed in Procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form._(see Developer Notes).EAL #3 Basis aAddresses a total loss of the communications methods used to notify the NRC of an emergency declaration.
Basis Reference(s):
- 1. NEI 99-01 Rev 6, CU5 2. 1105-12 Communications System 3. FSAR Section 7.4.4, Communication Month 20XX TMI 3-93 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Initiating Condition:
Inability to maintain the plant in cold shutdown.Operating Mode Applicability:
5,6 CA53 Emergency Action Level (EAL): Note: The Emergency Director should declare the Ale---event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temDerature
> 200°F due to loss of decay heat removal for > Table C2 duration.Table C2 RCS Heat-up Duration Thresholds RCS Containment Closure Heat-up Status Status Duration Intact Not Applicable 60 minutes*Not Intact Established 20 minutes*OR Reduced Not Established 0 minutes Inventory* If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not applicable.
OR 2. UNPLANNED RCS pressure rise > 10 osia as a result of temperature rise due to loss of decay heat removal. (This EAL does not apply in solid plant conditions.)
S I I M, f1 r 1 A 0,10 1I-r% ! ..I~If~ * .~..----.. .L.. 1¶L.ffffffffffffffffffffffffffff~-~--
~r'~I I IF~II-I -¶r~P~t-I I trwrr~z1r.r1 In I-¶1 = Tflmr1f~r1TIIrC~
T~ f1rf~ITf4r rrIn IFITf~ Vhlr-NIIIU Le....l c d rI-------
--- -------an ll, duration pepcifiod in the fo-lloing table.JVI Month 20XX TMI 3-94 EP-AA-1009 (Revision XX)
Tkrmm Uilia lalanri Qfatinn Anniav FIsYlnn Nn rlhuar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Table: RCS He-at up Duration Thoeshod RCS Staus Containment Clocuro Heat-up Duration Status hAtaet (but not at.reduod i nentoiI applia 6u iinutei fP444;1)Not intacst (Or at rouedGN7=
Establoshe2d M-nt~es-*Inwente~y
[Pl4q~) Not Ectabliched 0 F~inutes* if an RCS hoat removal system is in oncration with:in this time fr-ame and RCS tcmperaturo is boing reduced, the EAL. is not applmicablo-.i l&li--tl Ali, lklr"r't .-&I- /_.u -!.C!-' S ft Sr,. A ft ft ,rr% I-,IE.% .-. ~~V~T' 1~1 FT'~ f~r1rN~TIr*
rirrwi~i rf~h-. ' -~ ~-- r'rt4wTT~;.
~ S SIS 1 RU.. ~%~4j I *%t A~ASS.IPWAD II ULUI r.. ~Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter chanae or event mav be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, etc.).This IC addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.
The RCS Heat-up Duration Thresholds table addresses ao i6,reaserise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inventory is reduced (e.g., mid-loop operation in PWRs). The 20-minute criterion was included to allow time for operator action to address the temperature Month 20XX TMI 3-95 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS I The RCS Heat-up Duration Thresholds table also addresses an inereaserise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature inereaserise without a substantial degradation in plant safety.Finally, in the case where there is an inereaserise in RCS temperature, the RCS is not intact or is at reduced inventory-[P-RJ, and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes).
This is because 1) the evaporated reactor coolant may be released directly into the Containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.EAL #2 Basis pProvides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS61- or RAS1.Basis Reference(s):
- 1. NEI 99-01 Rev 6, CA3 2. Technical Specifications sections:
1.2.1, 1.7.a and c 3. Technical Specifications sections:
3.6.12.a 4. Technical Specifications sections:
3.6.5 5. Technical Specifications sections:
3.8.6 6. Technical Specifications sections:
1.2.1, 1.7.a and c, 3.6.12.a, 3.6.5, 3.8.6 7. 1101-3 Containment Integrity and Access Limits 8. OP-TM-EOP-030, Loss of Decay Heat Removal 9. Outage Fuel Protection Criteria Document Month 20XX TMI 3-96 EP-AA-1009 (Revision XX)
Throm Wha lalanri Qtafinn Annav I=Yalnn N, ii , nnilp nleaTBleniE l i 3-2n: EVIn lechnIcI TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU53 Initiating Condition:
UNPLANNED iArGease-rise in RCS temperature Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual E'-ntovent promptly upon determining that the applicable time -1.-miFites-has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temDerature
> 200°F due to loss of decay heat removal.OR 2. Loss of the followinq*
for > 15 minutes.* ALL RCS temperature indications AND* ALL RCS level indications 1 WWIPI NEDf InrrGMpp in 5Z~ tcF~r~nPtiir tG nrr"ateF than 1ritre 6nterifir
---r G g *-r~..,..%..a,..fI
~ nairi ni... .*rjn.Ar.
- nrv.r..n rr'.*. awn I;.'.'. ;*'I.............
r..... r f% I m A I I -'Cn a----.. Ui niLiL Iv ~IIIl,J'vf.JA,.UIU ,1IU IU..ULI~v vv vi , v, v,.v Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
This IC addresses an UNPLANNED i*Reeaserise in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine Month 20XX TMI 3-97 EP-AA-1009 (Revision XX)
Thre Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS RCS temperature and level, represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC CA53.RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.
I EAL #1 involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications.
During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.
During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled.
A loss of forced decay heat removal at reduced inventory may result in a rapid iniereaserise in reactor coolant temperature depending on the time after shutdown.EAL #2 reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.
I Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.
I Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA53 based on exceeding plant configuration-specific time criteria.Basis Reference(s):
Month 20XX TMI 3-98 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS
- 1. NEI 99-01 Rev 6, CU3 2. 1103-11 RCS Water Level Control 3. FSAR Section 7.3.2, Non-Nuclear Instrumentation
- 5. NEI 99-01 Rev 5, CU4 6. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX TMI 3-99 EP-AA-1009 (Revision XX)
Throm Uilds lalanel tatinn Annov P~valnn Nltrhlar Thro~ Mila IcI~nr4 ~t~tinn Annv ~v~Inn NiuiI.mr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CG6-4 Initiating Condition:
Loss of reactor vessel/RCS inventory affecting fuel clad integrity with containment challenged.
Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note: The Emergency Director should declare the G-noral ElinergencycLvent promptly upon determining that the applicable time 30-minutes-has been exceeded, or will likely be exceeded.1. Reactor vessel level unknown for > 30 minutes.AND 2. Core uncovery is indicated by ANY of the following: " Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Erratic Source Range Neutron Monitor indication.
OR" Radiation monitors RM-G-6 or RM-G-7 reading > 3 RPhr.AND 3. Any Containment Challenge Indication (Table Q4)Table C3 Indications of RCS Leakaqe" UNPLANNED Reactor BIdg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise** UNPLANNED RCDT level rise*" UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.
Month 20XX TMI 13-100 EP-AA-1 009 (Revision XX)
Thrdada Uilin lainnel Qfafinn Anngv FIaYlenn MN,,rluar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Table C4 Containment Challenge Indications
- Hydrogen Concentration in Containment
> 4%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established*
- if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.1 a. (Reactor S level less than (site specific level) for 30 minutes oF AND b. ANY indication from the Containment Ghallongce Table (see below).2. a. Reactor vesseV/RGS level cannot be moenitored-for 30 mninutes Or longor.Alki lr'k i ;~ A f A k, AK fV +k~ f H~IA~i¶A:IV. A: A: I-:4!: -1 e Erratic sour-ee range moenitor-indication
-- J1 0 4 +4XIW4ý AP;*IAQP, A I-q +Fk, q;RP.P. A V.14Mn AR--. Ar. M-A P,4ALQ, IQ Q P-14 92 6but.mna-nitude to inateute core uneoverw AND tner- site speelcifle atcattlons)
AKIV irA;^ft+a^r%
- r^rv, +kft tr-.+ ; + t-%k H -r k! k-0 lllU *U S w *l cciw Kl * *1t* *i *ClntainmInt Challenge Tablo 89 CONT.AINMENT CLOSURE not established*
45 (Explosive mixture) exists inside eontainment Is UNPLANNED increase in ntainment pressure Month 20XX TMI 13-101 EP-AA-1 009 (Revision XX)
Throm Uilm lalanrl Qtatinn Annov F:v-alnn M* r-loar Tkrea Mile lelenel ~tetiw~n Annay ~v.Inn M.u~l.er TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS
- If CONTAINMENT CLOSURE is re establiehd PrGir to eXcoding the 30 minute time limit, then d-larMati-n of a General Emer t reqUired.Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.IMMINENT:
The traiectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged.
This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity.
Releases can be reasonably expected to exceed EPA Protective Action Guidelines (PAG. exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment.
If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity.
It therefore represents a challenge to Containment integrity.
In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment.
If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.
Month 20XX TMI 3-102 EP-AA-1 009 (Revision XX)
ThrAma Milo lalanfi Qtafinn Annov IFvalnn hlir-laar Thrna Mila I@kanel ~t~tinn Ann~v Fv.Inn Muuri~~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS In EAL-2-b, Tthe 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties).
It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.
If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.
These EALs address concems raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
Basis Reference(s):
- 1. NEI 99-01 Rev 6, CG1 2. 1103-11 RCS Water Level Control 3. 1101-3 Containment Integrity and Access Limits 4. OP-TM-EOP-030, Loss of Decay Heat Removal 5. FSAR Sections 5.2, Reactor Building 6. FSAR Sections 6.5.2, Hydrogen Monitoring
- 8. Technical Specifications 3.5.5, Accident Monitoring Instrumentation
- 9. EP-AEL-0501, Estimation of Radiation Monitor Readings Indicating Core Uncovery During Refuel 10. 1301-1 Shift and Daily Checks, Data Sheet 3 Month 20XX TMI 3-103 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6-1 Initiating Condition:
Loss of reactor vessel/RCS inventory affecting core decay heat removal capability.
Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note: The Emergency Director should declare the Site Ara EmergencGye.ent promptly upon determining that the applicable time 30-*miRutes-has been exceeded, or will likely be exceeded.1. a. Reactor vessel/RCS level unknown for >30 minutes.AND b. Core uncovery is indicated by ANY of the following: " Table C3 indications of a sufficient magnitude to indicate core uncoverY.OR* Erratic Source Range Neutron Monitor indication.
OR" Radiation Monitors RM-G-6 or RM-G-7 reading > 3 R/hr.Table C3 Indications of RCS Leakaqe" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise*" UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.
Month 20XX TMI 3-104 EP-AA-1 009 (Revision XX)
Fxelon Nuclear Three Mile Island tation Annex Exelon Nulea. r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS 1 a. CONT.AI NMENT CLOS'U' nrm o.,t
- l.v .w u i 4zrI1MfrND PALN1%P1Ic^f~
Lo w w"-"J Lý ..... JI%-.--. r-2 a. CONITAINMEArMNlT ostablished.-AND I P. t elactOr V98seVRG8[-jt.
V -'vvn Or i-irv ["Mv-ff level less ihan tieno spe~ii eve+y b d b df A 3. a. t oacmor voesscv "b. [#dW-Hvt Or Kidw MVVi-hf ieVo1 c-annot DOP monnorca-e for 30 mFinuto or I9ngre.b. Core Uncovery is indicated by ANY of the followina:
.. ............
j ....--j ...........
0 (Site spccitic r-actiation moenitor-)
reactin ereater- tflan (site speeciei value)* ,rratic souree r-ane montotr n IP PWRNI J 1 1 P eLJ" 1UNPLAPNP4L increase int kstte speeciuc sump anwaor tanK) levels of Sufficefem magnitude to intdicate cor-e uncoever-y" (Other- site specific indieations)
Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.CONTAINMENT CLOSURE: The procedurallv defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
Thi" IC addresses a "ignificant and p,.l.ng.d loss of r.actOF. ...s-eVRCS in..ntor;control and makeup capability loading to IMMINENT fuel damage. .The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.
Month 20XX TMI 3-105 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS I Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.I Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.
The differenc
- e. in the speifi.ed RC5,,'roqact9r Veol levels of EAL" 1 .b and 2., rolo,-t the fact that with CLOSURE tr- thero ;s a la1 probability of a fission pro9duct roloaco to the enyironmont.
kin AL-&a 1-,tThe 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties).
It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.
If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump I and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.
These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
Escalation of the emergency classification level would be via IC CG-16 or ARG1.Basis Reference(s):
- 1. NEI 99-01 Rev 6, CS1 2. OP-TM-PRF1-0405 RB Sump Level Hi 3. 1101-3 Containment Integrity and Access Limits Month 20XX TMI 3-106 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS
- 4. 1301-1 Shift and Daily Checks, Data Sheet 3 5. 1103-11 RCS Water Level Control 6. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX TMI 3-107 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6I-Initiating Condition:
Loss of reactor vessel/RCS inventory.
Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note: The Emergency Director should declare the event Ale--promptly upon determining that the applicable time 4 6 minutes-has been exceeded, or will likely be exceeded.1. Loss of reactor vessel / RCS inventory as indicated by RCS level < 0 inches on Draindown Level indicator.
OR 2. a. Reactor vessel / RCS level unknown for > 15 minutes.AND b. Loss of reactor vessel / RCS inventory per Table C3 indications.
Table C3 Indications of RCS Leakage" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary BId-g. Sump level rise*" UNPLANNED BWST level rise*" UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vesseVRCS inventory.
- 1. Less of reactor invento, y as indicated by level less than (,ite- spcifi, level)2. a. Reactor vosA.ol'RCS_
level cannot be monitored for 15 minutes or longer Month 20XX TMI 13-108 EP-AA-1009 (Revision XX)
Fyplnn NunlAnr Thratz Miis 11-r-lnd Rtatinn Annox ExAInn Nunipjr~I TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS AND b. UNPLANNED increaso in (site cpecific sump and/or tank) levels due to less. Of roactor vocccl/RCS ivnoBasis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.--This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).This condition represents a potential substantial reduction in the level of plant safety.EAL #1 Basis F=G: EAL aA lowering of water level below 0 inches on Draindown Level indicator (site-speGifiG. indicates that operator actions have not been successful in restoring and maintaining reactor vessel/RCS water level. The heat-up rate of the coolant will iWiearserise as the available water inventory is reduced. A continuing desiease-drop in water level will lead to core uncovery.Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). An inIreaeerise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA53.EAL #2 Basis ,- AI-v,, tThe inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.
If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels.Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.
The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS61-If the reactor vessel/RCS inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS64-.Month 20XX TMI 3-109 EP-AA-1009 (Revision XX)
Thraso Mfiilg la@6ne1 Qttinn Annoy IFyalnn TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):
- 1. NEI 99-01 Rev 6, CA1 2. OP-TM-PRF1-0405 RB Sump Level Hi 3. 1301 -1 Shift and Daily Checks, Data Sheet 3 4. 1103-11 RCS Water Level Control 5. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX TMI 3-110 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU6-Initiating Condition:
UNPLANNED loss of reactor vessel/RCS inventory for 15 minutes or longer.Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note: The Emergency Director should declare the Unucual Eventevent promptly upon determining that the applicable time 45-inutes-has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in the inability to restore and maintain reactor vessel / RCS level to > procedurally established lower limit for > 15 minutes.OR 2. a. Reactor vessel / RCS level unknown AND b. Loss of reactor vessel / RCS inventory per Table 03 indications.
Table C3 Indications of RCS Leakage" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise*" UNPLANNED RCDT level rise*" UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.
I l_ _ I l= =- II .... .1. ,;io-R W 99 roaorA cooiant rIu-it In reactor ves,-v-68 level IeSeMan a reauired lowor limfit for 15 mninutoc Or loG~er.2~. a. ReiacROr vessew:u Ica lve GannoI he manmotau.Month 20XX TMI 3-111 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS
- h. UNPL ANNEDinrocoi (lit-p epoific sump andio tank) leveols.Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor reactor vessel/RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.The procedurally established lower limit is not an operational band established above the procedural limit to allow for operator action prior to exceeding the procedural limit, but it is the procedurally established lower limit.Refueling evolutions that deerease-lower RCS water inventory are carefully planned and controlled.
An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.EAL #1 Basis-rfecognizes that the minimum required reactor vessel/RCS level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented.
This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.EAL #2 Basis-aAddresses a condition where all means to determine reactor vessel/RCS level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.
Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6-- or CA53.Month 20XX TMI 3-112 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):
- 1. NEI 99-01, Rev. 6 CUi 2. Technical Specification
3.1.6. Leakage
- 3. OP-TM-220-251 RCS Leak Rate Determination Using PPC 4. OP-TM-220-252, Primary -To -Secondary Leakrate Determination (OTSG Leakage):
Normal Operations
- 5. OP-TM-MAP-C0105 RCS Draindown LVL HI/LO 6. OP-TM-PRF1-0405 RB Sump Level HI 7. UFSAR 6.4.3, Bases of Leakage Estimate 8. 1103-11 RCS Water Level Control 9. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX TMI 3-113 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 Initiating Condition:
HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:
1,2,3,4,5,6, D Emergency Action Level (EAL): 1. A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.AND 2. a. ANY Table H1 safety function cannot be controlled or maintained.
OR b. Damaae to spent fuel has occurred or is IMMINENT Table H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)" Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)1 A HOS9T" R ACTION in, ennuFiring n has nnnrcmrd w~ithin thN PRQTFCGT-E AD~A ..nna.4a~'4 k~. 4kn In4n rsaa;4 n nan. *nhi t.k;~ ~.W mV m mY A 13 C ANDl k EITuED ,ý*af II'amrik nir,4-. .a--"--I ----!UIV m TVl mOIIOW fflO -ýA&DT TEiCIfe iS~~ar-ar CTflflO .. aoiTo Zo or maitied." Reaetivity eontroel" Coe e-eealifg" RCS heat remoeval OP.a * .~+/-x~* L.-----a"A I amage to onn Tipin i nla ourrotU oer OF TMI 3-114!MMHN1M1N+.
EP-AA-1009 (Revision XX)Month 20XX hrgag% Rfiilg% lainnei tatinn Anndav I::aleln Thr~ MiI~ lolanri Qt~tir~n Ann~v Fv~Inn hi. maI.ar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:
An obiect directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.IMMINENT:
The traiectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions.
It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to 1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls, etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot be maintained.
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].Emorgoncy plans and implementing pr.,,durc thorefore, EALS, should not inceororate S-ecurity sensitive information.
This includoes infomation tha Month 20XX TMI 3-115 EP-AA-1009 (Revision XX)
Throa Uila Wand qtntinn Annow FYmlnn
- r MII~a~lkwIIii¥ IQHIIt tim AIII'vA IFvpInn NmItnisar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY may be adyantagopu6 to a potential advercar,', Such as the padiculaFGRG cocrina specific throat Or threat location.
Security sensitive infeo~mation should be contained in non public documon9te cuch as the Security Plan.Basis Reference(s):
- 1. NEI 99-01, Rev. 6 HG1 2. Security and Safeguards Contingency Plan Station Security Plan -Appendix C Month 20XX TMI 3-116 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 Initiating Condition:
HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:
1,2,3,4,5,6, D Emergency Action Level (EAL): A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.1. A HOSTILEr" ACTION.M is occurr.ing or has ..cur..d within the PROTECTED AREA as roportod by the (sito cpocific cocurity shift suporvision).
Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:
An obiect directed toward a NPP that could cause concem for its continued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.
Month 20XX TMI 3-117 EP-AA-1009 (Revision XX)
I=yAInn Thrat Milua haIand Rtiation Annax Exellnn Nuclei~ar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).
The Site Area Emergency declaration will mobilize ORO resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.
This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should be assessed using IC HAl. It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR§ 50.72.Emer-gency plans and implementing procoduros aro public documonts; thoreforo, EALs should not incorporato Sccurity sensitive information.
This includes information that may be advantageous to a poential andvxers-ary, SUch as, the particulars OA cneig a specific threat or threat loation. sensitiv.
e information should be conta"ined in non public dOcumoents such as the Security Plan.Escalation of the emergency classification level would be via IC HG1.Basis Reference(s):
- 1. NEI 99-01 Rev 6, HS1 2. Security and Safeguards Contingency Plan Station Security Plan -Appendix C Month 20XX TMI 3-118 EP-AA-1009 (Revision XX)
Thrisi Mfiil Ihunind Station Annex ExeInn Nuclazr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 Initiating Condition:
HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.Operating Mode Applicability:
1,2,3,4,5,6, D Emergency Action Level (EAL): 1. A validated notification from NRC of an aircraft attack threat < 30 minutes from the site.1. A HO1STILE ACTION is ....ring or- has o.....ed wit.hn the OWNER OR 2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.-A validated notification from NRC of an afircraft attack throat within 30 mninutoc of Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:
An obiect directed toward a NPP that could cause concem for its continued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business.Month 20XX TMI 3-119 EP-AA-1009 (Revision XX)
Thriam Uila lalanel Qtafinn Annov Pv--Ionn M ilAg~ar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).
The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL #1 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant Personnel and OROs are in a heightened state of readiness.
This EAL is met when the threat-related information has been validated in accordance with OP-TM-AOP-008, Security Threat /Intrusion.
EAL #24 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA.Month 20XX TMI 3-120 EP-AA-1009 (Revision XX)
Throgs Uila laicknei Qfzbfinn Anniav IFvalnn Mid-as:r~l Tkree Mile le6nrI ~totirn Annoy ~velnn hi. .,ior TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY EAL #2 addresses the throat from the impact of an arcraft. an the plant, and the anticipatod arri'.al time is within 30 mninutes.
Tho intent of this EAL is to cnsure tht thrAt+_relatAd ification; eare mnade in a timely maRennr so that plant and OR~s are in a heightened State Of readiness.
This EAL is mnet w~hen the threat reelatted information has boon validated in accordancc with (Site Specific procedure).
The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.
The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.EmergencY plans and implementing procedures are public documents; therefore, EiALs should not incorporate Security sensitive information.
This includ-e-s inforFmation that may be advantageous to a potential adver-sar;, such as the particul..ars cncming a specific thre-.at r t~hrea-t lctin Security sensitive information should be contained i non-public-doc-numents such as the Securfity Plan.Escalation of the emergency classification level would be via IC HS1.Basis Reference(s):
- 1. NEI 99-01 Rev 6, HA1 2. Security and Safeguards Contingency Plan Station Security Plan -Appendix C 3. OP-TM-AOP-008, Security Threat / Intrusion Month 20XX TMI 3-121 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 Initiating Condition:
Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:
1,2,3,4,5,6, D Emergency Action Level (EAL): 1. Notification of a credible security threat directed at the site as determined Per SY-AA-1 01-132, Security Assessment and Response to Unusual Activities.
1 .A SECURITY CONDITION that does not involve a HOSTILE ACT-ION as r-eperted by the (site specific secur-ity shift superyisioni).
OR 2. A validated notification from the NRC providing information of an aircraft threat.2. Notification of a cr-edible security threat direeted at the sitc OR 3. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.3. A validatod frm tho NRC proeviding information of an aircraf throat.Basis: SECURITY CONDITION:
Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION SAFETY SYSTEM: A system reguired for safe plant operation, cooling down the Plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).Month 20XX TMI 3-122 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-101-132.
rcforone-' (ct .p... securit. chi.t occurringohaocred Traiin onsouri' ont oonfirmation and casciafigoation im aontrollodl duo to the naturo Mof Saegurds and 10 CFr- & 2.Q inoain EAL #2 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.
The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with OP-TM-AOP-008, Security Threat / Intrusion. (sl-'+ .... ". -" ... .th. r"..'+-of a credible secuity throat. The credibility of tho thre.at. s assessed in aoredance with (site specific procedure).
EAL #3 references Security Force.s..
t spe.. fi. secu ftuýrit. h .....4 .... -because these are the individuals trained to confirm that a security event is occurring or has occurred.
Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.39 information.addrossc thb thr-oat from theo pla-t The d-arters Operatio-n
- Offier. )'.,;ll plane mayl alson be pro'.'j- iso by NORAM throughli ti-hejr HRO.0aldation0 of the- threat i EmFergency plans and implementing procedu wre are p-ublic documents; therefore, EALs Month I 2OX.. ....... .... TM.. ..... 3-.. .12 EP.... A -..... 00 (Revision
.. .X)...Month 20XX TMI 3-123 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY SFGUuIu iu nGI~upiL RGPFdeeUFiny eurWy~ iintorwtten. -t-HI AGIu-iuuu IinuIAWME"iu tw may be advantageous to a potential advorsar.., cUch a. the c. .ing a SepoiGctra rtra oain Socurity sensitive information should bo containod in no public documonts cuch as tho Socurity Plan.Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):
-132, Security Assessment and Response to Unusual Activities
- 3. Security And Safeguards Contingency Plan Station Security Plan -Appendix C Month 20XX TMI 3-124 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS26 Initiating Condition:
Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:
1,2,3, 4,5,6, D Emergency Action Level (EAL): Note: The Emergency Director should declare the Sit-e Area Em,,
promptly upon determining that (Site .p.ific nb---. '-the applicable has been exceeded, or will likely be exceeded.1. A Control Room evacuation has resulted in olant control beina transferred from the Control Room to the Remote Shutdown (RSD) stations.AND 2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* Core Cooling (ability to cool the core)" RCS Heat Removal (ability to maintain heat sink)1. a. An event has resulted in plant control being tra;ns~forre-d-panels andloa contro stations).
from the Control Room to (Sit Specifi remote Shutdon AND b. Control of ANY of the following key Safety fUnctienrs is not reostablished within (sto specific number of mninutes)." Reactivity control A r'.r -;1" rDIACam / iD\ MIA= I201 E IA/0I* RCS heat remov~al..... L ..... J Month 20XX TMI 3-125 EP-AA-1009 (Revision XX)
Thrgg% RAilim lalonrl Qfatinn Annmv PI=alrn N,,-Ilmar.... -- .w... ..s4. .ts4t.. a -n U. .n s.. .a TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Basis: The time Period to establish control of the plant starts when either: a. Control of the plant is no longer maintained in the Main Control Room OR b. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plan control to alternate locations is a precursor to a challenge to one Or moreajy fission product barriers within a relatively short period of time.The determination of whether or not "control" is established at the remote safe shutdown location(s) is based on Emergency Director judgment.
The Emergency Director is expected to make a reasonable, informed judgment within (the site-spe-i-f*
time f-. .a.sfeo 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).
Escalation of the emergency classification level would be via IC FG1 or CG64-.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HS6 2. OP-TM-EOP-020, Cooldown from Outside the Control Room Month 20XX TMI 3-126 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA26 Initiating Condition:
Control Room evacuation resulting in transfer of plant control to alternate locations.
Operating Mode Applicability:
1, 2,3,4,5,6, D Emergency Action Level (EAL): An-eyentA Control Room evacuation has resulted in plant control being transferred from the Control Room to the Remote Shutdown (RSD) stations.
'.(.ite-.peGi...
remote shutdown pano lhand- control stations).
Basis: This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations.
The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel.
Activation of the ERO and emergency response facilities will assist in responding to these challenges.
Escalation of the emergency classification level would be via IC HS26.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HA6 2. OP-TM-EOP-020, Cooldown from Outside the Control Room Month 20XX TMI 3-127 EP-AA-1009 (Revision XX)
Three Mile IAsland Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU34 Initiating Condition:
FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:
1,2,3,4,5,6, D Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Eventevent promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of the following FIRE detection indications: " Report from the field (i.e., visual observation)" Receipt of multiple (more than 1) fire alarms or indications" Field verification of a single fire alarm OR 2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).AND b. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR 3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.
OR 4 A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
Month 20XX TMI 3-128 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Table H2 Vital Areas* Reactor Building* Intake Building 0 Intermediate Building* Control Tower* Auxiliary and Fuel Handling Buildings* 1 A and 1 B Diesel Generator Buildings* BWST* CST* ILBIB t .I
- Il " (1) a. A & Imit- us P1444 emtinaulshed witnin 113-minutoS Of AP* of the Tollewing FR-iit aetection iAG1cGAuons:
0 ý f~rf t f *k~t f ,h^ Col b~ a~. v .cua ah-raon w A* 55 .S S S tfl St. S .S ~S .V S- ---S V LASS%~* 5/v A A SI34LJt:XSS USAPS S/SStJ UA SL in nw eRem vu ...ILIUI elt a3 singleu 1111 aIla ANDl.w-zrv (site-spocifi list of plant rooms or arcas)AJE __ \;.I a. eODDIO or a single Tra naram i.e.. no Gfmer inoucamon of a ri-1~i 9..........
I" AND b. Th- FIRE is locAted Within ANY of thA fo.lloinn ,lant ro omsFo areas.(6itc spocific li6t of plant rooms Or areas)AiND G. The e;stcno of -a FIRE is not Yrificd wA~ithin 30 minutes of alarm (3) A FIRE within the plant ,r -pnt with an ISFS. outside the plant;rottedAfera l PROTECTED AREA not etinguished within 60minutes oft i nitial report, alarm Or indication.
- AIm I
- al l *C41 1'- HI-IH AAIRfllf tfA flIflt or 1541i-Si Un Pl nantr. mw!T an ii-Sif ni imrin MRl~ Wantf I "!Dv ... .-',*i A ..- w-¶ DD 1 ýwT f ADýA *k.w '.I~i~ -5 *rmkVLI NUr~,S w-h R wý c , offsiot- fire response to ..v;-,a ui;h il--I Month 20XX TMI 3-129 EP-AA-1009 (Revision XX)
ThrimAm Wig& laltanei Qfnfirn Annimv WL~v,'Innn kNilr-Imor TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Basis: FIRE: Combustion characterized by heat and light. Sources of smoke such as slippinq drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.EAL #1 Basis The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed.
Similarly, the fire duration clock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 Basis This-EAL-aAddresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.
A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a Month 20XX TMI 3-130 EP-AA-1009 (Revision XX)
Nuclear ThreIeI MilIe IVsland Station Annex FI n NucIeasr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.
EAL #3 Basis In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety. This basis extends to a FIRE ccurr'ing within thc PROTECTED AREA -ofn SFSI lo,,,,,,,ated
,.,id.-,,e the plant PROTECTED AREA.[Sentence for plants with an ISESI outside the plant P-roterted Anrea EAL #4 Basis If a FIRE within the plant or ISFS, [forplants with an ISFSI the plant Prtoctod Ar-ea]-PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded.
The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish.
Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.
In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.Month 20XX TMI 3-131 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA26 or MA5SA9.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HU4 2. FSAR Figure 2.1-3, Extended Plot Plan TMINS 3. FSAR Section 5.1, Class I Structures, Components, and Systems 4. OP-TM-AOP-001, Fire 5. OP-TM-EOP-020, Cooldown Outside of Control Room Month 20XX TMI 3-132 EP-AA-1009 (Revision XX)
Throm Uila lalanri Qfafinn Annov I::alnn NnMalr Tham. Mum IoImnrI Qtmtir~n Annmv Fvmlnn i~ImirIm~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU42 Initiating Condition:
Seismic event greater than OBE levels.Operating Mode Applicability:
1,2,3,4,5,6, D Emergency Action Level (EAL): Seismic event > Operating Basis Earthquake (OBE) as indicated by seismic Alarms PRF-1-3 Operating Basis Earthquake and PRF-1-2 Threshold Seismic Condition.
Siw;n-m eveont groatcr than Oporating Basis Earthquak, (,BE) as indicatod by:.a. (cito- sepoific indic-ation that.asii ovent met Or oxcooedod 0OBE limits)Basis: This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE)'. An earthquake greater than an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections).
Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following an OBE. Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA26 or HA5SA".An OBE is vibratory ground motion for which those features of a nuclear power plant necessary for continued operation without undue risk to the health and safety of the public will remain functional.
An SSE is vibratory ground motion for which certain (generally, safety-related) structures, systems, and components must be designed to remain functional.
Month 20XX TMI 3-133 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Basis Reference(s):
- 1. NEI 99-01, Rev 6 HU2 2. OP-TM-AOP-003, Earthquake
- 3. PRF 1-3 Operating Bases Earthquake
- 4. PRF 1-2 Threshold Seismic Event Month 20XX TMI 3-134 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 Initiating Condition:
Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:
1,2,3,4,5,6, D Emergency Action Level (EAL): Note: If the eauipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emeraencv classification is warranted.
- 1. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*
Modes 4. 5. and 6 Intermediate Building*
Modes 4, 5, and 6 Auxiliary Building*
Modes 4, 5, and 6 Fuel Handling Building*
Modes 4, 5, and 6*Areas required to establish shutdown cooling AND 2. Entrv into the room or area is prohibited or impeded Note: It the equipment In the listed oom or arca was areadyinoperable Or out1 e e thc event occurred, then no- omergency classification is Wa~rated.-
(1) a. Release of a toxiccroie asphyxiant or: flammable gas into any of the followin pln-ooSo rias OR!.' ...-10-J --J - --...........
- J.L ----X .... I=,IL--J =--J--ýWTYZTZ ýým ý'&' ZI.r, ., I Month 20XX TMI 3-135 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY b. intry into the rFOom O area is prohibited or impeded.Basis: This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant proceduresma.itai.
no.mal plant operamtio o requed for a no.mal plant coodown and chutd -- ..n... This condition represents an actual or potential substantial degradation of the level of safety of the plant.Table H3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown.This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas.An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the gaseous release preclude the ability to place shutdown cooling in serviceat the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
An emergency declaration is not warranted if any of the following conditions apply.The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release).
For example, the plant is in Mode 1 when the gaseous Month 20XX TMI 3-136 EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing)." The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment.
This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.I This EAL does not apply to firefighting activities that generate smoke or that automatically or manually activate a fire suppression system in an area.I Escalation of the emergency classification level would be via Recognition Category BA, C or F ICs.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HA5 2. FSAR Figure 2.1-3, Extended Plot Plan TMINS 3. FSAR Section 5.1, Class I Structures, Components, and Systems 4. NEI 99-01, Rev. 5 HA3 5. OP-TM-406-901, Hazardous Material Release 6. AR-660892, Station Halon and IDLH Evaluations
- 7. 29CFR1910.134(b) and 29CFR1910.134(d)(2)(iii)
Month 20XX TMI 3-137 EP-AA-1009 (Revision XX)
Throm Uila Wand Qtatinn Annov Fvl=eml Kbitl-har TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU63 Initiating Condition:
Hazardous Event Operating Mode Applicability:
1, 2,3,4,5,6, D Emergency Action Level (EAL): Note: EAL #4 does not applv to routine traffic impediments such as foq. snow, ice, or vehicle breakdowns or accidents.
- 1. Tornado strike within the PROTECTED AREA.OR 2. Internal room or area floodinq of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode.OR 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involvina hazardous materials (e.a., an offsite chemical spill or toxic aas release).OR 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessina the site via Dersonal vehicles.OR 5. Abnormal river water level at the intake Pump and Screen House. as indicated by EITHER: a. > 300 ft. el. (high level)OR b. < 274 ft. el. (low level)KI M AI 4J'Url nA r4n nrnt nrm 1rn*.4;n ; A; ml- 1 4- -. ma .to UM "me% " K----I- "- -" " M e " p " r tf~, rf t----I--:--I--
L --- --I-J av a narln ate.I----- --~-------%.Ii III^ ^/ ^ pt Ir^^ A ti IPll 14I A ~ .....Z..~...L..
4L.. M^ r1r-r-*r~rý A Mr-~ A k -Li iU i ru .uii i M1 tWHIM, btHMI W~tH, t iu Month 20XX TMI 3-138 EP-AA-1009 (Revision XX) hroo Uila halsand Rtntinn Annoy Thi. MIuli Iv v Vt~n A Exn Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY (2) Irt-,.,.--
re mOrT, ar; -... e-,,-,,.;,,g of a magntud ; ,I ..ft,,;n-, to ..... e ....I,, automatic A-elotrical isoelation of a SAFETYý SYSTEM Gompnn neded for thO current operating moede-.(3) Movement o-f personnel within the PROTECTED AREA is impeded duo to an offeito eyent in.oighzardous materials (e.g., an offeito chemical spill Or toxiG_(4) A hazardouc event that results in on-site conditions suffic-ient to prohibit the plant staff frome _accessing the site via personal vehicles.(5) (Site-specific of natural Or thngical hazard events)Basis: PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.SAFETY SYSTEM: A system required for safe plant ogeration.
cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are tygically systems classified as safety-related.
This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.EAL #1 -Basis-aAddresses a tornado striking (touching down) within the Protected Area.EAL #2 Basis aAddresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. Manual isolation of power to a SAFETY SYSTEM component as a result of leakage is an event of lesser impact and would be expected to cause small and localized damage. The consequence of this type of event is adequately assessed and addressed in accordance with Technical Specifications.
EAL #3 Basis aAddresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.Month 20XX TMI 3-139 EP-AA-1009 (Revision XX)
Three Mile IRsland Station Annex Exelon NuceIar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY EAL #4 Basis aAddresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.
Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.EAL #5 Basis: The level of the Susquehanna River is approaching flood stage; flood stage is defined as 302 ft el. at the Intake Pump and Screen House.A low river water condition below 274 ft el. requires a Technical Specification
3.0.1 plant
shutdown per OP-TM-AOP-005 and is a precursor to a more serious condition.
EAL= #5 addroccec (site spccific descriptiGPn).
Escalation of the emergency classification level would be based on ICs in Recognition Categories RA, F, MSj H or C.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HU3 2. OP-TM-AOP-005 River Water System Failures 3. OP-TM-AOP-002, Flood 4. OP-TM-AOP-004, Tornado / High Winds Month 20XX TMI 3-140 EP-AA-1 009 (Revision XX)
Thrmn~ M.ild li@Inni Q*fafinnu Anngav I=v-mlnn M"rAmar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG7 Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY.
Operating Mode Applicability:
1,2,3, 4,5,6, D Emergency Action Level (EAL): (44 Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Basis: IMMINENT:
The traiectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy eguipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:
An obiect directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a General Emergency.
Basis Reference(s):
- 1. NEI 99-01, Rev 6 HG7 Month 20XX TMI 3-141 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS7 Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY.
Operating Mode Applicability:
1,2,3, 4,5,6, D Emergency Action Level (EAL): M( Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:
An obiect directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a Site Area Emergency.
Basis Reference(s):
Throm Milts Weandi Qtatinn Anno~v Fwi::nl N, Mplar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA7 Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT Operating Mode Applicability:
1,2, 3, 4, 5, 6, D Emergency Action Level (EAL): (-1) Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HA7 Month 20XX TMI 3-143 EP-AA-1009 (Revision XX)
Thnag Migla Ieanei Qtntiv~n Annov I:valenn Mir-loar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU7 Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrant declaration of an (NO),UNUSUAL EVENT.Operating Mode Applicability:
1,2,3, 4,5,6, D Emergency Action Level (EAL): I (-M1 Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an EVENT.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HU7 Month 20XX TMI 3-144 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis Emergency Action Level Technical Basis Page Index General Site Area Alert Unusual Event EAL Pg. EAL Pg. EAL Pg. EAL Pg.RG1 3-32 RS1 3-34 RA1 3-36 RU1 3-39 RA2 3-42 RU2 3-44 RA3 3-46 RU3 3-49 FG1 3-50 FS1 3-51 FA1 3-52 1 Fuel Clad RCS Containment FC1 3-53 RC1 3-59 CT1 3-64 FC2 3-54 RC2 3-61 CT2 3-67 FC3 3-56 RC3 3-62 CT3 3-68 CT4 3-69 FC5 3-58 RC5 3-63 CT5 3-75 MG1 3-76 MS1 3-78 MA1 3-80 MUW 3-82 MG2 3-83 MS2 3-85 MS3 3-86 MA3 3-88 MU3 3-90 MA4 3-93 MU4 3-95 MA5 3-97 MU6 3-99 MU7 3-101 MU8 3-103 CA1 3-105 CU1 3-107 C A 2 3 -10 9 _ _ _ _-1 1____ _ _ ____ __ ___ CU3 3-111 CU4 3-113 CA5 3-115 CU5 3-118 CG6 3-120 CS6 3-124 CA6 3-127 CU6 3-129 HG1 3-131 HS1 3-133 HA1 3-135 HU1 3-138 HS2 3-140 HA2 3-142 HU3 3-143 HU4 3-147 HA5 3-148 HU6 3-151 HG7 3-154 HS7 3-155 HA7 3-156 HU7 3-157 Month 20XX TMI 3-31 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RGI Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRem TEDE or 5000 mRem thyroid CDE.Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR 2. Dose assessment Using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 1000 mRem TEDE OR b. > 5000 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >1000 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.
Month 20XX TMI 3-32 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG1 (cont)Emergency Action Level (EAL) (cont): Table R1 Effluent Monitor Thresholds Effluent Monitor General Emergency RM-G-25 (Cond Offgas) 9.53 E+06 mR/hr RM-A-8GH (Station Vent) 3.09 E+05 cpm RM-G-24 (RB Purge) 5.55 E+05 mRlhr RM-A-14 (ESF Vent) 6.66 E+02 uCi/cc Basis: This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases.
Releases of this magnitude will require implementation of protective actions for the public.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.
The TEDE dose is set at the EPA PAG of 1000 mRem while the 5000 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Basis Reference(s):
- 1. NEI 99-01 Rev 6, AG1 2. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values, Three Mile Island 3. EP-AA-112-500 Emergency Environmental Monitoring
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDE or 500 mRem thyroid CDE.Operating Mode Applicability:
1, 2,3, 4,5,6, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to the environment is established.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15 minutes.OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 100 mRem TEDE OR b. > 500 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >100 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.
Month 20XX TMI 3-34 EP-AA-1009 (Revision XX)
N r Three MileIs land Station Annex FvAinn NuleIAar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 (cont)Emergency Action Level (EAL) (cont): Table RI Effluent Monitor Thresholds Effluent Monitor Site Area Emergency RM-G-25 (Cond Offgas) 9.53 E+05 mR/hr RM-A-8GH (Station Vent) 3.09 E+04 cpm RM-G-24 (RB Purge) 5.55 E+04 mR/hr RM-A-14 (ESF Vent) 6.66 E+01 uCi/cc Basis: This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).It includes both monitored and un-monitored releases.
Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.
The TEDE dose is set at 10% of the EPA PAG of 1000 mRem while the 500 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Escalation of the emergency classification level would be via IC RG1.Basis Reference(s):
- 1. NEI 99-01 Rev 6, AS1 2. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values, Three Mile Island 3. EP-AA-1 12-500 Emergency Environmental Monitoring
- 6. EP-AA-1 10-201 On Shift Dose Assessment Month 20XX TMI 3-35 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 Initiating Condition:
Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRem TEDE or 50 mRem thyroid CDE.Operating Mode Applicability:
1,2, 3, 4, 5, 6, D Emergency Action Level (EAL): Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 10 mRem TEDE OR b. > 50 mRem CDE Thyroid OR 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary a. 10 mRem TEDE for 60 minutes of exposure OR b. 50 mRem CDE Thyroid for 60 minutes of exposure OR Month 20XX TMI 3-36 EP-AA-1009 (Revision XX)
Thran Win hmhanrl -Qfnfien Annoy I:vnlrn KI"t-Inmr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)Emergency Action Level (EAL) (cont): 4. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.
Table R1 Effluent Monitor Thresholds Effluent Monitor Alert RM-G-25 (Cond Offgas) 9.53 E+04 mR/hr RM-A-8GH (Station Vent) 3.09 E+03 cpm RM-G-24 (RB Purge) 5.55 E+03 mR/hr RM-A-14 (ESF Vent) 6.66 E+00 uCi/cc Basis: This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases.
Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.
The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while the 50 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Escalation of the emergency classification level would be via IC RS1.Month 20XX TMI 3-37 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, AA1 2. OP 1101-2.1 Radiation Monitoring System Setpoints 3. FSAR Section 11.4 Radiation Monitoring System 4. OP-TM-MAP-CO101, Radiation Level HI 5. EP-EAL-0609, Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values, Three Mile Island 6. EP-EAL-0616, Revision 0, Three Mile Island Criteria for Choosing Radiological Liquid Effluent EAL Threshold Values 7. EP-EAL-0622, Revision 0, Three Mile Island Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values for Waste Gas Decay Tanks Month 20XX TMI 3-38 EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU1 Initiating Condition:
Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.Operating Mode Applicability:
1,2, 3, 4, 5, 6, D Emergency Action Level (EAL): Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.1. Reading on ANY of the following effluent monitors > 2 times alarm setpoint established by a current radioactive release discharge permit for > 60 minutes." RM-L-6, Radwaste Discharge" RM-L-12, IWTS / IWFS Discharge" RM-A-7, Waste Gas Decay Tank Discharge" Discharge Permit specified monitor OR 2. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 60 minutes.OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.Month 20XX TMI 3-39 EP-AA-1009 (Revision XX)
r Three Mile~ Island Staition Annex ExalInn NuclerIAr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUI (cont)Emergency Action Level (EAL) (cont): Table R1 Effluent Monitor Thresholds Effluent Monitor Unusual Evet RM-G-25 (Cond Offgas) 1.09 E+03 mR/hr RM-A-8GH (Station Vent) 7.03 E+01 cpm RM-G-24 (RB Purge) 6.34 E+01 mR/hr RM-A-14 (ESF Vent) 7.60 E-02 uCi/cc Basis: This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release).
It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment.
Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases.
The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.
Releases should not be prorated or averaged.
For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.EAL #1 Basis This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).The effluent monitors listed are those normally used for planned discharges.
If a discharge is performed using a different flowpath or effluent monitor other than those listed (e.g., a portable or temporary effluent monitor), then the declaration criteria will be based on the monitor specified in the Discharge Permit.EAL #2 Basis This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous effluent pathways.Month 20XX TMI 3-40 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUl (cont)Basis (cont): EAL #3 Basis This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Escalation of the emergency classification level would be via IC RAI.Basis Reference(s):
- 1. NEI 99-01 Rev 6, AU1 2. OP 1101-2.1 Radiation Monitoring System Setpoints 3. FSAR Section 11.4 Radiation Monitoring System 4. Offsite Dose Calculation (ODCM)5. OP-TM-MAP-CO101, Radiation Level HI 6. EP-EAL-0609 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values, Three Mile Island Month 20XX TMI 3-41 EP-AA-1009 (Revision XX)
Three Mile kIslnd Station Annexv ExaInn Miiu-lpagr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 Initiating Condition:
Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R2 Radiation Monitor reading >1000 mRem/hr Table R2 Radiation Monitors RMS Area Monitored Mode RM-G-9 FHB Bridge Rad Monitor ALL RM-G-6 RB Auxiliary Bridge Rad Monitor 5, 6 RM-G-7 RB Main Bridge Rad Monitor 5, 6 Basis: REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly.
These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment.
As such, they represent an actual or potential substantial degradation of the level of safety of the plant.Month 20XX TMI 3-42 EP-AA-1009 (Revision XX)
Thran Milo lalnnrl Qfnfinn Annoy IPvln~n Thr~a MiI~ I@6nv4 ~t2*inn Ann~v Fvalnn Nuu-I~~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 (cont)Basis (cont): EAL #1 Basis: This EAL escalates from RU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters.
Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.
While an area radiation monitor could detect a rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered.
To the degree possible, readings should be considered in combination with other available indications of inventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.EAL #2 Basis: This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly.
A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).
Escalation of the emergency would be based on either Recognition Category R or C ICs.Basis Reference(s):
- 1. NEI 99-01 Rev 6, AA2 2. Operating Procedure OP-TM-MAP-C0105 RCS Draindown LVL HI/LO 3. OP-TM-MAP-CO101, Radiation Level HI 4. UFSAR, Section 14.2.2.1 -"Fuel Handling Accident" 5 Technical Specification 3.8.11 (Reactor Cavity Level)6. Operating Procedure OP 1101-2.1 Radiation Monitoring System Setpoints Month 20XX TMI 3-43 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 Initiating Condition:
UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:
1,2, 3, 4, 5, 6, D Emergency Action Level (EAL): 1. a. UNPLANNED water level drop in the REFUELING PATHWAY.AND b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R2.Table R2 Radiation Monitors RMS Area Monitored Mode RM-G-9 FHB Bridge Rad Monitor ALL RM-G-6 RB Auxiliary Bridge Rad Monitor 5,6 RM-G-7 RB Main Bridge Rad Monitor 5, 6 Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.This IC addresses a loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.A water level loss will be primarily determined by indications from available level instrumentation.
Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available) or from any other temporarily installed monitoring instrumentation.
A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations.
Month 20XX TMI 3-44 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 (cont)Basis (cont): The effects of planned evolutions should be considered.
For example, a refueling bridge area radiation monitor reading may rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly.
Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RA2.Basis Reference(s):
- 1. NEI 99-01 Rev 6, AU2 2. UFSAR, Section 14.2.2.1 -"Fuel Handling Accident" 3. OP-TM-MAP-CO105 RCS Draindown 4. OP 1202-12, Excessive Radiation Levels 5. OP 1101-2.1 Radiation Monitoring System Setpoints 6. Technical Specification 3.8.11 (Reactor Cavity Level)Month 20XX TMI 3-45 EP-AA-1009 (Revision XX)
Three Mile kIslnd Stamtion Annex FYAlnn Mana-I0nr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 Initiating Condition:
Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): Note:* If the equipment in the room or area listed in Table R4 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.
- 1. Dose rate > 15 mR/hr in ANY of the areas contained in Table R3: Table R3 Areas Requiring Continuous Occupancy* Main Control Room* Central Alarm Station -(by survey)OR 2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the following Table R4 plant rooms or areas: Table R4 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*
Modes 4, 5, and 6 Intermediate Building*
Modes 4, 5, and 6 Auxiliary Building*
Modes 4, 5, and 6 Fuel Handling Building*
Modes 4, 5, and 6*Areas required to establish shutdown cooling Month 20XX TMI 3-46 EP-AA-1009 (Revision XX) r Three MileIs land Stamtion Annex Fyelnn NuclaInr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 (cont)Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures.
As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine if another IC may be applicable.
Table R4 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown.
This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the elevated radiation levels preclude the ability to place shutdown cooling in service. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding beyond that required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation rise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4." The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
Month 20XX TMI 3-47 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 (cont)Basis (cont):* The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.Basis Reference(s):
- 1. NEI 99-01 Rev 6, AA3 2. FSAR Section 5.01 Class I Structures, Components, and Systems 3. OP-TM-MAP-CO101, Radiation Level HI Month 20XX TMI 3-48 EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU3 Initiating Condition:
Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): 1. Letdown Monitor RM-L-1 alert alarm (high or low channel).OR 2. Sample analysis indicates that: a. Dose Equivalent 1-131 specific coolant activity > 60.0 uCi/gm.OR b. Dose Equivalent XE-133 specific coolant activity>
797.0 uCi/gm.Basis: This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications.
This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel clad degradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity.
An Unusual Event is only warranted when actual fuel clad damage is the cause of the elevated coolant sample activity (as determined by laboratory confirmation).
Fuel clad damage should be assumed to be the cause of elevated Reactor Coolant activity unless another cause is known.Escalation of the emergency classification level would be via ICs FAl or the Recognition Category R ICs.Basis Reference(s):
- 1. NEI 99-01 Rev 6, SU3 2. Operating Procedure 1101-2.1 Radiation Monitoring System Setpoints 3. FSAR Section 11.4.4, Liquid Monitoring Subsystem 4. OP-TM-MAP-CO101, Radiation Level HI 5. Technical Specifications 3.1.4, Reactor Coolant System Activity Month 20XX TMI 3-49 EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FG1 Initiating Condition:
Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers.At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FS1 Initiating Condition:
Loss or Potential Loss of ANY two barriers.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):
- 1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX TMI 3-51 EP-AA-1009 (Revision XX)
Nur.legr Three Mile Island Sftation Annex FveInn Nucler~I TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FA1 Initiating Condition:
ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Alert classification level, Fuel Cladding and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability.
Note that the loss or potential loss of Containment barrier in combination with loss or potential loss of either Fuel Cladding or RCS barrier results in declaration of a Site Area Emergency under EAL FSI.Basis Reference(s):
- 1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX TMI 3-52 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1 Initiating Condition:
RCS or SG Tube Leakage Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSS 1. RCITS hot leg instruments indicate 0 inches after lowering trend.AND 2. In-core thermocouples are unavailable.
AND 3. ALL RCP's are secured.Basis: There is no Loss threshold associated with RCS or SG Tube Leakage.Potential Loss Threshold
- 1 Basis: This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.Basis Reference(s):
- 3. OP-TM-EOP-008, RCS Superheated
- 4. OP-TM-EOP-010, Emergency Procedure Rules Guides and Graphs Month 20XX TMI 3-53 EP-AA-1009 (Revision XX)
FxpInn Three Mile kIsland Staition Annex FvAlnn Nucler~I TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 Initiating Condition:
Inadequate Heat Removal Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
LOSS 1. Tclad > 1400°F POTENTIAL LOSS 2. > 25°F Superheat OR 3. HPI-PORV Cooling in effect.Basis: Loss Threshold
- 1 Basis This reading indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.Potential Loss Threshold
- 2 Basis This reading indicates temperatures within the core are sufficient to allow the onset of heat-induced cladding damage.Potential Loss Threshold
- 3 Basis This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.
Meeting this threshold results in a Site Area Emergency because this threshold is identical to RCS Barrier RC2 Potential Loss threshold; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and raise RCS pressure to the point where mass will be lost from the system.Month 20XX TMI 3-54 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, Table 9-F-3 2. OS-24 Attachment D 3. OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer 4. OP-TM-EOP-008, RCS Superheated
- 5. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs 6. OS-24, Conduct of Operations during Abnormal and Emergency Events Month 20XX TMI 3-55 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC3 Initiating Condition:
Containment Radiation
/ RCS Activity Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
LOSS 1. Containment radiation monitor (RM-G-22 or RM-G-23) reading > 1.95E+03 R/hr.OR 2. Coolant activity > 300uCi/gm Dose Equivalent 1-131 Basis: Loss Threshold
- 1 Basis: The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 300pCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCS Barrier RC3 Loss Threshold since it indicates a loss of both the Fuel Clad Barrier and the RCS Barrier. Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.
Loss Threshold
- 2 Basis: This threshold indicates that RCS radioactivity concentration is greater than 300 pCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete.
Nonetheless, a sample-related threshold is included as a backup to other indications There is no Fuel Clad Barrier Potential Loss threshold associated with RCS Activity /Containment Radiation.
Month 20XX TMI 3-56 EP-AA-1009 (Revision XX)
Kh Throp Milo~ 1--Ind Station Annex Pvalnn Nmuuulanr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC3 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, Table 9-F-3 2. OP-TM-MAP-CO101, Radiation Level HI 3. FSAR Section 11.4.4, Liquid Monitoring
System Description
- 4. Calculation C3640-98-034, Prediction of the Response of RM-G-6 and 7 to Fuel Damage 5. Core Damage Assessment Methodology (CDAM)Month 20XX TMI 3-57 EP-AA-1 009 (Revision XX)
Pvalnn kl"Aanr Three Mila kIslnd Rtnatinn AnnqxF~n .1 vgi TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC5 Initiating Condition:
Emergency Director Judgment.Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
LOSS 1. Any condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.POTENTIAL LOSS 2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.Basis: Loss Threshold
- 1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold
- 2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.
Basis Reference(s):
- 1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX TMI 3-58 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC1 Initiating Condition:
RCS or SG Tube Leakage Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
LOSS 1. Automatic or manual ESAS actuation is required by EITHER of the following:
- a. UNISOLABLE RCS leakage OR b. Steam Generator tube RUPTURE.POTENTIAL LOSS 2. UNISOLABLE RCS leakage > 150gpm.OR 3. HPI-PORV Cooling in effect.OR 4. a. RCS Pressure > 2450 psig.AND b. RCS Pressure not lowering.Basis: UNISOLABLE:
An open or breached system line that cannot be isolated, remotely or locally.RUPTURE(D):
The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.
FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.
Loss Threshold
- 1 Basis This threshold is based on an UNISOLABLE RCS leak of sufficient size to require an automatic or manual actuation of the Emergency Core Cooling System (ECCS). This condition clearly represents a loss of the RCS Barrier.Month 20XX TMI 3-59 EP-AA-1009 (Revision XX)
Three Milo Islandl Station Annex Fvalnn INJ~rlanr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RCl (cont)Basis (cont): This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location -inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.
A steam generator with primary-to-secondary leakage of sufficient magnitude to require a safety injection is considered to be RUPTURED.
If a RUPTURED steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier CT1 Loss threshold will also be met.Potential Loss Threshold
- 2 Basis This threshold is based on an UNISOLABLE RCS leak that results in the inability to maintain pressurizer level within specified limits by operation of a normally used charging (makeup) pump, but an ECCS (SI) actuation has not occurred.
The threshold is met when an operating procedure, or operating crew supervision, directs that a standby charging (makeup) pump be placed in service to restore and maintain pressurizer level.This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location -inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.
If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier CT1 Loss Threshold#1 will also be met.Potential Loss Threshold
- 3 Basis This condition indicates an extreme challenge to the integrity of the RCS pressure boundary due to pressurized thermal shock -a transient that causes rapid RCS cooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).
Basis Reference(s):
- 1. NEI 99-01 Rev 6, Table 9-F-3 2. OP-TM-EOP-010 Emergency Procedure Rules, Guides And Graphs 3. OP-TM-EOP-002 Loss of 25°F Subcooled Margin 4. OP-TM-MAP-D031, MU Flow HI 5. OP-TM-EOP-005, OTSG Tube Leakage Month 20XX TMI 3-60 EP-AA-1009 (Revision XX)
Thra~ MiIA% liennr -4fnfiv~n Anng~v P~v-ltln Ik1, ,-Imr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 Initiating Condition:
Inadequate Heat Removal Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSS HPI-PORV Cooling in effect.Basis: There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold Basis HPI-PORV Cooling in effect indicates a Lack of Primary to Secondary Heat Transfer capability.
This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.
Meeting this threshold results in a Site Area Emergency because this threshold is identical to Fuel Clad Barrier FC2 Potential Loss Threshold
- 3; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and raise RCS pressure to the point where mass will be lost from the system.Basis Reference(s):
- 1. NEI 99-01 Rev 6, Table 9-F-3 2. OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer Month 20XX TMI 3-61 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3 Initiating Condition:
Containment Radiation
/ RCS Activity Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
LOSS Containment radiation monitor (RM-G-22 or RM-G-23) reading > 25 R/hr.Basis: Loss Threshold Basis The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC3 Loss threshold
- 1 since it indicates a loss of the RCS Barrier only.There is no RCS Potential Loss threshold associated with RCS Activity / Containment Radiation.
Basis Reference(s):
- 1. NEI 99-01 Rev 6, Table 9-F-3 2. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor Reading Indicative of Loss of RCS Barrier Month 20XX TMI 3-62 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC5 Initiating Condition:
Emergency Director Judgment.Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
LOSS 1. Any condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.POTENTIAL LOSS 2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Basis: Loss Threshold
- 1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is lost.Potential Loss Threshold
- 2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored..Basis Reference(s):
Thraga Milo kinnei -Qfnfie-.n Annoy P:valnn Klir-lnr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT1 Initiating Condition:
RCS or SG Tube Leakage Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
LOSS 1. SG tube leakage > 150gpm AND 2. SG is FAULTED outside of containment.
Basis: FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.
RUPTURE(D):
The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.
Loss Threshold Basis This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment.
The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier RC1 Potential Loss Threshold 2 and Loss Threshold 1.b, respectively.
This condition represents a bypass of the containment barrier.FAULTED is a defined term within the NEI 99-01 methodology; this determination is not necessarily dependent upon entry into, or diagnostic steps within, an EOP. For example, if the pressure in a steam generator is decreasing uncontrollably
[part of the FAULTED definition]
and the faulted steam generator isolation procedure is not entered because EOP user rules are dictating implementation of another procedure to address a higher priority condition, the steam generator is still considered FAULTED for emergency classification purposes.The FAULTED criterion establishes an appropriate lower bound on the size of a steam release that may require an emergency classification.
Steam releases of this size are readily observable with normal Control Room indications.
The lower bound for this aspect of the containment barrier is analogous to the lower bound criteria specified in IC RU3 for the fuel clad barrier (i.e., RCS activity values) and IC MU6 for the RCS barrier (i.e., RCS leak rate values).This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steam generator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant and Month 20XX TMI 3-64 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CTI (cont)Basis (cont): sustained release of radioactive steam to the environment (and are thus similar to a FAULTED condition).
The inability to isolate the steam flow without an adverse effect on plant cooldown meets the intent of a loss of containment.
Steam releases associated with the expected operation of a SG power operated relief valve or safety relief valve do not meet the intent of this threshold.
Such releases may occur intermittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stable condition and prepare to initiate a plant cooldown.
Steam releases associated with the unexpected operation of a valve (e.g., a stuck-open safety valve) meets this threshold.
Following an SG tube leak or rupture, there may be minor radiological releases through a secondary-side system component (e.g., air ejectors, glad seal exhausters, valve packing, etc.). These types of releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.The emergency classification levels resulting from primary-to-secondary leakage, with or without a steam release from the FAULTED SG, are summarized below.Affected SG is FAULTED Outside of Containment?
Yes No Primary to Secondary Leak Rate Less than or equal to 25 gpm Greater than 25 gpm Greater than 150 gpm.The capacity of one makeup pump in the normal charging mode is exceeded (RCS Barrier Potential Loss)Requires an automatic or manual ESAS actuation (RCS Barrier Loss)No classification Unusual Event per MU6 Site Area Emergency per FS1 Site Area Emergency per FS1 No classification Unusual Event per MU6 Alert per FA1 Alert per FAI There is no Potential Loss threshold associated with RCS or SG Tube Leakage.Month 20XX TMI 3-65 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT1 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, Table 9-F-3 2. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs 3. OP-TM-EOP-005, OTSG Tube Leakage 4. OP-TM-EOP-001, Reactor Trip Month 20XX TMI 3-66 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear Thre Mil Isand taton AnexExelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2 Initiating Condition:
Inadequate Heat Removal Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSS 1. Tclad > 1800°F.AND 2. EOP Restoration procedures not effective in < 15 minutes.Basis: IMMINENT:
The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss Threshold Basis This condition represents an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. For this condition to occur, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. If implementation of a procedure(s) to restore adequate core cooling is not effective (successful) within 15 minutes, it is assumed that the event trajectory will likely lead to core melting and a subsequent challenge of the Containment Barrier.The restoration procedure is considered "effective" if core exit thermocouple readings are decreasing and/or if reactor vessel level is increasing.
Whether or not the procedure(s) will be effective should be apparent within 15 minutes. The Emergency Director should escalate the emergency classification level as soon as it is determined that the procedure(s) will not be effective.
Severe accident analyses (e.g., NUREG-1 150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damage scenarios, and that the likelihood of containment failure is very small in these events.Given this, it is appropriate to provide 15 minutes beyond the required entry point to determine if procedural actions can reverse the core melt sequence.Basis Reference(s):
- 3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs 4. OP-TM-EOP-006, LOCA Cooldown Month 20XX TMI 3-67 EP-AA-1009 (Revision XX)
Three MileIs land Staition Annex Fvnlnn NmirlIg:ar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 Initiating Condition:
Containment Radiation
/ RCS Activity Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSS Containment radiation monitor (RM-G-22 or RM-G-23) reading > 4.40E+03 R/hr.Basis: There is no Loss threshold associated with RCS Activity / Containment Radiation.
Potential Loss Threshold Basis The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that 20% of the fuel cladding has failed.This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds.
NUREG-1 228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 20%in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency.
Basis Reference(s):
- 1. NEI 99-01 Rev 6, Table 9-F-3 2. Core Damage Assessment Methodology (CDAM)Month 20XX TMI 3-68 EP-AA-1 009 (Revision XX)
Throa RAila kinnd Atntinn Annoy IP=Ylnn NMtlor, ~Thr~ MiI~ IQI2nrI ~t~*inn Ann~iw Fv~Ir~n NmmvIc~ar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 Initiating Condition:
Containment Integrity or Bypass Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
LOSS 1. Containment isolation is required and EITHER of the following:
- a. UNPLANNED lowering in containment pressure or rise in radiation monitor readings outside of containment in the Emergency Directors judgment indicate a loss of containment integrity.
OR b. UNISOLABLE pathway from containment to the environment exists.OR 2. Indication of RCS leakage outside of containment POTENTIAL LOSS 3. Reactor Building Pressure > 55 psig and rising.OR 4. Hydrogen Concentration in Containment
> 4%.OR 5. a. Reactor Building pressure > 30 psig AND b. Reactor Building Emergency cooling is less than ANY one of the following conditions:
SPRAY COOLERS 2 0 0 3 1 1 Basis: FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.
UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.Month 20XX TMI 3-69 EP-AA-1 009 (Revision XX)
Thrao Milo lainnd _Qfnfirn Annoy I~v-g- In n Thrc&c MiIg~ Ie6nd ~t2tinn Anng~w Fv~inn tJm.pIa~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)Basis (cont): UNISOLABLE:
An open or breached system line that cannot be isolated, remotely or locally.Loss Threshold
- 1 Basis These thresholds address a situation where containment isolation is required and one of two conditions exists as discussed below. Users are reminded that there may be accident and release conditions that simultaneously meet both loss thresholds 1.a and 1.b.l.a -Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or sometimes referred to as design leakage).
Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop in containment pressure.
Recognizing the inherent difficulties in determining a containment leak rate during accident conditions, it is expected that the Emergency Director will assess this threshold using judgment, and with due consideration given to current plant conditions, and available operational and radiological data (e.g., containment pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.).Refer to the middle piping run of Figure 3-F-1. Two simplified examples are provided.One is leakage from a penetration and the other is leakage from an in-service system valve. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure.Another example would be a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment.
In this case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment.
Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components.
These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.1.b -Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment.
As used here, the term "environment" includes the atmosphere of a room or area, outside the containment, that may, in turn, communicate with the outside-the-plant atmosphere (e.g., through discharge of a ventilation system or atmospheric leakage).
Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure.Month 20XX TMI 3-70 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)Basis (cont): Refer to the top piping run of Figure 3-F-1. In this simplified example, the inboard and outboard isolation valves remained open after a containment isolation was required (i.e., containment isolation was not successful).
There is now an UNISOLABLE pathway from the containment to the environment.
The existence of a filter is not considered in the threshold assessment.
Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.Leakage between two interfacing liquid systems, by itself, does not meet this threshold.
Refer to the bottom piping run of Figure 3-F-1. In this simplified example, leakage in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building.
The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met.If the pump or system piping developed a leak that allowed steam/water to enter the Auxiliary Building, then loss threshold 2 would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the four monitors depicted in the figure and cause threshold 1.a to be met as well.Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design)containment leakage through various penetrations or system components.
Minor releases may also occur if a containment isolation valve(s) fails to close but the containment atmosphere escapes to a closed system. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Barrier CT1 Loss threshold.
Loss Threshold
- 2 Basis Containment sump, temperature, pressure and/or radiation levels will rise if reactor coolant mass is leaking into the containment.
If these parameters have not increased, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence).
Raises in sump, temperature, pressure, flow and/or radiation level readings outside of the containment may indicate that the RCS mass is being lost outside of containment.
Unexpected elevated readings and alarms on radiation monitors with detectors outside containment should be corroborated with other available indications to confirm that the source is a loss of RCS mass outside of containment.
If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not rise significantly; however, other unexpected changes in sump levels, area temperatures or pressures, flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of the containment.
Month 20XX TMI 3-71 EP-AA-1009 (Revision XX)
Throp Mila IslandI Station Annex PvaInn Niirlanr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)Basis (cont): Refer to the middle piping run of Figure 3-F-1. In this simplified example, a leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building.Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause loss threshold I.a to be met as well. To ensure proper escalation of the emergency classification, the RCS leakage outside of containment must be related to the mass loss that is causing the RCS Barrier RC1 Loss Threshold l.a and/or Potential Loss threshold 2.a to be met.Potential Loss Threshold
- 3 Basis If containment pressure exceeds the design pressure, there exists a potential to lose the Containment Barrier. To reach this level, there must be an inadequate core cooling condition for an extended period of time; therefore, the RCS and Fuel Clad barriers would already be lost. Thus, this threshold is a discriminator between a Site Area Emergency and General Emergency since there is now a potential to lose the third barrier.Potential Loss Threshold
- 4 Basis The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity.
It therefore represents a potential loss of the Containment Barrier.Potential Loss Threshold
- 5 Basis This threshold describes a condition where containment pressure is greater than the set point at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible.
This threshold represents a potential loss of containment in that containment heat removal/depressurization systems (e.g., containment sprays, ice condenser fans, etc., but not including containment venting strategies) are either lost or performing in a degraded manner.Month 20XX TMI 3-72 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, Table 9-F-3 2. FSAR Section 6.6 Reactor Building Pressure-Time Response 3. Technical Specifications 3.5.3, Engineered Safeguards Protection System Actuation Setpoints 4. FSAR Section 6.3.3, Actuation 5. FSAR Section 6.5.3, Hydrogen Generation
- 6. OP-TM-EOP-006, LOCA Cooldown 7. 1302-5.25 Reactor Building Sump Level 8. FSAR Section 5.2 Reactor Building 9. FSAR Section 9.2, Chemical Addition and Sampling System 10. OP-TM-EOP-002, Loss of 25 0 F Subcooling Margin 11. OP-TM-EOP-006, LOCA Cooldown 12. OP-TM-EOP-010, Emergency Procedure Rules, Guides and Graphs 13. OP-TM-MAP-D0301, High Make-up Flow Month 20XX TMI 3-73 EP-AA-1009 (Revision XX)
Throciaf lalanrd .tnfinn Annoy a EwarIn& ^Im~RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Pinni irn 24.1:.l" PWR Ce.nntninmont Infonrift nr QunMae Fvomnl,0 W W I* 1.b-- Airborne release from *pathway Vent Cooling Month 20XX TMI 3-74 EP-AA-1009 (Revision XX)
Fxelnn Three Mile Island Station Annex FeInIn NuIcIeIar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT5 Initiating Condition:
Emergency Director Judgment.Operating Mode Applicability:
1,2,3,4 Fission Product Barrier (FPB) Threshold:
LOSS 1. Any condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.POTENTIAL LOSS 2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Basis: Loss Threshold
- 1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is lost.Potential Loss Threshold
- 2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.
Basis Reference(s):
- 1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX TMI 3-75 EP-AA-1009 (Revision XX)
r Three MileIsa ind Station Annex Fxelnn N~uclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 Initiating Condition:
Prolonged loss of all offsite and all onsite AC power to emergency busses.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to Emergency 4KV buses.AND 2. Failure of EG-Y-1A, EG-Y-1 B Emergency Diesel Generators and EG-Y-4 SBO Diesel Generator to supply power to Emergency 4KV buses.AND 3. EITHER of the following:
- a. Restoration of at least one Emergency 4KV bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.OR b. > 25°F superheat Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC addresses a prolonged loss of all power sources to AC emergency buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A prolonged loss of these buses will lead to a loss of any fission product barriers.
In addition, fission product barrier monitoring capabilities may be degraded under these conditions.
The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FG1. This will allow additional time for implementation of offsite protective actions.Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and Month 20XX TMI 3-76 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 (cont).Basis (cont): event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation.
Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.Basis Reference(s):
- 1. NEI 99-01 Rev 6, SG1 2. OP-TM-EOP-010 Emergency Procedure Rules, Guides And Graphs 3. FSAR Section 8.2.2 Unit Distribution System 4. FSAR Section 8.2.3 Sources of Auxiliary Power 5. FSAR Section 8.5 Station Blackout 6. Technical Specification Section 3.7, Unit Electric Power System 7. 1107-1 Normal Electrical System 8. 11 07-2A Emergency Electrical
-4KV and 480 Volt 9. OP-TM-AOP-020 Loss Of Station Power 10. 1107-3 Diesel Generator 11. 1107-9 SBO Diesel Generator 12. OP-TM-EOP-008 RCS Superheated
- 13. OS-24, Conduct of. Operation during Abnormal and Emergency Events Month 20XX TMI 3-77 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC Power to Emergency 4KV buses.AND 2. Failure of EG-Y-1A, EG-Y-1 B Emergency Diesel Generators and EG-Y-4 SBO Diesel Generator to supply power to Emergency 4KV buses.AND 3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutes from the time of loss of both offsite and onsite AC power Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. In addition, fission product barrier monitoring capabilities may be degraded under these conditions.
This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via ICs RG1, FG1, MG1, or MG2.Month 20XX TMI 3-78 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, SS1 2. FSAR Section 8.2.3, Sources of Auxiliary Power 3. Technical Specification Section 3.7, Unit Electric Power System 4. 1107-1 Normal Electrical System 5. 11 07-2A Emergency Electrical
-4KV and 480 Volt 6. OP-TM-AOP-020 Loss Of Station Power 7. 1107-3 Diesel Generator 8. 1107-9 SBO Diesel Generator 9. FSAR Section 8.2.2, Unit Distribution System 10. FSAR Section 8.5, Station Blackout Month 20XX TMI 3-79 EP-AA-1009 (Revision XX)
F=Yplnn Nw-lonr Three MileIsl~andl Station AnnexF~n Ni~aa TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MAI Initiating Condition:
Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. AC power capability to Emergency 4KV buses reduced to only one of the following power sources for > 15 minutes.* Auxiliary Transformer 1A* Auxiliary Transformer 1 B* Emergency Diesel Generator EG-Y-1A* Emergency Diesel Generator EG-Y-1 B* SBO Diesel Generator EG-Y-4 AND 2. Any additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.
This IC provides an escalation path from IC MUl.An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.* A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).
Month 20XX TMI 3-80 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MAI (cont)Basis (cont): " A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.
- A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.Escalation of the emergency classification level would be via IC MS1.Basis Reference(s):
- 1. NEI 99-01 Rev 6, SA1 2. FSAR Section 8.2.3, Sources of Auxiliary Power 3. FSAR Section 8.5, Station Blackout 4. Technical Specification Section 3.7, Unit Electric Power System 5. 1107-1 Normal Electrical System 6. 11 07-2A Emergency Electrical
-4KV and 480 Volt 7. OP-TM-AOP-020 Loss Of Station Power 8. 1107-3 Diesel Generator 9. .1107-9 SBO Diesel Generator 10. FSAR Section 8.2.2, Unit Distribution System Month 20XX TMI 3-81 EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU1 Initiating Condition:
Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): Note: e The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to Emergency 4KV busses for > 15 minutes.Basis: This IC addresses a prolonged loss of offsite power. The loss of offsite power sources renders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification purposes, "capability" means that an offsite AC power source(s) is available to the emergency buses, whether or not the buses are powered from it.The emergency busses of the affected unit can be powered from the unaffected unit through the crosstie breakers.
Unit crosstie is considered an adequate source of offsite power when evaluating this EAL.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.Escalation of the emergency classification level would be via IC MAl.Basis Reference(s):
- 1. NEI 99-01 Rev 6, SU1 2. FSAR Section 8.2.3, Sources of Auxiliary Power 3. Technical Specification Section 3.7, Unit Electric Power System 4. 1107-1 Normal Electrical System 5. 11 07-2A Emergency Electrical
-4KV and 480 Volt 6. OP-TM-AOP-020 Loss Of Station Power 7. 1107-3 Diesel Generator 8. 1107-9 SBO Diesel Generator 9. FSAR Section 8.2.2, Unit Distribution System Month 20XX TMI 13-82 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 Initiating Condition:
Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to Emergency 4KV buses.AND 2. Failure of EG-Y-1A, EG-Y-1B Emergency Diesel Generators and EG-Y-4 SBO Diesel Generator to supply power to Emergency 4KV buses.AND 3. Voltage is < 105 VDC on 125 VDC Distribution System 1A and lB.AND 4. ALL AC and Vital DC power sources have been lost for >15 minutes.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A loss of Vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both AC and DC power will lead to multiple challenges to fission product barriers.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. The 15-minute emergency declaration clock begins at the point when all EALs are met.Month 20XX TMI 3-83 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, SG8 2. FSAR Section 8.2.2.6, 250/125 VDC System 3. 11 07-2C Vital DC Electrical System 4. OP-TM-AOP-023, A DC System Failure 5. OP-TM-AOP-024, B DC System Failure 6. FSAR Section 8.2.2, Unit Distribution System 7. FSAR Section 8.2.3, Sources of Auxiliary Power 8. Technical Specification Section 3.7, Unit Electric Power System 9. 1107-1 Normal Electrical System 10. 1107-2A Emergency Electrical
-4KV and 480 Volt 11. OP-TM-AOP-020 Loss Of Station Power 12. 1107-3 Diesel Generator 13. 1107-9 SBO Diesel Generator 14. FSAR Section 8.5, Station Blackout Month 20XX TMI 3-84 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS2 Initiating Condition:
Loss of all vital DC power for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on 125 VDC Distribution System 1A and 1B for>15 minutes.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC addresses a loss of Vital DC power which compromises the ability to monitor and control SAFETY SYSTEMS. In modes above Cold Shutdown, this condition involves a major failure of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via ICs RG1, FG1 or MG3.Basis Reference(s):
- 1. NEI 99-01 Rev 6, SS8 2. FSAR Section 8.2.2.6, 250/125 VDC System 3. 1107-2C Vital DC Electrical System 4. OP-TM-AOP-023, A DC System Failure 5. OP-TM-AOP-024, B DC System Failure Month 20XX TMI 3-85 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 Initiating Condition:
Inability to shutdown the reactor causing a challenge to core cooling or RCS heat removal.Operating Mode Applicability:
1,2 Emergency Action Level (EAL): 1. Automatic or Manual Trip did not shutdown the reactor as indicated by Reactor Power > 5%.AND 2. ALL manual actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 5%.AND 3. EITHER of the following conditions exist: a. Tclad > 1400 0 F.OR b. HPI-PORV Cooling in effect.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron injection, are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.
In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs.
This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Escalation of the emergency classification level would be via IC RG1 or FGI.Month 20XX TMI 3-86 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, SS5 2. OP-TM-EOP-004, Lack of Primary-to-Secondary Heat Transfer 3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs 4. OP-TM-EOP-001, Reactor Trip 5. 1102-4 Power Operation 6. OP-TM-641-000-Reactor Protection System (RPS/DSS)Month 20XX TMI 3-87 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 Initiating Condition:
Automatic or manual trip fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:
1,2 Emergency Action Level (EAL): Note:* A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
- 1. Automatic Trip did not shutdown the reactor as indicated by Reactor Power > 5%.AND 2. Manual actions taken at the Console Center are not successful in shutting down the reactor as indicated by Reactor Power > 5%.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the Console Center to shutdown the reactor are also unsuccessful.
This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the Console Center since this event entails a significant failure of the RPS.A manual action at the Console Center is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip. This action does not include manually driving in control rods or implementation of boron injection strategies.
If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the Console Center (e.g., locally opening breakers).
Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the Console Center".The plant response to the failure of an automatic reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough to cause a challenge to the core cooling or RCS heat removal safety functions, the emergency Month 20XX TMI 3-88 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 (cont)Basis (cont): classification level will escalate to a Site Area Emergency via IC MS3. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC MS3 or FS1, an Alert declaration is appropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL are included to ensure a timely emergency declaration.
A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Basis Reference(s):
- 1. NEI 99-01 Rev 6, SA5 2. OP-TM-EOP-004, Lack of Primary-to-Secondary Heat Transfer 3. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs 4. OP-TM-EOP-001, Reactor Trip 5. 1102-4 Power Operation 6. OP-TM-641-000-Reactor Protection System (RPS/DSS)Month 20XX TMI 3-89 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 Initiating Condition:
Automatic or manual trip fails to shutdown the reactor.Operating Mode Applicability:
1,2 Emergency Action Level (EAL): Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
- 1. a. Automatic Trip did not shutdown the reactor as indicated by Reactor Power> 5%.AND b. Subsequent manual action taken at the Console Center is successful in shutting down the reactor.OR 2. a. Manual Trip did not shutdown the reactor as indicated by Reactor Power > 5%.AND b. Subsequent automatic Trip is successful in shutting down the reactor.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the Console Center or an automatic trip is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.EAL #1 Basis Following the failure on an automatic reactor trip, operators will promptly initiate manual actions at the Console Center to shutdown the reactor (e.g., initiate a manual reactor trip). If these manual actions are successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.Month 20XX TMI 3-90 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)Basis (cont): EAL #2 Basis If an initial manual reactor trip is unsuccessful, a concurrent plant condition, may lead to the generation of an automatic reactor trip signal. If a subsequent automatic trip is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.A manual action at the Console Center is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip). This action does not include manually driving in control rods or implementation of boron injection strategies.
Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the Console Center".The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the Console Center are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MA3. Depending upon the plant response, escalation is also possible via IC FAI. Absent the plant conditions needed to meet either IC MA3 or FAI, an Unusual Event declaration is appropriate for this event.A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that creates a real condition that should have included an automatic reactor trip and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated." If the signal generated as a result of plant work does not cause a plant transient but should have generated an RPS trip signal and the trip failure is determined through other means (e.g., assessment of test results), then this IC and the EALs are not applicable and no classification is warranted.
Month 20XX TMI 13-91 EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, SU5 2. OP-TM-EOP-010, Emergency Procedure Rules, Guides And Graphs 3. OP-TM-EOP-001, Reactor Trip 4. 1102-4 Power Operation 5. OP-TM-641-000-Reactor Protection System (RPS/DSS)Month 20XX TMI 3-92 EP-AA-1009 (Revision XX)
Three Mile kIslnd Station Annex FxeInn Nule~I~ar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters" Reactor Power" PZR Level , RCS Pressure" In Core/Core Exit Temperature" Level in at least one OTSG.* OTSG Emergency Feed Water Flow AND b. ANY Table M2 transient in progress.Table M2 Significant Transients" Automatic Turbine Runback >25% thermal reactor power" Electrical Load Rejection
>25% full electrical load" Reactor Trip* ESAS Actuation a Thermal Power oscillations
> 10%Month 20XX TMI 3-93 EP-AA-1009 (Revision XX)
Three Mih- Islamnd Staution Annex Fvninn Niir~icpr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 (cont)Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fission product barrier challenge is reduced. It thus represents a potential substantial degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for any of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s).
For example, the reactor power level cannot be determined from any analog, computer point, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required.
The event would be reported if it significantly impaired the capability to perform emergency assessments.
In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.
This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition.
In addition, if all indication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.
Escalation of the emergency classification level would be via ICs FS1 or IC RSI.Basis Reference(s):
- 1. NEI 99-01 Rev 6, SA2 Month 20XX TMI 3-94 EP-AA-1009 (Revision XX) r Three Mile kIslnd Station Annex FvAinn NucleI~ar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters a Reactor Power* PZR Level* RCS Pressure* In Core/Core Exit Temperature
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. This condition is a precursor to a more significant event and represents a potential degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for any of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s).
For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room. An event involving a loss of plant indications, Month 20XX TMI 3-95 EP-AA-1009 (Revision XX)
PyPinn Mid-lonr Three~ Mile Islmnd Stt~ion Anne~x FAn ~~~TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 (cont)Basis (cont): annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required.
The event would be reported if it significantly impaired the capability to perform emergency assessments.
In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.
This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition.
In addition, if all indication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.
Escalation of the emergency classification level would be via IC MA4.Basis Reference(s):
- 1. NEI 99-01 Rev 6, SU2 Month 20XX TMI 3-96 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear Thre Mil Isand taton AnexExelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA5 Initiating Condition:
Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): 1. The occurrence of ANY of the following hazardous events: " Seismic event (earthquake)" Internal or external flooding event" High winds or tornado strike" FIRE* EXPLOSION" Other events with similar hazard characteristics as determined by the Shift Manager AND 2. EITHER of the following:
- a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.OR b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.Basis: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.EXPLOSION:
A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization.
A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion.
Such events may require a post-event inspection to determine if the attributes of an explosion are present.Month 20XX TMI 3-97 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA5 (cont)Basis (cont): SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis.
The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.
This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL #2.a Basis This EAL addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in operation since indications for it will be readily available.
The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.EAL #2.b Basis This EAL addresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in operation or readily apparent through indications alone, as well as damage to a structure containing SAFETY SYSTEM components.
Operators will make this determination based on the totality of available event and damage report information.
This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC FS1 or RS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.*Basis Reference(s):
- 1. NEI 99-01, Rev 6 SA9 Month 20XX TMI 3-98 EP-AA-1009 (Revision XX)
Three Mile Islandl Station Annexv Fwalfnn NIlanr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU6 Initiating Condition:
RCS leakage for 15 minutes or longer.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage > 10 gpm for > 15 minutes.OR 2. RCS identified leakage >25 gpm for > 15 minutes.OR 3. Leakage from the RCS to a location outside containment
>25 gpm for > 15 minutes.Basis: UNISOLABLE:
An open or breached system line that cannot be isolated, remotely or locally.This IC addresses RCS leakage which may be a precursor to a more significant event.In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.EAL #1 and EAL #2 Basis These EALs are focused on a loss of mass from the RCS due to "unidentified leakage","pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications).
EAL #3 Basis This EAL addresses a RCS mass loss caused by an UNISOLABLE leak through an interfacing system. These EALs thus apply to leakage into the containment, a secondary-side system (e.g., steam generator tube leakage) or a location outside of containment.
The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications.
Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation).
EAL #1 uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage.Month 20XX TMI 3-99 EP-AA-1009 (Revision XX)
ThrAn MiIA kI~nd St~tinn Annn~r Three Mile Island Station Annex Exellon N"d-h-ar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU6 (cont)Basis (cont): The release of mass from the RCS due to the as-designed/expected operation of a relief valve does not warrant an emergency classification.
An emergency classification would be required if a mass loss is caused by a relief valve that is not functioning as designed/expected (e.g., a relief valve sticks open and the line flow cannot be isolated).
The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible.Escalation of the emergency classification level would be via ICs of Recognition Category R or F.Basis Reference(s):
- 1. NEI 99-01 Rev 6, SU4 2. OP-TM-220-251 RCS Leak Rate Determination
- 3. OP-TM-220-252, Primary -To -Secondary Leakrate Determination
- 4. OP-TM-PRFl-0405 RB Sump Level HI 5. UFSAR 6.4.3, Bases of Leakage Estimate 6. UFSAR 6.4.4, Design Basis Leakage 7. OP-TM-AOP-050, Reactor Coolant Leakage 8. Technical Specification 3.1.6, Leakage and Table 4.1-2, Minimum Equipment Test Frequency Month 20XX TMI 3-100 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 Initiating Condition:
Loss of all On-site or Off-site communications capabilities.
Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): 1. Loss of ALL Table M3 Onsite communications capability affecting the ability to perform routine operations.
OR 2. Loss of ALL Table M3 Offsite communication capability affecting the ability to perform offsite notifications.
OR 3. Loss of ALL Table M3 NRC communication capability affecting the ability to perform NRC notifications.
Table M3 Communications Caoabilitv System Onsite Offsite NRC Radios X Plant page X Plant Telephone System X Sound Powered Phones X Commercial Telephones X X X NARS X ENS X X HPN X X Satellite phones X X Basis: This IC addresses a significant loss of on-site, offsite, or NRC communications capabilities.
While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).Month 20XX TMI 3-101 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 (cont)Basis (cont): EAL #1 Basis Addresses a total loss of the communications methods used in support of routine plant operations.
EAL #2 Basis Addresses a total loss of the communications methods used to notify all OROs of an emergency declaration.
The OROs referred to here are listed in procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form.EAL #3 Basis Addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.
Basis Reference(s):
- 1. NEI 99-01 Rev 6, SU6 2. 1105-12 Communications System 3. FSAR Section 7.4.4, Communication Month 20XX TMI 3-102 EP-AA-1009 (Revision XX)
Thrain Milo laitanri -Q+mfinn Annav Izv--Ir^n kh,,-li-,r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU8 Initiating Condition:
Failure to isolate containment or loss of containment pressure control.Operating Mode Applicability:
1,2,3,4 Emergency Action Level (EAL): 1. a. Failure of containment to isolate when required by an actuation signal.AND b. ANY required penetration remains open > 15 minutes of the actuation signal.OR 2. a. Reactor Building pressure > 30 psig AND b. Reactor Building Emergency cooling is less than ANY one of the following conditions for > 15 minutes: SPRAY COOLERS 2 0 0 3 1 1 Basis: This IC addresses a failure of any containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems. Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant.EAL #1 Basis The containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure);
a failure resulting from testing or maintenance does not warrant classification.
The determination of containment and penetration status -isolated or not isolated -should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute criterion is included to allow operators time to manually isolate the required penetrations, if possible.Month 20XX TMI 3-103 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex mmlvmvl m i ThreeMileIslan Staion Anex xelnn NuclerIzr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU8 (cont)Basis (cont): EAL #2 Basis Addresses a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible.
The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g., containment sprays or ice condenser fans) are either lost or performing in a degraded manner.This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers.Basis Reference(s):
- 1. NEI 99-01 Rev 6, SU7 2. FSAR Section 6.6 Reactor Building Pressure-Time Response 3. Technical Specifications 3.5.3, Engineered Safeguards Protection System Actuation Setpoints 4. FSAR Section 6.3.3, Actuation 5. FSAR Section 6.5.3, Hydrogen Generation
- 6. OP-TM-EOP-006, LOCA Cooldown 7. 1302-5.25 Reactor Building Sump Level 8. FSAR Section 5.2 Reactor Building 9. FSAR Section 9.2, Chemical Addition and Sampling System 10. OP-TM-EOP-002, Loss of 25 0 F Subcooling Margin 11. OP-TM-EOP-006, LOCA Cooldown 12. OP-TM-EOP-010, Emergency Procedure Rules, Guides and Graphs 13. OP-TM-MAP-D0301, High Make-up Flow Month 20XX TMI 3-104 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA1 Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.Operating Mode Applicability:
5,6, D Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to Emergency 4KV buses.AND 2. Failure of EG-Y-1A, EG-Y-1 B Emergency Diesel Generators and EG-Y-4 SBO Diesel Generator to supply power to Emergency 4KV buses.AND 3. Failure to restore power to at least one Emergency 4KV bus in < 15 minutes from the time of loss of both offsite and onsite AC power.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an emergency bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via IC CS6 or RS1.Month 20XX TMI 3-105 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CAI (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, CA2 2. FSAR Section 8.2.2, Unit Distribution System 3. FSAR Section 8.2.3, Sources of Auxiliary Power 4. Technical Specification Section 3.7, Unit Electric Power System 5. 1107-1 Normal Electrical System 6. 11 07-2A Emergency Electrical
-4KV and 480 Volt 7. OP-TM-AOP-020 Loss Of Station Power 8. 1107-3 Diesel Generator 9. 1107-9 SBO Diesel Generator 10. FSAR Section 8.5, Station Blackout Month 20XX TMI 3-106 EP-AA-1009 (Revision XX)
Three Mile Island Station Annexm B Thre Mil Islnd tatin Anex xelnn Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS cul Initiating Condition:
Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:
5,6, D Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. AC power capability to Emergency 4KV buses reduced to only one of the following power sources for > 15 minutes." Auxiliary Transformer 1A" Auxiliary Transformer 1 B" Emergency Diesel Generator EG-Y-1A" Emergency Diesel Generator EG-Y-1 B" SBO Diesel Generator EG-Y-4 AND 2. ANY additional single power source failure will result in a loss of ALLAC power to SAFETY SYSTEMS.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.
When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased time available to restore another power source to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.Month 20XX TMI 3-107 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CUl (cont)Basis (cont): An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below." A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).
- A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.
- A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA1.Basis Reference(s):
- 1. NEI 99-01 Rev 6 CU2 2. FSAR Section 8.2.2, Unit Distribution System 3. FSAR Section 8.2.3, Sources of Auxiliary Power 4. Technical Specification Section 3.7, Unit Electric Power System 5. 1107-1 Normal Electrical System 6. 11 07-2A Emergency Electrical
-4KV and 480 Volt 7. OP-TM-AOP-020 Loss Of Station Power 8. 1107-3 Diesel Generator 9. 1107-9 SBO Diesel Generator 10. FSAR Section 8.5, Station Blackout Month 20XX TMI 3-108 EP-AA-1009 (Revision XX) r Three Mile~ kIslnd Station Annex Fvalnn Myt-lon&~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 Initiating Condition:
Hazardous event affecting SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:
5,6 Emergency Action Level (EAL): 1. The occurrence of ANY of the following hazardous events: " Seismic event (earthquake)
- Internal or external flooding event" High winds or tornado strike" FIRE" EXPLOSION" Other events with similar hazard characteristics as determined by the Shift Manager AND 2. EITHER of the following:
- a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.OR b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.Basis: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.EXPLOSION:
A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization.
A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion.
Such events may require a post-event inspection to determine if the attributes of an explosion are present.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
Month 20XX TMI 3-109 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear Thre Mil Isand taton AnexExelnn Nucilear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 (cont)Basis (cont): VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis.
The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.
This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL #2.a Basis Addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in operation since indications for it will be readily available.
The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.EAL #2.b Basis Addresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components.
Operators will make this determination based on the totality of available event and damage report information.
This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6 or RS1.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):
- 1. NEI 99-01 Rev 6, CA6 Month 20XX TMI 3-110 EP-AA-1009 (Revision XX)
N Three MileIsa dnd St~ation Annex Fvialnn N~im-lonr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU3 Initiating Condition:
Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Indicated voltage is < 105 VDC on required 125 VDC Distribution System 1A and 1B for> 15 minutes.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
This IC addresses a loss of Vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions raise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.
For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Depending upon the event, escalation of the emergency classification level would be via IC CA6 or CA5, or an IC in Recognition Category R.Month 20XX TMI 3-111 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU3 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, CU4 2. FSAR Section 8.2.2.6, 250/125 VDC System 3. 1107-2C Vital DC Electrical System 4. OP-TM-AOP-023, A DC System Failure 5. OP-TM-AOP-024, B DC System Failure Month 20XX TMI 3-112 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex 3x:lTn Nuchnric TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4 Initiating Condition:
Loss of all onsite or offsite communications capabilities.
Operating Mode Applicability:
5,6, D Emergency Action Level (EAL): 1. Loss of ALL Table C1 Onsite communications capability affecting the ability to perform routine operations.
OR 2. Loss of ALL Table C1 Offsite communication capability affecting the ability to perform offsite notifications.
OR 3. Loss of ALL Table C1 NRC communication capability affecting perform NRC notifications.
the ability to Table Cl Communications Capability System Onsite Offsite NRC Radios X Plant page X Plant Telephone System X Sound Powered Phones X Commercial Telephones X X X NARS X ENS X X HPN X X Satellite phones I X X Basis: This IC addresses a significant loss of on-site, offsite, or NRC communications capabilities.
While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).EAL #1 addresses a total loss of the communications methods used in support of routine plant operations.
Month 20XX TMI 3-113 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4 (cont)Basis (cont): EAL #2 Basis Addresses a total loss of the communications methods used to notify all OROs of an emergency declaration.
The OROs referred to here are listed in procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form.EAL #3 Basis Addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.
Basis Reference(s):
- 1. NEI 99-01 Rev 6, CU5 2. 1105-12 Communications System 3. FSAR Section 7.4.4, Communication Month 20XX TMI 3-114 EP-AA-1009 (Revision XX)
Throo Milo lainnd Rfnfinn Annav I:v,%1lnn Km,,-I--,r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 Initiating Condition:
Inability to maintain the plant in cold shutdown.Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature
> 2001F due to loss of decay heat removal for > Table C2 duration.OR 2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature rise due to loss of decay heat removal. (This EAL does not apply in solid plant conditions.)
Table C2 RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Status Duration Intact Not Applicable 60 minutes*Not Intact Established 20 minutes*OR Reduced Inventory Not Established 0 minutes* If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not applicable.
Month 20XX TMI 3-115 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 (cont)Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, etc.).This IC addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.
The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inventory is reduced (e.g., mid-loop operation in PWRs). The 20-minute criterion was included to allow time for operator action to address the temperature rise.The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature rise without a substantial degradation in plant safety.Finally, in the case where there is a rise in RCS temperature, the RCS is not intact or is at reduced inventory, and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes).
This is because 1) the evaporated reactor coolant may be released directly into the Containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.EAL #2 Basis Provides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS6 or RS1.Month 20XX TMI 3-116 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, CA3 2. Technical Specifications sections:
1.2.1, 1.7.a and c 3. Technical Specifications sections:
3.6.12.a 4. Technical Specifications sections:
3.6.5 5. Technical Specifications sections:
3.8.6 6. Technical Specifications sections:
1.2.1, 1.7.a and c, 3.6.12.a, 3.6.5, 3.8.6 7. 1101-3 Containment Integrity and Access Limits 8. OP-TM-EOP-030, Loss of Decay Heat Removal 9. Outage Fuel Protection Criteria Document Month 20XX TMI 3-117 EP-AA-1009 (Revision XX)
Three MileIs land Staition Annex FYAlnn Nucler~I TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5 Initiating Condition:
UNPLANNED rise in RCS temperature Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature
> 200OF due to loss of decay heat removal.OR 2. Loss of the following for >15 minutes.* ALL RCS temperature indications AND* ALL RCS level indications Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
This IC addresses an UNPLANNED rise in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC CA5.RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.
Month 20XX TMI 3-118 EP-AA-1009 (Revision XX)
N, Thra.o Mila~ IslandI Station Annex Fwainn NiirIanr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5 (cont)Basis (cont): EAL #1 involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications.
During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.
During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled.
A loss of forced decay heat removal at reduced inventory may result in a rapid rise in reactor coolant temperature depending on the time after shutdown.EAL #2 reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.
Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA5 based on exceeding plant configuration-specific time criteria.Basis Reference(s):
- 1. NEI 99-01 Rev 6, CU3 2. 1103-11 RCS Water Level Control 3. FSAR Section 7.3.2, Non-Nuclear Instrumentation
- 5. NEI 99-01 Rev 5, CU4 6. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX TMI 3-119 EP-AA-1009 (Revision XX)
Three Mile kIslnd Station Annex FwAlnn NucleItar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 Initiating Condition:
Loss of reactor vessel/RCS inventory affecting fuel clad integrity with containment challenged.
Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Reactor Vessel / RCS level unknown for > 30 minutes.AND 2. Core uncovery is indicated by ANY of the following: " Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Erratic Source Range Neutron Monitor indication.
OR* Radiation Monitor RM-G-6 or RM-G-7 reading > 3 R/hr.AND 3. ANY Containment Challenge Indication (Table C4)Table C3 Indications of RCS Leakage* UNPLANNED Reactor Bldg Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise*" UNPLANNED BWST level rise** UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.
Month 20XX TMI 3-120 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Emergency Action Level (EAL) (cont): Table C4 Containment Challenge Indications
- Hydrogen Concentration in Containment
> 4%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established*
- if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged.
This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity.
Releases can be reasonably expected to exceed EPA Protective Action Guidelines (PAG) exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment.
If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.Month 20XX TMI 3-121 EP-AA-1009 (Revision XX)
Thran RAilda lainnei -Q+n+irn Annov I~v-Inlrn K, ,ig----r Thra~~ MiI~ Ic6nrI ~*~h$inn Annav ~v~Ii~n hi I *f~ I ~ r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Basis (cont): The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity.
It therefore represents a challenge to Containment integrity.
In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment.
If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.
The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties).
It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.
If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.
These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
Month 20XX TMI 3-122 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, CG1 2. 1103-11 RCS Water Level Control 3. 1101-3 Containment Integrity and Access Limits 4. OP-TM-EOP-030, Loss of Decay Heat Removal 5. FSAR Sections 5.2, Reactor Building 6. FSAR Sections 6.5.2, Hydrogen Monitoring
- 8. Technical Specifications 3.5.5, Accident Monitoring Instrumentation
- 9. EP-AEL-0501, Estimation of Radiation Monitor Readings Indicating Core Uncovery During Refuel 10. 1301-1 Shift and Daily Checks, Data Sheet 3 Month 20XX TMI 3-123 EP-AA-1009 (Revision XX)
Three Mile kIslnd Sta~tion Annex FvAinn Nucler~I TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 Initiating Condition:
Loss of reactor vessel/RCS inventory affecting core decay heat removal capability.
Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Reactor Vessel / RCS level unknown for >30 minutes.AND 2. Core uncovery is indicated by ANY of the following: " Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Erratic Source Range Neutron Monitor indication.
OR* Radiation Monitors RM-G-6 or RM-G-7 reading > 3 R/hr.Table C3 Indications of RCS Leakage* UNPLANNED Reactor Bldg Sump level rise** UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise** UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.
Month 20XX TMI 3-124 EP-AA-1009 (Revision XX)
Three MileIsa mnd Station Annex FvAinn N~uclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CS6 (cont)Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.
The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.
Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.
The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties).
It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.
If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.
These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.
Escalation of the emergency classification level would be via IC CG6 or RG1.Month 20XX TMI 3-125 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, CS1 2. OP-TM-PRF1-0405 RB Sump Level Hi 3. 1101-3 Containment Integrity and Access Limits 4. 1301-1 Shift and Daily Checks, Data Sheet 3 5. 1103-11 RCS Water Level Control 6. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX TMI 3-126 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6 Initiating Condition:
Loss of reactor vessel/RCS inventory.
Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of Reactor Vessel / RCS inventory as indicated by RCS level< 0 inches on Draindown Level indicator.
OR 2. a. Reactor Vessel / RCS level unknown for > 15 minutes.AND b. Loss of Reactor Vessel / RCS inventory per Table C3 indications.
Table C3 Indications of RCS Leakage" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise*" UNPLANNED BWST level rise*" UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.
Month 20XX TMI 3-127 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear Thre Mil Isand taton AnexExelon Nuclea~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6 (cont)Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).
This condition represents a potential substantial reduction in the level of plant safety.EAL #1 Basis A lowering of water level below 0 inches on Draindown Level indicator indicates that operator actions have not been successful in restoring and maintaining reactor vessel/RCS water level. The heat-up rate of the coolant will rise as the available water inventory is reduced. A continuing drop in water level will lead to core uncovery.Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). A rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA5.EAL #2 Basis The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.
If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.
The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS6 If the reactor vessel/RCS inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS6.Basis Reference(s):
- 1. NEI 99-01 Rev 6, CA1 2. OP-TM-PRF1-0405 RB Sump Level Hi 3. 1301-1 Shift and Daily Checks, Data Sheet 3 4. 1103-11 RCS Water Level Control 5. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX TMI 3-128 EP-AA-1009 (Revision XX) l:xmlnn Three Mile Island Station Annex Fvl:n Nucha sris TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 Initiating Condition:
UNPLANNED loss of reactor vessel/RCS inventory for 15 minutes or longer.Operating Mode Applicability:
5,6 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in the inability to restore and maintain Reactor Vessel / RCS level to > procedurally established lower limit for > 15 minutes.OR 2. a. Reactor Vessel / RCS level unknown.AND b. Loss of Reactor Vessel / RCS inventory per Table C3 indications.
Table C3 Indications of RCS Leakage" UNPLANNED Reactor Bldg Sump level rise*" UNPLANNED Auxiliary Bldg. Sump level rise** UNPLANNED BWST level rise*" UNPLANNED RCDT level rise** UNPLANNED rise in RCS makeup" Observation of leakage or inventory loss*Rise in level is attributed to a loss of reactor vessel/RCS inventory.
Basis: UNPLANNED:
A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor reactor vessel/RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.Month 20XX TMI 3-129 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 (cont)Basis (cont): The procedurally established lower limit is not an operational band established above the procedural limit to allow for operator action prior to exceeding the procedural limit, but it is the procedurally established lower limit.Refueling evolutions that lower RCS water inventory are carefully planned and controlled.
An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.EAL #1 Basis Recognizes that the minimum required reactor vessel/RCS level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented.
This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.EAL #2 Basis Addresses a condition where all means to determine reactor vessel/RCS level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.
Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6 or CA5.Basis Reference(s):
- 1. NEI 99-01, Rev. 6 CU1 2. Technical Specification
3.1.6. Leakage
- 3. OP-TM-220-251 RCS Leak Rate Determination Using PPC 4. OP-TM-220-252, Primary -To -Secondary Leakrate Determination (OTSG Leakage):
Normal Operations
- 5. OP-TM-MAP-C0105 RCS Draindown LVL HI/LO 6. OP-TM-PRF1-0405 RB Sump Level HI 7. UFSAR 6.4.3, Bases of Leakage Estimate 8. 1103-11 RCS Water Level Control 9. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX TMI 3-130 EP-AA-1009 (Revision XX)
Three Mile Islamnd Stt~ion Annex~ Fvalnn Nwirlonr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 Initiating Condition:
HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): 1. A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.AND 2. a. ANY Table H1 safety function cannot be controlled or maintained.
OR b. Damage to spent fuel has occurred or is IMMINENT Table H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.Month 20XX TMI 13-131 EP-AA-1009 (Revision XX)
Three Mile Island Station Annexm m ThreeMileIslad Staion nnexFvAon Nucler~I TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 (cont)Basis (cont): HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions.
It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to 1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls, etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot be maintained.
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].contained in non-public documents such as the Security Plan.Basis Reference(s):
- 1. NEI 99-01, Rev. 6 HG1 2. Security and Safeguards Contingency Plan Station Security Plan -Appendix C Month 20XX TMI 3-132 EP-AA-1009 (Revision XX)
Thrina RAHAm lalnnrl -Qfnfirn Annav Pimyglrnn N, gl-ner Thr~ MiIg& Ie6nrI Q*~t.vhn Ann~v Fv~Ir~n hi. ir~Ic~r TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1.Initiating Condition:
HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:
1, 2,3,4,5,6, D Emergency Action Level (EAL): A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Month 20XX TMI 3-133 EP-AA-1 009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 (cont)Basis (cont): Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).
The Site Area Emergency declaration will mobilize ORO resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.
This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should be assessed using IC HAl. It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR§ 50.72.Escalation of the emergency classification level would be via IC HG1.Basis Reference(s):
- 1. NEI 99-01 Rev 6, HS1 2. Security and Safeguards Contingency Plan Station Security Plan -Appendix C Month 20XX TMI 3-134 EP-AA-1009 (Revision XX)
Three Mile kIslnd S~tation Annex FvPInn NucleIar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HAI Initiating Condition:
HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.Operating Mode Applicability:
1,2, 3, 4, 5, 6, D Emergency Action Level (EAL): 1. A validated notification from NRC of an aircraft attack threat < 30 minutes from the site.OR 2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the Month 20XX TMI 3-135 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HAI (cont)Basis (cont): This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact. Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).
The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL #1 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness.
This EAL is met when the threat-related information has been validated in accordance with OP-TM-AOP-008, Security Threat /Intrusion.
EAL #2 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.
The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.Escalation of the emergency classification level would be via IC HS1.Month 20XX TMI 3-136 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HAI (cont)Basis Reference(s):
- 1. NEI 99-01 Rev 6, HA1 2. Security and Safeguards Contingency Plan Station Security Plan -Appendix C 3. OP-TM-AOP-008, Security Threat / Intrusion Month 20XX TMI 3-137 EP-AA-1009 (Revision XX)
Fxelnn Three Mile~ kIslnd Station Annex FvAlnn Nuclekar TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 Initiating Condition:
Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:
1, 2,3,4,5,6, D Emergency Action Level (EAL): 1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.
OR 2. A validated notification from the NRC providing information of an aircraft threat.OR 3. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.Basis: SECURITY CONDITION:
Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.Month 20XX TMI 3-138 EP-AA-1009 (Revision XX)
Thran Win IQ12nri Q+!m+irn Annav C%-d%1#%n Khir-ldmýr Thr~ MiIc, IeI~anrI ~*~*.r~n Annav *5 ..
- w* .*. ...... --.... .r.. ...n fl~I %.1 I I~ L 1 ~OI TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HUl (cont)Basis (cont): This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-101-132.
EAL #2 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.
The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with OP-TM-AOP-008, Security Threat / Intrusion.
EAL #3 references Security Force because these are the individuals trained to confirm that a security event is occurring or has occurred.
Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR§ 2.39 information.
Escalation of the emergency classification level would be via IC HAl.Basis Reference(s):
- 1. NEI 99-01 Rev 6, HU1 2. SY-AA-101-132, Security Assessment and Response to Unusual Activities
- 3. Security And Safeguards Contingency Plan Station Security Plan -Appendix C Month 20XX TMI 3-139 EP-AA-1009 (Revision XX)
Throa RAila lainnd Rtnfinn Annov IPvg'lrnn KIuorlimr TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 Initiating Condition:
Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per OP-TM-EOP-020, Cooldown from Outside the Control Room.AND 2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table H1 Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* Core Cooling (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis: The time period to establish control of the plant starts when either: a. Control of the plant is no longer maintained in the Main Control Room OR b. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plan control to alternate locations is a precursor to a challenge to any fission product barriers within a relatively short period of time.Month 20XX TMI 3-140 EP-AA-1009 (Revision XX)
I=-zpinn Niie.Ipr Three Mile Island Station AnnexFYnnNIAa TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 (cont)Basis (cont): The determination of whether or not "control" is established at the remote safe shutdown location(s) is based on Emergency Director judgment.
The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).
Escalation of the emergency classification level would be via IC FG1 or CG6.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HS6 2. OP-TM-EOP-020, Cooldown from Outside the Control Room Month 20XX TMI 3-141 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA2 Initiating Condition:
Control Room evacuation resulting in transfer of plant control to alternate locations.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per OP-TM-EOP-020, Cooldown from Outside the Control Room.Basis: This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations.
The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel.
Activation of the ERO and emergency response facilities will assist in responding to these challenges.
Escalation of the emergency classification level would be via IC HS2.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HA6 2. OP-TM-EOP-020, Cooldown from Outside the Control Room Month 20XX TMI 3-142 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 Initiating Condition:
FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:
1,2, 3, 4, 5, 6, D Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of the following FIRE detection indications: " Report from the field (i.e., visual observation)" Receipt of multiple (more than 1) fire alarms or indications
- Field verification of a single fire alarm OR 2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).AND b. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR 3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.
OR 4 A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
Month 20XX TMI 3-143 EP-AA-1009 (Revision XX)
Three Mile Island Station AnnexNuclear Thre Mil Isand taton AnexExelnn Nucilear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)Emergency Action Level (EAL) (cont): Table H2 Vital Areas* Reactor Building* Intake Building* Intermediate Building 0 Control Tower 0 Auxiliary and Fuel Handling Buildings 0 1A and 1B Diesel Generator Buildings* BWST o CST Basis: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.EAL #1 Basis The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed.
Similarly, the fire duration clock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 Basis Addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.
Month 20XX TMI 3-144 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)Basis (cont): A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.
EAL #3 Basis In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.EAL #4 Basis If a FIRE within the plant PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded.
The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish.
Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.Month 20XX TMI 37145 EP-AA-1009 (Revision XX)
Three Mile Isla~nd Station Annex FvieInn Nucler~I TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)Basis (cont): Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.
In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MA5.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HU4 2. FSAR Figure 2.1-3, Extended Plot Plan TMINS 3. FSAR Section 5.1, Class I Structures, Components, and Systems 4. OP-TM-AOP-001, Fire 5. OP-TM-EOP-020, Cooldown Outside of Control Room Month 20XX TMI 13-146 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 Initiating Condition:
Seismic event greater than OBE levels.Operating Mode Applicability:
1,2, 3, 4, 5, 6, D Emergency Action Level (EAL): Seismic event > Operating Basis Earthquake (OBE) as indicated by seismic Alarms PRF-1-3 Operating Basis earthquake and PRF-1-2 Threshold Seismic Condition.
Basis: This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE)1.An earthquake greater than an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections).
Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following an OBE. Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MA5.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HU2 2. OP-TM-AOP-003, Earthquake
- 3. PRF 1-3 Operating Bases Earthquake
- 4. PRF 1-2 Threshold Seismic Event 1 An OBE is vibratory ground motion for which those features of a nuclear power plant necessary for continued operation without undue risk to the health and safety of the public will remain functional.
An SSE is vibratory ground motion for which certain (generally, safety-related) structures, systems, and components must be designed to remain functional.
Month 20XX TMI 3-147 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 Initiating Condition:
Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): Note: If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.
- 1. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*
Modes 4, 5, and 6 Intermediate Building*
Modes 4, 5, and 6 Auxiliary Building*
Modes 4, 5, and 6 Fuel Handling Building*
Modes 4, 5, and 6*Areas required to establish shutdown cooling AND 2. Entry into the room or area is prohibited or impeded Basis: This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures.
This condition represents an actual or potential substantial degradation of the level of safety of the plant.Month 20XX TMI 3-148 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 (cont)Basis (cont): Table H3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown.
This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas.An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the gaseous release preclude the ability to place shutdown cooling in service. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).
An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release).
For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing)." The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.Month 20XX TMI 3-149 EP-AA-1009 (Revision XX)
NtislAir Three MileIsa dnd Station Annex FvAlnn Nucler~I TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 (cont)Basis (cont): An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment.
This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke or that automatically or manually activate a fire suppression system in an area.Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HA5 2. FSAR Figure 2.1-3, Extended Plot Plan TMINS 3. FSAR Section 5.1, Class I Structures, Components, and Systems 4. NEI 99-01, Rev. 5 HA3 5. OP-TM-406-901, Hazardous Material Release 6. AR-660892, Station Halon and IDLH Evaluations
- 7. 29CFR1910.134(b) and 29CFR1910.134(d)(2)(iii)
Month 20XX TMI 3-150 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 Initiating Condition:
Hazardous Event Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL): Note: EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.
- 1. Tornado strike within the PROTECTED AREA.OR 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode.OR 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).OR 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.OR 5. Abnormal river water level at the intake Pump and Screen House, as indicated by EITHER: a. > 300 ft. el. (high level)OR b. < 274 ft. el. (low level)Basis: PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.
Month 20XX TMI 3-151 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 (cont)Basis (cont): This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.EAL I Basis Addresses a tornado striking (touching down) within the Protected Area.EAL #2 Basis Addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. Manual isolation of power to a SAFETY SYSTEM component as a result of is an event of lesser impact and would be expected to cause small and localized damage. The consequence of this type of event is adequately assessed and addressed in accordance with Technical Specifications.
EAL #3 Basis Addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.EAL #4 Basis Addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.
Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.Escalation of the emergency classification level would be based on ICs in Recognition Categories R, F, M, H or C.Basis Reference(s):
- 1. NEI 99-01, Rev 6 HU3 2. OP-TM-AOP-005 River Water System Failures 3. OP-TM-AOP-002, Flood 4. OP-TM-AOP-004, Tornado / High Winds Month 20XX TMI 3-152 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 (cont)B asis .(co~nt):
.i .,.'~ ii..i .!. '.. ...... ... ...... .... ..... .. .. .. ..... .. ....EAL #5 Basis: The level of the Susquehanna River is approaching flood stage; flood stage is defined as 302 ft el. at the Intake Pump and Screen House.A low river water condition below 274 ft el. requires a Technical Specification
3.0.1 plant
shutdown per OP-TM-AOP-005 and is a precursor to a more serious condition.
Escalation of the emergency classification level would be based on ICs in Recognition Categories R, F, M, H or C.Basis Reference(s):,, 1. NEI 99-01, Rev 6 HU3 2. OP-TM-AOP-005 River Water System Failures 3. OP-TM-AOP-002, Flood 4. OP-TM-AOP-004, Tornado / High Winds Month 20XX TMI 3-153 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelnn Nucler~I TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG7 Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY.
Operating Mode Applicability:
1,2, 3, 4, 5, 6, D Eimergencyi Action LevelE(EAL):
Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.
Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a General Emergency.
Basis Refere.ce():
1.. ........ ....e1 -O 1 ,..ev 6 H .................
..... ... .....G..... .... ...1. NEI 99-01, Rev 6 HG7 Month 20XX TMI 3-154 EP-AA-1009 (Revision XX)
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Other conditions exist which in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY.
Operating ModeAppihcability:
1,2, 3, 4, 5, 6, D Emergency Action Level (EAL):..Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.B a s is : .. ..:. ." ......HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a Site Area Emergency.
.- ... ... ..* ..... .. ..Basis 9Reference(s):
- 1. NEI 99-01, Rev 6HS7 Month 20XX TMI 3-155 EP-AA-1009 (Revision XX)
Three Mile Island Station Annex Exelon Nuclear TABLE TMI 3-2: EAL Technical Basis RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA7 Initiating Condition:.,:, Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT.operating Mode Applicability.
.. r.tin. ....Appl i..l....i 1,2,3, 4,5,6, D Emergency Action Level (EAL): -Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.
HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:
An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.Basis Reference(s)-:....
....................................
1 .. ... ...... ....1 .NEI 99-01, Rev 6 HA7 Month 20XX TMI 3-156 EP-AA-1009 (Revision XX)
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Other conditions exist which in the judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT.Ope~rating Mode'..Applicability:..:,.., .1,2,3, 4,5,6, D Emergency Action Level (EAL):.Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.
No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENT.Basis Reference(s):
- 1. NEI 99-01, Rev 6HU7 Month 20XX TMI 3-157 EP-AA-1009 (Revision XX)