Text

Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. Cover Through Page LGS 3-69
	ML14164A068
Person / Time
Site:	Limerick
Issue date:	05/30/2014
From:	; Exelon Generation Co
To:	; NRC/FSME, Office of Nuclear Material Safety and Safeguards
Shared Package
ML14164A053	List: ML14164A054; ML14164A055; ML14164A056; ML14164A058; ML14164A060; ML14164A061; ML14164A062; ML14164A063; ML14164A064; ML14164A065; ML14164A066; ML14164A067; ML14164A068; ML14164A069; ML14164A071; ML14164A073; ML14164A076; ML14164A079; NEI 99-01, Braidwood, Units 1 and 2, Attachment 2, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1001, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 2A, and 2B, Cover Through Pa; NEI 99-01, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3A, 3B, Cover - by 3-74; NEI 99-01, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3B, 3C, by 3-75 - by 3-157; NEI 99-01, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4A and 4B, Cover - Cl 3-73; NEI 99-01, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4B and 4C, Cl 3-74 - Cl 3-151; NEI 99-01, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5A and 5B, Cover - Dr 3-76; NEI 99-01, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5B and 5C, Dr 3-77 - Dr 3-160; NEI 99-01, LaSalle, Units 1 & 3, Attachment 6, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1005, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 6A and 6B, Cover - LS 3-74; NEI 99-01, License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.; RA-14-032, Attachment 10: Discussion of Revision to the Radiological Emergency Plan Annex for Quad Cities Nuclear Power Station, Page QC 3-69 Through End; RA-14-032, Attachment 11: Discussion of Revision to the Radiological Emergency Plan Annex for Three Mile Island Nuclear Station, Page TMI 3-80 Through End; RA-14-032, Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. Cover Through Page LGS 3-69; RA-14-032, Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. LGS 3-70 Page LGS 3-155; RA-14-032, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station, Page Ocgs 3-76 Through End; RA-14-032, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station. Cover Through Page Ocgs 3-75; RA-14-032, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Cover Through Page PBAPS 3-76; RA-14-032, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Page PBAPS 3-77 Through End; RA-14-032, Braidwood, Units 1 and 2, Attachment 2, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1001, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 2A, and 2B, Cover Through Pa; RA-14-032, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3A, 3B, Cover - by 3-74; RA-14-032, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3B, 3C, by 3-75 - by 3-157; RA-14-032, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4A and 4B, Cover - Cl 3-73; RA-14-032, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4B and 4C, Cl 3-74 - Cl 3-151; RA-14-032, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5A and 5B, Cover - Dr 3-76; RA-14-032, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5B and 5C, Dr 3-77 - Dr 3-160; RA-14-032, LaSalle, Units 1 & 3, Attachment 6, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1005, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 6A and 6B, Cover - LS 3-74; RA-14-032, License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.; RS-14-115, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Page PBAPS 3-77 Through End; TMI-14-046, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station, Page Ocgs 3-76 Through End;
References
	RA-14-032, RS-14-115, TMI-14-046 EO-AA-1008, NEI 99-01, Rev. 6
	Download: ML14164A068 (136)
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ATTACHMENT 7 DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FOR LIMERICK GENERATING STATION EP-AA-1 008 Enclosures

Enclosure 7A -EAL Comparison Matrix Document* Enclosure 7B -EAL Red-Line Basis Document* Enclosure 7C -EAL Basis Document NEI 99-01 REVISION 6 DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS ArrACHMENT 7 DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FOR LIMERICK GENERATING STATION mr Exelon Generation.

0 NEI 99-01 Rev 6 Proposed EAL I Justification AGI Initiating Condition

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

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

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

RGI Initiating Condition:

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

1,2,3,4,5.

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

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

1. 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.

Table R1 Effluent Monitor Thresholds Release Path General Emergency North Stack (WR Monitor: RIX-26-076-4) 1.92 E+08 uCi/sec South Stack (Unit 1: RY26-185A-3 I RY26- 2.71 E-01 uCi/sec 185-B-3 or Unit 2: RY26-285A-3

/ RY26-285-B-3)H No Change F--]Difference I Deviation 1) Listed site-specific monitors and threshold values to ensure timely classification.

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

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 lx1 7 procedure matrix used by the SM.Page 1 of66 NEI 99-01 Rev 6 Proposed EAL Justification ASI Initiating Condition

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

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

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

RS1 Initiating Condition:

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

1,2,3,4,5, D Emergency Action Level (EAL): Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* 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.

I. Readings on ANY Table RI 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.

Table R1 Effluent Monitor Thresholds Release Path Site Area Emergency North Stack (WR Monitor: RIX-26-076-4) 1.92 E+07 uCi/sec South Stack (Unit 1: RY26-185A-3

/ 2.71 E-02 uCi/sec RY26-185-B-3 or Unit 2: RY26-285A-3 I RY26-285-B-3)

LI No Change E Difference 1 Deviation 1) Listed site-specific monitors and threshold values to ensure timely classification.

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

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 11x17 procedure matrix used by the SM.Page 2 of 66 NEI 99-01 RevS Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL Justification 4 +AA1 Initiating Condition

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

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

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

RA1 Initiating Condition:

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

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

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

1. Readings on ANY Table RI 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. > 10 mRem TEDE OR b. > 50 mRem CDE Thyroid OR 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary a. 10 mRem TEDE for 60 minutes of exposure OR b. 50 mRem CDE Thyroid for 60 minutes of exposure OR 4. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (cdosed window) dose rates > 10 mR/hr are expected to continue for a 60 minutes.OR b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.

Table RI Effluent Monitor Thresholds Release Path Alert North Stack (WR Monitor: RIX-26-076-4) 1.92 E+06 uCi/sec South Stack (Unit 1: RY26-185A-3

/ 2.71 E-03 uCi/sec RY26-185-B-3 or Unit 2: RY26-285A-3

/RY26-285-B-3)

LI No Change E Difference

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

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

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x17 procedure matrix used by the SM.3) A calculation was performed, in accordance with (lAW) guidance provided in NEI 99-01 revision 6 EAL AA1, to determine the effluent monitor response for a radioactive liquid release via the normal site release pathway. The liquid release would contain activity equivalent to provide 10mrem TEDE or 50mrem thyroid CDE at the site boundary.

The calculation determined the effluent monitor response would be >110% of the instrument maximum range and as such, lAW NEI 99-01 Rev 6 guidance, was not included in this EAL.Page 3 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification AUI Initiating Condition

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

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

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

1,2, 3,4, 5, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.1. Reading on ANY of the following effluent monitors > 2 times alarm setpoint established by a current radioactive release discharge permit for a 60 minutes." Radwaste Discharge Effluent Monitor (RR63-OR001)

OR" Discharge Permit specified monitor OR 2 Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 60 minutes: Table R1 Effluent Monitor Thresholds Release Path Unusual Event North Stack (WR Monitor: RIX-26-076-4) 2.20 E+04 uCi/sec South Stack (Unit 1: RY26-185A-3

/ RY26- 3.09 E-05 uCi/sec 185-B-3 or Unit 2: RY26-285A-3

/ RY26-285-B-3)OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.D:1 No Change 111 Difference F Deviation 1) Listed site-specific monitors and threshold values to ensure timely classification.

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

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x17 procedure matrix used by the SM.Page 4 of 66 NED 99-01 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL Justification

--- -t AG2 Initiating Condition

-- GENERAL EMERGENCY Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.Operating Mode Applicability:

All Example Emergency Action Levels: NOTES: The Emergency Director should declare the General Emergency promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded 1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.RG2 D No Change E Difference 1 Deviation 1) EAL not used in accordance with the discussion in Section 1.4, NRC Order EA-1 2-051, it is recommended that this EAL be implemented when the enhanced spent fuel pool level instrumentation is available for use per developer note guidance, The completion of the enhanced SFP level indicators and need for the inclusion of this EAL is being tracked in accordance with Exelon Generation Company, LLC's Initial Status Report to March 12, 2012 Commission Order Modifying Licenses with Regard for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated October 25,2012.Page 5 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition

-SITE AREA EMERGENCY AS2 RS2 1 No Change FIDifference jJ Deviation Spent fuel pool level cannot be restored to at least (site-specific Level 3 description)

1) EAL not used in accordance with the discussion in Section 1.4, NRC Order EA-1 2-051, it is recommended that this EAL be implemented when the enhanced Operating Mode Applicability:

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

October 25,2012.Page 6 of 66 0 NEI 99-01 Rev 6 Proposed EAL Justification AA2 RA2 Initiating Condition

-ALERT Initiating Condition:

A2 j No Change Difference Deviation Significant loweing of water level above, or damage to, irradiated fuel. Significant lowering of water level above, or damage to, irradiated fuel. 1) Listed site-specific monitors and threshold values to ensure timely classification.

Operating Mode Applicability:

All Operating Mode Applicability:

2) EAL #3 not used in accordance with the discussion in Section 1.4. NRC Order 1. 2, 3, 4, 5, D EA-12-051, it is recommended that this EAL be implemented when the enhanced Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Level (EAL): spent fuel pool level instrumentation is available for use per developer note guidance.

The completion of the enhanced SFP level indicators and need for the 1. Uncovery of irradiated fuel in the REFUELING PATHWAY. 1. Uncovery of irradiated fuel in the REFUELING PATHWAY. inclusion of this EAL is being tracked in accordance with Exelon Generation OR Company, LLC's Initial Status Report to March 12, 2012 Commission Order 2. Damage to irradiated fuel resulting in a release of radioactivity from the Modifying Licenses with Regard for Reliable Spent Fuel Pool Instrumentation fuel as indicated by ANY of the following radiation monitors:

2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel (Order Number EA-12-051) dated October 25,2012.as indicated by ANY Table R2 Radiation Monitor reading >1000 mRemlhr.(site-specific listing of radiation monitors, and the associated readings, setpoints and/or alarms)Table R2 3. Lowering of spent fuel pool level to (site-specific Level 2 value). Refuel Floor ARM's" RIS29-Ml-1(2)K600.

Drywell Head Laydown" RIS30-M1-1(2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool" RIS32-Ml-1(2)K600, New Fuel storage Vault.RIS33-M1-1(2)K600, Pool Plug Laydown Page 7 of 66 NEI 99-01 Rev 6 [ Proposed EAL [ Justification AA3 Initiating Condition

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

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

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

RA3 Initiating Condition:

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

1,2, 3,4, 5, D Emergency Action Level (EAL): Note: If the equipment in the room or area listed in Table R4 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.

1-l No Change 1 Difference 1 Deviation 1) Listed site specific plant rooms and areas with identified mode applicability to ensure timely classification.

1 .Dose rate > 15 mR/hr in ANY of the following Table R3 areas: 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 Enclosure*

I Modes 3, 4, and 5*Areas required to establish shutdown cooling Page 9 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU3 RU3 I No Change [--j Difference U Deviation Initiating Condition:

UNUSUAL EVENT Initiating Condition:

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

Operating Mode Applicability:

2) Listed this system category EAL in the radiological category EAL section to Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 maintain consistency with current and previous revisions of Exelon EALs. This will Example Emergency Action Levels: Emergency Action Level (EAL): ensure a timely classification since the threshold values are more aligned with the radiological category vice system category.1. (Site-specific radiation monitor) reading greater than (site-specific value). 1. Air Ejector discharge radiation monitor (RISH 26 1(2)K601A, B) Hi-Hi alarm.OR OR 2. Sample analysis indicates that a reactor coolant activity value is greater than 2. Specific coolant activity > 4.0 uClIgm Dose Equivalent 1-131.an allowable limit specified in Technical Specifications.

Page 10 of 66 NEI 99-01 rev 6 Fission Product Barrier Matrix Fisso Product_ _ _ _ _ _ _ _ Barrier_ _ _ _ _ _ Mari _ _ _ _ _ _ _ _ _ _ __ITAEAEMEGECYALRT_

otM_ _FGI Loss of any two barriers AND Loss or Potential Loss of third barrier.1.2,3 FSI Loss or Potential Loss of ANY two barriers.1,2,3 FAI ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 1,2,3 FC -Fuel C lad RC -Reactor Coolant System CT -Containment Siubo-Category Loss Potential Loss Loss Potential Loss Loss Potential Loss 1. RCS Activity/

A. UNPLANNED rapid drop in primary A. Primary containment pressure greater containment pressure following than (site-specific value)Containment A (Site specific indications that A Primary containment pressure primary containment pressure rise OR Cnan nt reactor coolant activity is greater NoneA.Piaycnimetpsur Pressure r greater than (site-specific value) None OR B. (site-specific explosive mixture) exists than 300 uCi/gm dose equivalent due to RCS leakage. inside primary containment Primary 1-131) B. Primary containment pressure Containment response not consistent with LOCA OR Conditions conditions.

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

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

A. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal OR A. UNISOLABLE primary system leakage A. UNISOLABLE break in any of the that results in exceeding EITHER of B. Intentional primary containment A, RCSOLLeakbraRateany thehe following:EO~

3 .R C S Le a k R a te / fo llow ing : ( site -spe c ific syste m s w ith the fo llowi ng : O per tin O R N one Co tanm e nt None None potential for high-energy line breas) 1.M x N r a p rtn RNone NettfrgngibaOR Temperature C. UNISOLABLE primary system Isolation Failure B. Emergency RPV Depressurization OR leakage that results in exceeding 2. Max Normal Operating Area EITHER of the following:

Radiation Level. 1. Max Safe Operating Temperature.

OR 2. Max Safe Operating Area Radiation Level.4.Primary A. Primary Containment Radiation A. Primary Containment Radiation A. Primary Containment Radiation Monitor Containment Monitor reading greater than None Monitor reading greater than (site- None None reading greater than (site-specific Radiation (site-specific value), specific value). value).5. Emergency Director Judgment A. Any Condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.A. ANY Condition in the opinion of the A. Any Condition in the opinion of the Emergency Director that indicates Loss Emergency Director that indicates of the RCS Barrier. Potential Loss of the RCS Barrier.A. Any Condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier..A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Page 11 of 66 Proposed Fission Product Barrier Matrix Fission_ _ _ _ _ _ _ _ _ _ PrdcIare arxGNRLEEREC IEAE MREC LR Proposed Fission Product Barrier Matrix FG1 Loss of any two barriers AND Loss or Potential Loss of third barrier. [FSI Loss or Potential Loss of ANY two barriers.

NJ[Ur2 j FAI ANY Loss or ANY Potential Loss of either Fuel Clad or RCS r[]A FC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category Loses Potential Loss Loss Potential Loss Loss Potential Loss Coolant activity > 300 uCtigm Dose None None 1. RCS Activity Equivalent 1-131. None Nose None 2 RPV water level cannot be restored and 1. RPV water level cannot be restored and 1. Plant conditions indicate Primary maintained

> -161 Inches (TAF) maintained

> -161 Inches (TAF) Plant conditions indicate Primary Containment

2. RPV Water Containment flooding is required.

OR OR None None ftooding is required.Level 3. RPV water level causst be determined.

2. RPV water level cannot be determined.

3. Containment pressure s 55 pstg and rising.OR 1. UNPLANNED rapid drop in pnmary 4. a Drywell or Suppression Pool Hydrogen 1. Drywell pressure >1.68 pslg. containment pressure following primary concentration

> 6%.3. Primary AND containment pressure rise. AND Containment None None 2. Drywell pressure rise is due to RCS None OR b, Drywell or Suppression Pool Oxygen PressurelConditions leakage 2. Primary containment pressure response not concentration 5 5%consistent with LOCA conditions.

OR 5. Heat Capacity Limit (T-102 Curve SP/T-1))exceeded.3. UNISOLABLE primary system leakage that 1. UNISOLABLE Main Steam Line (MSL) results in EITHER of the following:

HPIC, Feedwater, RWCU, or RCIC hoe a. Secondary Containment area break, temperature

> T-1031 SAMP, Max 4.RCS Leak Rate None None OR Norm Op Value (MNO) None None 2. Emergency RPV Depressurization is OR 2.remerbre s Secondary Containment area radiation required, level > T-lg31 SAMP, Max Norm Op Value (MNO), 5.Primary Drywell radiation monitor reading NoneDrywell radiation monitor reading Cnanet >19E52RtrNoeDrywetl radiation monitor reading Nrwe Noneinmoiorradn Containment 1.90 E+02 R/hr. > 100R/hr o 4.35 E+O2 R/hr Radiation 1. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal.OR 2. Intentional Primary Containment venting/purging per EOPs or SAGs due to accident conditions.

OR 6.Primary

3. UNISOLA1BLE primary system leakage that Containment None NONE None None 3.UIOAL daysse ekg ht None Isotation Failure results in EITHER of the following:

a Secondary Containment area temperature T-1 031 SAMP, Max Safe Op Value fMNO)OR b. Secondary Containment area radiation level s T-1031 SAMP, Max Safe Op Value (MNO)1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. ANY Condition in the opinion of the 2 Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the Emergency 7. Emergency Emergency Director that indicates Loss Emergency Director that indicates Potential Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss of the Director that indicates Potential Loss of the Director Judgment of the Fuel Clad Barrier. Loss of the Fuel Clad Barrier. the RCS Barrier. Loss of the RCS Barrier. Containment Barrier. Containment Barrier.Page 12 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification FCl Category:

Fuel Clad Barrier RCS Activity Operating Mode Applicability:

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

Loss A. (Site specific indications that reactor coolant activity is greater than 300 uCi/gm dose equivalent 1-131)FC1 Category:

Fuel Clad Barrier RCS Activity Operating Mode Applicability:

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

Loss Coolant activity > 300 uCilgm Dose Equivalent 1-131.E No Change 1-] Difference 1:1 Deviation 1) Listed site-specific threshold value to ensure timely classification.

Page 13 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC2 Category:

Fuel Clad BarrierFC No Change Differ Deviation RPV Water Level RCS Activity 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Primary containment flooding required-

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

> -161 inches (TAF)A. RPV water level cannot be restored and maintained above (site-specific RPV OR water level corresponding to top of active fuel) or cannot be determined.

3. RPV water level cannot be determined.

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

Fuel Clad Barrier FC4 Category:

Fuel Clad BarrierFC No Change Difference Deviation Primary Containment Radiation Primary Containment Radiation

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

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Primary Containment Radiation Monitor reading greater than (site-specific Drywell radiation monitor reading > 1 .90 E+02 RJhr.value).Page 15 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC6 Category:

Fuel Clad Barrier FC7 No Change Difference Deviation Emergency Director Judgment Emergency Director Judgment Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1.2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

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

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

Reactor Coolant System Barrier Rd Category:

Reactor Coolant System Barrier RC3 E No Change Difference Deviation Primary Containment Pressure Primary Containment Pressure/Conditions

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

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Primary containment pressure greater than (site-specific value) due to RCS 1. Drywell pressure >1.68 pslg.leakage. AND 2. Drywell pressure rise is due to RCS leakage Page 17 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC2 Category:

Reactor Coolant System Barrier RC2 [ No Change Difference Deviation RPV Water Level RPV Water Level 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

Loss Loss A. RPV water level cannot be restored and maintained above (site-specific RPV 1. RPV water level cannot be restored and maintained

> -161 inches (TAF)level corresponding to the top of active fuel) or cannot be determined.

OR 2. RPV water level cannot be determined.

Page 18 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC3 Category:

Reactor Coolant System BarrierRC4 No Change Differe Deviation RCS Leak Rate RCS Leak Rate 1) Listed site-specific systems and threshold values to ensure timely classification.

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

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

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

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

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

a. Secondary Containment area temperature

> T-1031 SAMP, Max Norm Op 1. Max Normal Operating Temperature Value (MNO)OR OR 2. Max Normal Operating Area Radiation Level. b. Secondary Containment area radiation level > T-103/ SAMP, Max Norm Op Value (MNO).Page 19 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC4 Category:

Reactor Coolant System Barrier RC5 E No Change Difference Deviation Primary Containment Radiation Primary Containment Radiation

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

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Primary Containment Radiation Monitor reading greater than (site-specific Drywell radiation monitor reading > IO0R/hr value).Page 20 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC6 Category:

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

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

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

Containment Barrier CTI Category:

Containment BarrierCT No Change Diffrenc Deviation Primary Containment Conditions Primary Containment Pressure/Conditions

1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

Loss Loss C. UNPLANNED rapid drop in primary containment pressure following primary 1. UNPLANNED rapid drop in primary containment pressure following primary containment pressure rise containment pressure rise.OR OR 2. Primary containment pressure response not consistent with LOCA conditions.

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

Potential Loss Potential Loss D. Primary containment pressure greater than (site-specific value) 3. Containment pressure > 55 psig and rising.OR OR E. (site-specific explosive mixture) exists inside primary containment

4. a. Drywell or Suppression Pool Hydrogen concentration

> 6%.OR AND b. Drywell or Suppression Pool Oxygen concentration

> 5%B. HCTL exceeded.

OR 5. Heat Capacity Limit (T-102 Curve SPIT-1)) exceeded.Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT2 Category:

Containment Barrier CT2 No Change Diffrenc Deviation RPV Water Level RPV Water Level Operating Mode Applicability:

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

Potential Loss Potential Loss A. Primary containment flooding required.

Plant conditions indicate Primary Containment flooding is required.Page 23 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT3 Category:

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

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

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

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

following:

a. Secondary Containment area temperature

> T-1031 SAMP, Max Safe Op Value (MNO)1. Max Safe Operating Temperature.

OR OR b. Secondary Containment area radiation level > T-1031 SAMP, Max Safe 2. Max Safe Operating Area Radiation Level. Op Value (MNO)Page 24 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT4 Category:

Containment Barrier CT5 F] No Change Difference

[ Deviation Primary Containment Radiation Primary Containment Radiation

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

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

Potential Loss Potential Loss A. Primary Containment Radiation Monitor reading greater than (site-specific value). Drywell radiation monitor reading > 4.35 E+02 R/hr Page 25 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT6 Category:

Containment BarrierT No Change Diffren Deviation Emergency director Judgment Emergency Director Judgment Operating Mode Applicability:

Operating Mode Applicability:

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

Fission Product Barrier (FPB) Threshold:

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

2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier. Loss of the Containment Barrier.Page 26 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SG1 MG1 m Initiating Condition:

GENERAL EMERGENCY Initiating Condition:

L-'X- No Change j Difference U- Deviation Prolonged loss of all offsite and all onsite AC power to emergency buses. Prolonged loss of all offsite and all onsite AC power to emergency buses. 1) Listed site specific equipment, site specific time based on station blackout Operating Mode Applicability:

Operating Mode Applicability:

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

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

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses).1 Loss of ALL offsite AC power to unit 4 KV Safeguards Buses.AND AND 2. Failure of D11(21) and D12(22), D13(23), and D14(24) Emergency Diesel b. EITHER of the following:

Generators to supply power to unit 4KV Safeguards Buses.AND" Restoration of at least one emergency bus in less than (site-specific hours) is not likely. 3. EITHER of the following:

a. Restoration of at least one unit 4KV safeguards Bus in < 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is not* (Site-specific indication of an inability to adequately likely.remove heat from the core) OR b. RPV water level cannot be determined to be > -186 inches.Page 27 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification SS1 Initiating Condition:

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

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

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

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC Power to unit 4KV Safeguards Buses.AND 2. Failure of O11(21), O12(22), D13(23), and D14(24) Emergency Diesel Generators to supply power to unit 4KV Safeguards Buses.AND 3. Failure to restore power to at least one unit 4KV Safeguards bus in < 15 minutes from the time of loss of both offsite and onsite AC power.F] No Change Difference FIDeviation

1) Listed site specific equipment to ensure timely classification.

Page 28 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA1 Initiating Condition:

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

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Alert promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.1. a. AC power capability to (site-specific emergency buses) is reduced to a single power source for 15 minutes or longer.AND b. Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS.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 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit 4KV Safeguards Buses reduced to only one of the following power sources for > 15 minutes.* 101 Safeguards Transformer

201 Safeguards Transformer D 011(21) Diesel Generator* D12(22) Diesel Generator* D13(23) Diesel Generator D 014(24) Diesel Generator AND 2. ANY additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS.M No Change FIDifference R Deviation 1) Listed site specific equipment to ensure timely classification.

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

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

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15 minutes or longer MU1 Initiating Condition:

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

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

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

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

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

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

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to unit 4KV safeguards Buses.AND 2. Failure of D1 1(21), D12(22), D13(23), and D14(24) Emergency Diesel Generators to supply power to unit 4KV Safeguards Buses.AND 3. Voltage is <105 VDC on 125 VDC battery busses 1(2)FA, FB, FC, and FD for>15 minutes.AND 4. ALL AC and Vital DC power sources have been lost for > 15 minutes.H No Change M Difference FIDeviation

1) Listed site specific equipment to ensure timely classification.

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

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

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

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

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on 125 VDC battery busses 1(2)FA, FB, FC, and FD for > 15 minutes.D No Change M Difference

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

2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.Page 32 of 66 NEI 99-01 Rev 6 SS5 Initiating Condition:

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

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

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

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

1,2 Emergency Action Level (EAL): 1. Automatic scram did not shutdown the reactor as indicated by Reactor Power> 4%.AND 2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 4%.AND 3. EITHER of the following conditions exist: " RPV water level cannot be restored and maintained

> -186 inches.OR" Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.D-1 No Change M Difference FIDeviation

1) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scram Page 33 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification SAO Initiating Condition:

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

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

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

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

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

1. Automatic or manual scram did not shutdown the reactor as indicated by Reactor Power > 4%.AND 2. Manual / ARI actions taken at the Reactor Console are not successful in shutting down the reactor as indicated by Reactor Power > 4%.D No Change r -] Difference FIDeviation 1 ) Listed site specific indications to ensure timely classification.

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

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

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

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

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

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

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

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

1. a. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 4%.AND b. Subsequent manual / ARI action taken at the Reactor Console is successful in shutting down the reactor.OR 2. a. Manual scram did not shutdown the reactor as indicated by Reactor Power > 4%.AND b. EITHER of the following:

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

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

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

Automatic or Manual Runback >25% thermal reactor power* Electrical Load Rejection

>25% full electrical load* Reactor Scram* ECCS Actuation* Thermal Power oscillations

> 10%Page 36 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification SU2 Initiating Condition:

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

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

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

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

Reactor Power* RPV Water Level* RPV Pressure* Drywell Pressure* Suppression Pool Level* Suppression Pool Temperature Page 37 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA9 Initiating Condition:

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

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: 1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* (site-specific hazards)* Other events with similar hazard characteristics as determined by the Shift Manager AND b. EITHER of the following:

1. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.OR 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.MA5 Initiating Condition:

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

1,2,3 Emergency Action Level (EAL): 1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* Other events with similar hazard characteristics as determined by the Shift Manager AND 2. EITHER of the following:

a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical 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.F No Change M Difference FIDeviation

1) No additional site specific hazard noted 2) Changed the word "needed" to "required" in the IC and "required by Technical Specification" in the EAL to be consistent with terminology used by operators and minimize confusion.

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

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

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

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

1,2,3 F No Change i Difference I Deviation 1) Listed site specific values to ensure timely classification.

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

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

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 into the drywell > 10 gpm for> 15 minutes.OR 2. RCS identified leakage into the drywell >25 gpm for > 16 minutes.OR 3. Leakage from the RCS to a location outside the drywell >25 gpm for > 15 minutes.Page 39 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification Initiating Condition:

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

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods: (site-specific list of communications method 2. Loss of ALL of the following ORO communications s) methods: (site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods: (site-specific list of communications methods)SU6 MU7 Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

1,2,3 No Change F1 Difference FIDeviation

1) Listed site specific communication methods to ensure timely classification.

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 Capability System Onsite Offslte NRC Station Radio X Plant Public Address (PA) X Prelude System X X Station Phones X X X Satellite Phones X X X NARS X HPN X X ENS X X Page 40 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA2 Initiating Condition:

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

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

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

4,5, D Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of all offsite AC power to unit 4KV Safeguards Buses.AND 2. Failure of Dl1(21), D12(22), D13(23), and D14(24) Emergency Diesel Generators to supply power to unit 4KV Safeguards Buses.AND 3. Failure to restore power to at least one unit 4KV Safeguards bus in< 15 minutes from the time of loss of both offsite and onsite AC power.x No Change --' Difference 1: Deviation 1) Listed site specific equipment to ensure timely classification.

Page 41 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU2 Initiating Condition:

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

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

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

4,5, D Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit 4KV Safeguards Buses reduced to only one of the following power sources for > 15 minutes.* 101 Safeguards Transformer

201 Safeguards Transformer

D11(21) Diesel Generator* D12(22) Diesel Generator* D13(23) Diesel Generator* D14(24) Diesel Generator AND 2. ANY additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS.E No Change 1:] Difference r-1 Deviation 1) Listed site specific equipment to ensure timely classification.

Page 42 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification CAS Initiating Condition

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

Cold Shutdown, Refueling Example Emergency Action Levels: 1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

Internal or external flooding event High winds or tornado strike* FIRE* EXPLOSION ( (site-specific hazards)Other events with similar hazard characteristics as determined by the Shift Manager AND b. EITHER of the following:

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

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

4,5 Emergency Action Level (EAL): 1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* Other events with similar hazard characteristics as determined by the Shift Manager AND 2. EITHER of the following:

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

Page 43 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU4 U3 D No Change D Dfeec eito Initiating Condition:

UNUSUAL EVENT Initiating Condition:

Lgc Loss of Vital DC power for 15 minutes or longer. Loss of Vital DC power for 15 minutes or longer. 1) Listed site specific voltage and equipment to ensure timely classification.

Operating Mode Applicability:

2) Removed the word "indicated" this will allow for an indication problem to not Cold Shutdown, Refueling 4, 5 cause confusion on the need to declare.Example Emergency Action Levels: Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Event promptly upon Note: determining that 15 minutes time has been exceeded, or will likely be exceeded.

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 less than (site-specific bus voltage value) on required Vital DC buses for 15 minutes or longer.Voltage is < 105 VDC on required 125 VDC battery busses 1(2)FA, FB, FC, and FD for > 15 minutes.Page 44 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU5 Initiating Condition:

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

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

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

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

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

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

E No Change 1 Difference 1 Deviation 1) Listed site specific communications methods to ensure timely classification Thble Cl Cammunicntion~

C~nahilltv System Onsite Offsite NRC Station Radio X Plant Public Address (PA) X Prelude System X X Station Phones X X X Satellite Phones X X X NARS X HPN X X ENS X X Page 45 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA3 CA5 -NChne Dfeec Deito Initiating Condition:

ALERT Initiating Condition:

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

Inability to maintain plant in cold shutdown.

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

Operating Mode Applicability:

site-specific pressure reading to ensure timely classification.

Cold Shutdown, Refueling 4, 5 Example Emergency Action Levels: (1 or 2) Emergency Action Level (EAL): Note: The Emergency Director should declare the Alert promptly upon Note: determining that the applicable has been exceeded, or will likely be de exceededThe Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit) for greater than the duration specified in the following table. 1. UNPLANNED rise in RCS temperature

> 200 0 F due to loss of decay 2. UNPLANNED RCS pressure increase greater than (site-specific pressure heat removal for > Table C2 duration.reading). (This EAL does not apply during water-solid plant conditions.

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

[PWR])Not Intact (or at Established 20 minutes* Not Established 0 minutes reduced inventory[PWR]) Not Established 0 minutes If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not If an RCS heat removal system is in operation within this time frame and applicable.

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

OR 2. UNPLANNED RPV pressure rise > 10 psig as a result of temperature rise due to loss of decay heat removal.Page 46 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU3 CU5 N a De Initiating Condition:

UNUSUAL EVENT Initiating Condition:

1:j No Change Difference Deviation UNPLANNED increase in RCS temperature.

UNPLANNED rise in RCS temperature.

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

Operating Mode Applicability:

to ensure timely classification.

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

[PIVR] or RPV 1. UNPLANNED rise in RCS temperatureo>

20lF due to loss of decay[614q]) level indication for 15 minutes or longer. heat removal.OR 2. Loss of the following for >16 minutes." ALLRCS temperature indications AND" ALLRPV water level indications Page 47 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification CG1 Initiating Condition:

GENERAL EMERGENCY Loss of (reactor vessel/RCS

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

Operating Mode Applicability:

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

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

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

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

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

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

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

Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1 a. RPV water level 4 -161 Inches (TAF) flr > 30 minutes.AND b. ANY Containment Challenge Indication (Table C4)OR 2. a. RPV water level unknown for > 30 minutes.AND b. Core uncovery is indicated by ANY of the following:

Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Table C5 Refuel Floor Area Radiation Monitor >3 Ryhr.AND c. ANY Containment Challenge Indication (Table C4)H No Change Z Difference D Deviation 1) Listed site specific levels, radiation monitors, and sumps and tanks to ensure timely classification.

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

3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Table C3 Indications of RCS Leakage UNPLANNED floor or equipment sump level rise*UNPLANNED Suppression pool level tise'UNPLANNED vessel make up rate rise Observation of leakage or inventory loss'Rise in level is attributed to a loss of RPV inventory.

£ ________Table: Containment Challenge Table" CONTAINMENT CLOSURE not established*" (Explosive mixture) exists inside containment" UNPLANNED increase in containment pressure" Secondary containment radiation monitor reading above (site-specific value) [BWR]if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not reouired.Table C4 Containment Challenge Indlcatlons Primary Containment Hydrogen Concentration

> 6% and Oxygen > 0%UNPLANNED rise in containment pressure CONTAINMENT CLOSURE not established*

ANY Secondary Containment radiation monitor , T-1031 SAMP Max Safe Op Value (MSOI.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.Table C5 Refuel Floor ARM'e RIS29-Mt-1(2)K600, Drywell Head Laydown* RIS30-Mt-1(2)K600, Dryer I Separator Area RIS31-Mi-I(2)K600, Spent Fuel Pool RIS32-Mt-1(2)K600, New Fuel storage Vault* RIS33-Mlt-l(2)K6D0, Pool Plug Laydown Page 48 of 66 NEI 99-01 Rev 6 [ Proposed EAL I Justification CS1 Initiating Condition:

SITE AREA EMERGENCY Loss of (reactor vessel/RCS

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

Operating Mode Applicability:

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

AND b. (Reactor vessel/RCS

[PWR] or RPV [Bl4R]) level less than (site-specific level).2. a. CONTAINMENT CLOSURE established.

AND b. (Reactor vessel/RCS

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

[PWR] or RPV [BI4.R]) level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following:

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

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

CS6 Initiating Condition:

Loss of RPV inventory affecting core decay heat removal capabilities.

Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. With CONTAINMENT CLOSURE not established, RPV water level < -129 inches.OR 2. With CONTAINMENT CLOSURE established, RPV water level < -161 inches (TAF)OR 3. a. RPV water level unknown for > 30 minutes AND b. Core uncovery is indicated by ANY of the following:

Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* ANY Table C5 Refuel Floor Area Radiation Monitor >3 R/hr.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.

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

2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Table CS Refuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown* RIS30-M1-1(2)K600, Dryer / Separator Area* RIS31-M1-1(2)K600, Spent Fuel Pool* RIS32-M1-I(2)K600, New Fuel storage Vault* RIS33-M1-1(2)K600, Pool Plug Laydown Page 49 of 66 NEI 99-01 Rev 6 [ Proposed EAL I Justification CA1 Initiating Condition:

ALERT Loss of (reactor vessel/RCS

[PWR] or RPV [BI/R]) inventory Operating Mode Applicability:

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

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

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

[PWR] or RPV [BWR]) inventory.

CA6 Initiating Condition:

Loss of RPV inventory Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of RPV inventory as indicated by level < -38 inches.OR 2. a. RPV water level unknown for> 15 minutes.AND b. Loss of RPV inventory per Table C3 indications.

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

H No Change W Difference 1 Deviation 1) Listed site specific levels, and sumps and tanks to ensure timely classification.

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

UNUSUAL EVENT UNPLANNED loss of (reactor vessel/RCS

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

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

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

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

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

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

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

D No Change E Difference

--- Deviation 1) Described "a required lower limit" as a procedurally established lower limit, and listed site specific sumps and tanks to ensure timely classification.

2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.

Page 51 of 66 NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL Justification HG1 HG1 Initiating Condition:

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

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

AND b. EITHER of the following:

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

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

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

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

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

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

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

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

HSI Initiating Condition:

HOSTILE ACTION within the Protected Area.M No Change 1 Difference I Deviation 1) List site security shift supervision as Security Force.Operating Mode Applicability:

1,2, 3,4, 5, D Emergency Action Level (EAL): A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.Page 53 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HAI HAI Initiating Condition:

ALERT Initiating Condition:

F No Change Difference Deviation HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack 1) List site security shift supervision as Security Force.threat within 30 minutes. threat within 30 minutes.Operating Mode Applicability:

Operating Mode Applicability:

All 1,2, 3, 4, 5, D Example Emergency Action Levels: (1 or 2) Emergency Action Level (EAL): 1. A HOSTILE ACTION is occurring or has occurred within the OWNER 1. A validated notification from NRC of an aircraft attack threat < 30 minutes CONTROLLED AREA as reported by the (site-specific security shift from the site.supervision).

2. A validated notification from NRC of an aircraft attack threat within 30 OR minutes of the site.2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.Page 54 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HU1 HUl r---] m ifrne eito Initiating Condition:

UNUSUAL EVENT Initiating Condition:

LHU No Change M Difference FJ Deviation Confirmed SECURITY CONDITION or threat.Confirmed SECURITY CONDITION or threat. 1) List site security shift supervision as Security Force.Operating Mode Applicablity:

Mode Applicability:

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

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

1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.

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

SITE AREA EMERGENCY Initiating Condition:

L[ No Change M Difference LJ Deviation Inability to control a key safety function from outside the Control Room. Inability to control a key safety function from outside the Control Room. 1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedures the Control Room would enter should such an Operating Mode Applicability:

Operating Mode Applicability:

event occur, this allows for greater clarity as to when this EAL would apply than if each panel and station used in alternate shutdown were to be listed, All 1,2, 3,4, 5,0D 2) Added descriptors to better explain each safety function and allow for a timely classification.

Example Emergency Action Levels: (1 and 2) Emergency Action Level (EAL): Note: The Emergency Director should declare the Site Area Emergency promptly Note: 3) Changed "An event" to" A Control Room evacuation" to remove confusion if upon determining that (site-specific number of minutes) has been partial plant control was transferred to outside the control room with the control exceeded, or will likely be exceeded.

The Emergency Director should declare the event promptly upon determining that room still manned, due to testing or equipment failure.the applicable time has been exceeded, or will likely be exceeded.1. An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control stations).

1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per: 2. Control of ANY of the following key safety functions is not reestablished

.SE-i, Remote Shutdown within (site-specific number of minutes).

OR SReactivity control .SE-6, Altemate Remote Shutdown Core cooling [PWR] / RPV water level [BWyR] AND* RCS heat removal 2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table HI Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Page 56 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA6 HA2 mF Initiating Condition:

ALERT Initiating Condition:

LF No Change M -J Difference

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

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

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

Operating Mode Applicability:

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

Control Room to alternate locations per: " SE-1, Remote Shutdown OR" SE-6, Alternate Remote Shutdown Page 57 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HU4 HU3 Initiating Condition:

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

Initiating Condition:

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

1,2, 3, 4, 5, D I-X- No Change FIDifference FIDeviation

1) Listed site specific list of plant rooms or areas that contain SAFETY SYSTEM equipment to ensure timely classification.

All Example Emergency Action Levels: (1 or 2 or 3 or 4)Note: The Emergency Director should declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:

Report from the field (i.e., visual observation)

Receipt of multiple (more than 1) fire alarms or indications

Field verification of a single fire alarm AND b. The FIRE is located within ANY of the following plant rooms or areas: (site-specific list of plant rooms or areas)2. a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).AND b. The FIRE is located within ANY of the following plant rooms or areas: (site-specific list of plant rooms or areas)AND c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.3. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.

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

Emergency Action Level (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of the following FIRE detection indications:

Report from the field (i.e., visual observation)

Receipt of multiple (more than 1) fire alarms or indications

Field verification of a single fire alarm Table H2 Vital Areas* Reactor Enclosure (when inerted the drywell is exempt)* Control Enclosure* Diesel Generator Enclosure* Spray Pond Pump House / Spray Network OR 2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).AND b. The existence of a FIRE is not verified in< 30 minutes of alarm receipt.OR 3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.

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

Page 58 of 66 NEI 99-01 Rev 6 j Proposed EAL I Justification HU2 HU4 Initiating Condition:

UNUSUAL EVENT Seismic event greater than OBE levels.Operating Mode Applicability:

Initiating Condition:

Seismic event greater than OBE levels.Operating Mode Applicability:

1, 2,3, 4, 5, D F' No Change F Difference FIDeviation

1) Provided site specific indications to aid in timely classification.

All Example Emergency Action Levels: Seismic event greater than Operating Basis Earthquake (OBE) as indicated by: a. (site-specific indication that a seismic event met or exceeded OBE limits)Emergency Action Level (EAL): Seismic event > Operating Basis Earthquake (OBE) as indicated by: " ARC-MCR-00C693, WINDOW B1, OBE EXCEEDED alarmed OR" OBE red light is lit at panel 00C693 Page 59 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HAS Initiating Condition:

ALERT Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

All Example Emergency Action Levels: 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 .a. Release of a toxic, corrosive, asphyxiant or flammable gas into any of the following plant rooms or areas: (site-specific list of plant rooms or areas with entry-related mode applicability identified)

AND b. Entry into the room or area is prohibited or impeded.HAS Initiating Condition:

Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

1, 2, 3,4, 5, D Emergency Action Level (EAL): Note: If the equipment in the 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 a Table H3 area.Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Enclosure*

Modes 3, 4, and 5*Areas required to establish shutdown cooling AND 2. Entry into the room or area is prohibited or impeded H No Change FIDifference FIDeviation

1) Listed plant specific rooms and areas with entry related mode applicability to ensure timely classification.

Page 60 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification HU3 HU6 Initiating Condition:

UNUSUAL EVENT Hazardous Event Initiating Condition:

M No Change F Difference F Deviation 1) No site specific list of natural or technological hazard events was noted.Operating Mode Applicability:

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

1. A tornado strike within the PROTECTED AREA.2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode.3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.5. (Site-specific list of natural or technological hazard events)Hazardous Event Operating Mode Applicability:

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

1. Tornado strike within the PROTECTED AREA.OR 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode.OR 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).OR 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.Page 61 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification HG7 HG7 M No Change I Difference FIDeviation Initiating Condition:

GENERAL EMERGENCY Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency.

Operating Mode Applicability:

All Example Emergency Action Levels: 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 off-site for more than the immediate site area.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, 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 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 off-site for more than the immediate site area..Page 62 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

SITE AREA EMERGENCY Initiating Condition:

LSi No Change [j Difference

[j Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency.

declaration of a Site Area Emergency.

Operating Mode Applicability:

All 1,2, 3,4, 5, D Example Emergency Action Levels: Emergency Action Level (EAL): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely mao Other conditions exist which in the judgment of the Emergency Director indicate l y major 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 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 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 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 access to equipment needed for the protection of the public. Any releases are not Guiexp netedtoresultn exposure levels wthextebudEPaPr oexpected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Guideline exposure levels beyond the site boundary.Page 63 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA7 HA7 Initiating Condition:

ALERT Initiating Condition:

L-M No Change F Difference 1 Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert. declaration of an Alert.Operating Mode Applicability:

Operating Mode Applicability:

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

UNUSUAL EVENT Initiating Condition:

L-i No Change U Difference

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

Operating Mode Applicability:

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

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

UNUSUAL EVENT Initiating Condition:

Li No Change M Difference F Deviation Damage to a loaded cask CONFINEMENT BOUNDARY.Damage to a loaded cask.CONFINEMENT BOUNDARY.

1) Listed 2x the site specific cask specific allowable radiation level as per Limerick Generating Station ISFS1 1OCFR72.212 Evaluation Rev 6 Attachment 1 certificate Operating Mods Applicability:

Operating Mode Applicability:

of Compliance evaluation.

All 2) Not all technical specification radiation readings were on contact, one is a 1, 2, 3, 4, 5, D radiation reading at 3ft required by technical specification.

Modified the EAL by removing the "on the surface" requirement, and required "a radiation reading" Example Emergency Action Levels: allowing for the technical specification 3ft reading to be added to the EAL.Emergency Action Level (EAL): Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a technical specification allowable radiation level) on the surface of the spent fuel radiation reading: cask.* > 1400 mremlhr on the HSM or HSM-H front surface (applicable to type 1 61BTH DSC only)OR* > 800 mrem/hr at 3 ft from the HSM surface (applicable to 61 BT DSC only)OR* > 200 mremlhr on the HSM or HSM-H door centerline OR* > 40 mremlhr on the end shield wall exterior Page 66 of 66 Limerick Generatina Station Annex Exelon Nuclear L..m.ri.k.Ge.eratina Statio.AnnexE....nNucle.

RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARGI Initiating Condition:

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

1, 2, 3, 4, 5, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the General m=F.ergenGy event promptly upon I 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) Reading o,; 'n ANY o-f t.he following radiation monitorS greater thaR the reading shown fr15- minute or loner: (site specific monitor list and threshold values)1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes: Table R1 Effluent Monitor Thresholds Release Path General Emergency North Stack (WR Monitor: RIX-26-076-4) 1.92 E+08 uCi/sec South Stack (Unit 1: RY26-185A-3

/ 2.71 E-01 uCi/sec RY26-185-B-3 or Unit 2: RY26-285A-3

/RY26-285-B-3)

OR 2. Dose assessment using actual meteorology indicates doses at or beyond (site-speGifir dc.e rFecoptr point) the site boundary of EITHER: Month 20XX LGS 3-1 EP-AA-1008 (Revision XX)

I .imnri,.k

(' Znghreafnr -Q*~m;len A nnnv I::v, Inn , ir-l,-ar bulllt~i111 1 -V III If I;II ll b4Ul l l*~q u l RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS a. > 1000 mRem TEDE OR b. > 5000 mRem CDE Thyroid ORr-1810 SUrFe'; reSURS naicate ' .., ,,v, ,, n oWIng a! or DeYA ,cl. e v p,,... C dose roceptor point):ýL_ --A ^^^ -#-% It--A _J L L!_ z 160 minu-tes-or longer.vu~~vv -ww l V. 1A v i v u .~ v l v v v V l~ .* tHCn1nbW_1

_. MMl NU -VV3 tlV tF- 9106 tf tHC*HV l i de l V t nld H I n for one hou r of inhalation.

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.

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 mRrem while the 5000 mRfem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Classification based on efflent maontor readings assumes~ that a releanre path to th enirnent is established.

if the effluent flow past an effluent monGitor is known to hav ,stopped due to- a-c-tions to ilate the release path, th;n the monitor rAFeadn is no.nAer Valid for cl.assific.ation Du ses.Month 20XX LGS 3-2 EP-AA-1008 (Revision XX)

I imarirnk r-anarnting Rt~ation Annex Exellon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis Reference(s):

1. NEI 99-01 Rev 6, AG1 2. LGS ODCM 3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Limerick Generating Station 4. DBD L-S-43, Radiation Monitoring System Month 20XX LGS 3-3 EP-AA-1008 (Revision XX)

I im rele9n nofn Q nin n n P:v--Itnn Ik .l-A nr I r~-L tna~* nn~f*nnAn~v...

.n .a.se t..r ...,..*.~.RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARS1 Initiating Condition:

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

1, 2, 3, 4, 5, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the v.it.oArAea 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) Reading on ANY of the foelowing Fadiation mo~nitors greater than the_ reading shown fo-r 1 5 minlute Or logqer: (Site Specific_

mo-nitor list and threshold

':alue6)(2) Dorse assessment using ac-tual meteorology indicates doses greater than 100Q mreAm TEE r, O1500 mr;em; thyroid CDE At Or beyond (site specific dose recepto (3) Field suivey results- iniaeETHEROf the9 folloIwing at Or beyond (Site specific dose rcpOR O;n~" Closed v.'ndow dose rates greater- than 100 mR'hr expected to continufe for- 60 mainutes er- lnger-" Analyses of field survey samples indicate thyroeid CDE greater- than 500 ffrem for- one h10ur Of ifihala~tio.

Month 20XX LGS 3-4 EP-AA-1008 (Revision XX)

Ii m rie- ( Zanghaf5inn -Q*a*rnn Anna-w I::y,-I~n RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes: Table RI Effluent Monitor Thresholds Release Path Site Area Emergency North Stack (WR Monitor: RIX-26-076-4) 1.92 E+07 uCi/sec South Stack (Unit 1: RY26-185A-3

/ 2.71 E-02 uCi/sec RY26-185-B-3 or Unit 2: RY26-285A-3

/RY26-285-B-3)

OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 100 mRem TEDE OR b. > 500 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >100 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.

Basis: This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).It includes both monitored and un-monitored releases.

Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs Month 20XX LGS 3-5 EP-AA-1008 (Revision XX)

I irngri#-L-f'-gsnghrimfin Qfmfirn Annghv I::valnn ld, I iy~r.., ~~i~~*hi, Annv vannM~,.az RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1000 mRfem while the 500 mRfem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Classification bassed On fM'unt mnitor rFeadines assumes that a release oath to the eny.;irnment.

i. eabise. If th..

flo.., past an effluent monQ.itor is knoWn to havestoped due to actions, to isolate the release path, then the effluent monitor readin is no loner valid for. classific-atio pupoes Escalation of the emergency classification level would be via IC RAG1.Basis Reference(s):

1. NEI 99-01 Rev 6, AS1 2. LGS ODCM 3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Limerick Generating Station 4. DBD L-S-43, Radiation Monitoring System Month 20XX LGS 3-6 EP-AA-1008 (Revision XX)

Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARAI Initiating Condition:

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

1, 2, 3, 4, 5, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the Afe44-vent 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.

for: 1 5 minlutes Or longer: (site Specific monitor list and threshold values)(2) Dose assessment using actual mneteorology indicaters dosos6 greater than 10 Qmnero TEDE Or 50 mrcrn thyroid OIDE at Or beyond (Site specific dose Freeptor point).(3) Analysis of a liquid effluen;t " amp. e iRdicates-a on-entration Or release rate that would result ir doses, greateF than 10 FFFm TEDE Or 50 mnenm thyroid ODE ator beyond (site specific dose Freeptor point) for one hour Of exposure (4) Field survey Fresults indicate EITHER of the follew.ing at Or beyond (site specific dose... re..,eptor., " Closed vindo dose rates greater- than 10 mR:, expe.ted to continue for 60 minutes or-" Analyses of field sun.'ey samples indicate thyroid CDE greater- than 50 mremn for- oem hourL of inhalation.

Month 20XX LGS 3-7 EP-AA-1008 (Revision XX)

ExAIon Nuclear Limeric~k Generatina Station Annex Exelnn Nuclea~r RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15 minutes.Table R1 Effluent Monitor Thresholds Release Path Alert North Stack (WR Monitor: RIX-26-076-4) 1.92 E+06 uCi/sec South Stack (Unit 1: RY26-185A-3

/ 2.71 E-03 uCi/sec RY26-185-B-3 or Unit 2: RY26-285A-3

/RY26-285-B-3)

OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 10 mRem TEDE OR b. > 50 mRem CDE Thyroid OR 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary: a. 10 mRem TEDE for 60 minutes of exposure OR b. 50 mRem CDE Thyroid for 60 minutes of exposure OR 4. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for > 60 minutes.OR Month 20XX LGS 3-8 EP-AA-1008 (Revision XX)

I imarink fllanamfinn Atntinn AnnaX IExelon Nuclear I imrirk (~arninn tatnn An~vExelon Nucla~r RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.

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 mRfem while the 50 mRrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Classificaation b-ased- On e-fflue'n t Mon-itor readings assumes. that. a rele9ase path toD the enVironment is established.

if the effluent flow past- an effluent moenitor is known to have stopped due to actions to iotethe release path, then the effluent moenitor reading isr no longer valid for classificatio pupse-.Escalation of the emergency classification level would be via IC RAS1.Basis Reference(s):

1. NEI 99-01 Rev 6, AA1 2. LGS ODCM 3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Limerick Generating Station 4. L-S-43 Radiation Monitoring System 5. ARC-BOP-0AC304 C1 Liquid Radwaste Discharge Rad Monitor Hi Hi 6. ARC-MCR-003 El North Stack Hi-Hi Radiation 7. ARC-MCR-003 F1 Units 1&2 South Stack Hi-Hi Radiation 8. EP-EAL-0615 Revision 0, Limerick Criteria for Choosing Radiological Liquid Effluent EAL Threshold Values Month 20XX LGS 3-9 EP-AA-1008 (Revision XX)

I imprink rionarating Station Annay EXPInn Nuclea~r I im~riv~k (~Anar2tinn

~hatinn Ann~v FvAInn N.ir~Ia~ar RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARUI Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM (site-speraft effluent .,leae controlling document) limits for 60 minutes or longer.Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the Unusual Event event promptly upon determining that 60 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 effluent radiation monitor greater than 2 times the (site specific effluent release controlling document) limits for 60 lmin utes orlong: (site specific-mo-nitor list and- threshold valuer- corresponding to 2 times the con~trolling document limits)(2) Reading onI ANY e-fflue-Ant-radi-ation moni~tor greater than 2 times the alaFrm Setpon eta-blise a urn rad-ieactivit' discharge peFrmit for 60 minRutes Or Ienger.(3) Sample analysis for a gaseous Or liquid release indicates a concentration or release ratle greater than 2 times the (site specific.

effluent release centrol~ing docum~ent) limits6 for 690 Mminutes6 Or longer.1. Reading on ANY of the following effluent monitors > 2 times alarm setpoint established by a current radioactive release discharge permit for > 60 minutes." Radwaste Discharge Effluent Monitor (RR63-0R001)

OR" Discharge Permit specified monitor OR Month 20XX LGS 3-10 EP-AA-1008 (Revision XX)

IFvplnn I imgprirk Ganar~afing Stgation AnnexFA~nNIdm RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS 2. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 60 minutes: Table R1 Effluent Monitor Thresholds 1 Release Path Unusual Event North Stack (WR Monitor: RIX-26-076-4) 2.20 E+04 uCi/sec South Stack (Unit 1: RY26-185A-3

/ 3.09 E-05 uCi/sec RY26-185-B-3 or Unit 2: RY26-285A-3

/RY26-285-B-3)

OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.Basis: This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release).

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

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

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

Classification base-d on effluent Monitor reandings assumes that. a release patht the enVironment is established.

If the effluent floW past An effluet monitor is known have stopped duo to actions to isolate the release path, theni the effluent moneitor Feading i s no longer valid for classificatiopuos.

Releases should not be prorated or averaged.

For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.EAL #1 Basis: EAL #2 1 This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This Month 20XX LGS 3-11 EP-AA-1008 (Revision XX)

Limerick Generatinq Station Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS 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:&AL-#1-I-This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous OFIli id-effluent pathways.EAL #3 Basis: EA&-# ---This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Escalation of the emergency classification level would be via IC RAA1.Basis Reference(s):

1. NEI 99-01 Rev 6, AU1 2. LGS ODCM 3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Limerick Generating Station 4. L-S-43 Radiation Monitoring System 5. ARC-BOP-0AC304 Cl Liquid Radwaste Discharge Rad Monitor Hi Hi 6. ARC-MCR-109 A2 1 Service Water Rad Monitor Hi-Hi 7. ARC-MCR-01 1 C-4 RHRSW Rad Monitor Hi-Hi 8. ARC-MCR-003 El North Stack Hi-Hi Radiation 9. ARC-MCR-003 F1 Units 1&2 South Stack HI-Hi Radiation Month 20XX LGS 3-12 EP-AA-1008 (Revision XX)

Limerick Generatinn Station Annex Exeoln NucleI~ar RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARA2 Initiating Condition:

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

1, 2, 3, 4, 5, D Emergency Action Level (EAL): (1) Uncover; Of -rradiated fuel in the REFUELING PATH\AIAY.

(2) Damage to ir.adiatod fuel reSUlting in a f radioactivity from the fuel as indicated by ANY Of the followA~ing radiation mon9itors: (site specific listing of radiation monitors, and the associated readings, setpoints and/or alarms)(3) Lowering of spcnt fuel pool level to (site spec-ific.

Level1 2 Value). [See DeveIýGF 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 mRemlhr Table R2 Refuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown" RIS30-Ml-1(2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool" RIS32-Ml-1(2)K600, New Fuel storage Vault" RIS33-Ml-1(2)K600, Pool Plug Laydown Month 20XX LGS 3-13 EP-AA-1008 (Revision XX)

I=xelon N.dear Limeric~k Generatinn Station Annex Exelon Nucla~r RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS 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.CONFINEMENT BOUNDARY:

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

This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly., o. a ,igifant of w.ater le...l .,,ithi, th. spent fU.l p99l (,Se.eveloe " 'tes). These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment.

As such, they represent an actual or potential substantial degradation of the level of safety of the plant.This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1.Escalation of the emergency would be based on either Recognition Category AR or C ICs.EAL #1 Basis: This EAL escalates from RAU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters.

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

While an area radiation monitor could detect an iGF-easerise 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.Month 20XX LGS 3-14 EP-AA-1008 (Revision XX)

I imariunk r~anarnfinni At~tinn Annoy Fvalnn Nin~ilcanr RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 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 RA-or C ICs.r-AI= .#/Spent fuel pool water IlVel at vValu IVV W ithi thI loWer end of the level range neressary to prevet Signifcant dseo c q s- from direct gamma radiation to personnel performing oprations in the Vicinity Of the Spent fuel pool. ThiA cndi Erefle loss of spent fuel p oolwater, inventeor; and thus it is , a to a loss of the ability to adequately GOOl the_ irradiatcAd-fuel A-1ssrem.bles storFed in the pol EscalationA of the Femqergeny cl9assification levelI Would be via I~rc As! Or AS2 (seeAS Develop- Notes).Basis Reference(s):

1. NEI 99-01 Rev 6, AA2 2. ON-120 Fuel Handling Problems 3. DBD L-S-43, Radiation Monitoring System 4. ARC MCR 112-15 Fuel Pool Storage Hi/Lo Level 5. DBD L-S-16, Reactor Instrumentation System (RIS)6. DBD L-S-52, Fuel Pool Cooling and Cleanup System Month 20XX LGS 3-15 EP-AA-1008 (Revision XX)

I imimri&-I, fI-anPA*;fhin Qa*o;i#n A uimiv I:,=dlrn khig-l-nr I..IIUIU~r~~EU E IIh~4~~ E E 1II ~* flU~U*as ~ ~RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARU2 Initiating Condition:

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

1, 2, 3,4, 5, D Emergency Action Level (EAL): (1) a. UNPLANNED water leve el dr OpR the REFUELING PATHWAY as indicated by ANY of the followwin: (site specifc level indications).

b. UNPLANNED rise iea radiation leovel as indicated by ANY of the fooin-14AAg radiation monitors.(site specific list of area radi-ation moenitors) 1 .UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following: " Refueling Cavity water level < 484 inches.OR" Spent Fuel Pool level < 23 feet above seated irradiated fuel.OR* Indication or report of a drop in water level in the REFUELING PATHWAY.AND 2. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R2.Month 20XX LGS 3-16 EP-AA-1008 (Revision XX)

ExAIon Simeric~k Goneartinn Station Annex Exelnn Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Table R2 Refuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown" RIS30-Ml-1(2)K600, Dryer / Separator Area* RIS31-M1-1(2)K600, Spent Fuel Pool" RIS32-M1-1(2)K600, New Fuel storage Vault* RIS33-M1-1(2)K600, Pool Plug Laydown 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 dereaseeloss 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 deGrease loss will be primarily determined by indications from available level instrumentation.

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

A significant drop in the water level may also cause a; inAeaserise in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered.

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

Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RAA2.Basis Reference(s):

Month 20XX LGS 3-17 EP-AA-1008 (Revision XX)

I imnrir-L, ('2nnewnfin Qfnfien Anngv Iygilen Mm-rlonr I ;~~n~sL (~n~r~1* int $$rn n vFv n mr~a.n .. ... tt***5 *1-. U .RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 1. NEI 99-01 Rev 6, AU2 2. Technical Specifications 3.9.8 3. ON-120 Fuel Handling Problems 4. DBD L-S-16, Reactor Instrumentation System (RIS)5. DBD L-S-52, Fuel Pool Cooling and Cleanup System 6. ARC MCR 112-15 Fuel Pool Storage Hi/Lo Level 7. GP-6.1 U/1(2) Shutdown Operations

-Refuel Core Alterations

& Core Off-loading Month 20XX LGS 3-18 EP-AA-1008 (Revision XX)

I imprink rpnarafinn Afafinn Annoy I=xAInn N.nlAar I imrir~ (~n~rzainn tsa~nn An~vExelnn Nucledar RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARA3 Initiating Condition:

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

1, 2, 3, 4, 5, D Emergency Action Level (EAL): Note: If the equipment in the listed-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 greater than 15 mR/hr in ANY of the following areas:b*Centre l -o M nonoR* Central Alarm Station-(ysuvy OR pecific afeas/roomn)

(2) An UNPLANNED ev:ent results in radiation levels that prohibit Or impe-de accr-ess o any of the following plant rooms or areas:.(site specific list of plant rooms or areas with cntr,' related moede appliabilityl identfed)1. Dose rate gFeatefkhaf1>

15 mRlhr in ANY of the areas contained in Table R3: Table R3 Areas Requiring Continuous Occupancy" Main Control Room" Central Alarm Station -(by survey)OR Month 20XX LGS 3-19 EP-AA-1008 (Revision XX)

Limerick Generating Station Annex I=xelon Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the areas contained in Table R4: Table R4 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Enclosure*

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

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

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

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

Table 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 serviccat the time of the elevated radiation 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 Month 20XX LGS 3-20 EP-AA-1008 (Revision XX)

Limerick Generating Station Annex I=xelon Nuclear Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS 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 ie 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)." The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category RA, C or F ICs.Basis Reference(s):

1. NEI 99-01 Rev 6, AA3 2. UFSAR Table 7.7-2, Locations for Area Radiation Monitor Sensors 3. SE-1 Remote Shutdown 4. SE-6 Alternate Remote Shutdown 5. SE-8 Fire 6. DBD L-S-43, Radiation Monitoring System Month 20XX LISS 3-21 EP-AA-1008 (Revision XX)

Limerick Generatina Station Annex Exelon Nuclear Limerick .en .ra..n Station...

Annex.........n.Nuc..e..

RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS SRU3 Initiating Condition:

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

1,2,3 Emergency Action Level (EAL): (1) (Site specifc radiation monitor) reading greater than (site 6pecific ':alue).7 (2) Sample analysis indicates that a reactor coolant activity value i6 greater than an allo~Wabeiit speciflod-in Tec-hnical Specifications.

1. Air Ejector discharge radiation monitor (RISH 26 1(2)K601A, B) Hi-Hi alarm.OR 2. Specific coolant activity > 4.0 uCllgm Dose equivalent 1-131.Basis: This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications.

This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel clad degradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity.

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

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

1. NEI 99-01 Rev 6, SU3 2. Technical Specifications 3.4.5, Specific Activity 3. Technical Specifications 3.4.5, Basis 4. UFSAR Table 11.5-1, Process and Effluent Radiation Monitoring Systems 5. DBD L-S-43, Radiation Monitoring System 6. ARC MCR 109-G1, Air Ejector Offgas Discharge HI-HI Radiation Month 20XX LGS 3-22 EP-AA-1008 (Revision XX)

Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FG1 Initiating Condition:

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

1,2,3 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers.At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX LGS 3-23 EP-AA-1008 (Revision XX)

Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FS1 Initiating Condition:

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

1,2,3 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX LGS 3-24 EP-AA-1008 (Revision XX)

Fxelnn NuclAar Limeric~k Goner~atinn Stsation Annex FEceInn Nuicleazr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FA1 Initiating Condition:

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

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

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

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX LGS 3-25 EP-AA-1008 (Revision XX)

I imarink ronarnfinn Af2finn Annoy I=Yalnn Ninrlmar I imairit~k

(~nn~rntinn

~t2tinn Ann~w Fvalnn fI.ur~Io2r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1 Initiating Condition:

RCS Activity Operating Mode Applicability:

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

LOSS A. (Site:Specific ind-ications that reactor coolant activity is greater than 300u~ilgm dos eq,,ivaleRt-1 3!)Coolant activity > 300 uCi/gm Dose Equivalent 1-131.Basis: This threshold indicates that RCS radioactivity concentration is greater than 300 I4Ci/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete.

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

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

1 .NEI 99-01 Rev 6, Table 9-F-2 Month 20XX LGS 3-26 EP-AA-1008 (Revision XX)

I imariek rZonarnfin Atnfinn Annoy Pwi::nn NiAalnr I im~rirk (~nbr2tinn

~t2*inn Ann~v Fv~Inn hi.IuI~2r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 Initiating Condition:

RPV Water Level Operating Mode Applicability:

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

LOSS A-.-1. Plant conditions indicate Primary Crontainment flooding is required.POTENTIAL LOSS A-.2. RPV water level cannot be restored and maintained above (sate .pei..c RPV...ateF level c.r...ponding to the top of ,;,cie fuel)> -161 inches (TAF)Gr-OR 3. RPV water level cannot be determined.

Basis: Loss 2-AThreshold

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

Potential Loss 2-AThreshold

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

This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV wate RPV water level cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization.

EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, Month 20XX LGS 3-27 EP-AA-1008 (Revision XX)

Fvl:YInn iNnelon=r I impriink riona~rsainn Rtfatinn Annaw FidnNt~~m RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this Fuel Clad barrier Potential Loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory.

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

For such events, ICs SA,-MA3 or SS5-MS3 will dictate the need for emergency classification.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. T-1 11 Level Restoration

/ Steam Cooling- BASES 3. T-1 17 Level/Power Control -BASES Month 20XX LGS 3-28 EP-AA-1008 (Revision XX)

N.clAar Simeric~k fleneratinn Staition Annex Exelnn Nuclanr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC5 Initiating Condition:

Primary Containment Radiation Operating Mode Applicability:

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

LOSS A. containment radiation monitor reading greater than (site spocific value)Drywell radiation monitor reading > 1.90 E+02 R/hr.Basis: Less-4.The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals 300 jiCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCS Barrier RC5 Loss Tthreshold4A 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.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. Core Damage Assessment Methodology

3. Technical Specifications Table 3.3.7.5-1, Accident Monitoring Instrumentation

4. DBD L-S-43, Radiation Monitoring System 5. ST-2-026-418-1 Accident Monitoring

-Primary Containment Post -LOCA Radiation Division III Calibration (RE-26-191A)

6. ST-0-026-640-*

Alternate Monitoring for Inop Post-LOCA Radiation Monitors Month 20XX LGS 3-29 EP-AA-1008 (Revision XX)

I imarink rpnarnfinn Atntinn Annow Pynilnn N"Morl=r liI Imgirilli ( Hngr~ inn itmil nn ll Ana FI nn NI urIIoi1 RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC7 Initiating Condition:

Emergency Director Judgment.Operating Mode Applicability:

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

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

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

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX LGS 3-30 EP-AA-1008 (Revision XX)

Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 Initiating Condition:

RPV Water Level Operating Mode Applicability:

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

LOSS 1. RPV water level cannot be restored and maintained above (site .pecific RPV water level ....o..n.i. g to the top of cte fue4)> -161 inches (TAF)Gr-OR 2. RPV water level cannot be determined.

Basis: Less-2-.This water level corresponds to the Ttop of Aactive Ffuel (TAF) and is used in the EOPs to indicate challenge to core cooling.The RPV water level threshold is the same as Fuel Clad baiieF Barrier FC2 Potential Loss threshold-2A.

Thus, this threshold indicates a Loss of the RCS barrier and Potential Loss of the Fuel Clad barrier and that appropriately escalates the emergency classification level to a Site Area Emergency.

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

The term, "cannot be restored and maintained above," means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a Month 20XX LGS 3-31 EP-AA-1008 (Revision XX)

I=xelon Nuclear I imarirnk (rancarninn Afntinn Annaxv Exelon Nucleanr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation beyond the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to the top of ativ,.-' fuel in order to reduce reactor power. RPV wAater IoeIe as then coentrolled between the top of active fue-l and tho MinimumA Stoamn Cooling R Water Level (GRVI.A.)-.

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

For such events, ICs SA5-MA3 or ,S5-MS3 will dictate the need for emergency classification.

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

1. NEI 99-01 Rev 6, Table 9-F-2 2. T-BAS, TRIPS / SAMPS -Bases 3. T 101, RPV Control 4. T-1 11, Level Restoration

/ Steam Cooling Month 20XX LGS 3-32 EP-AA-1008 (Revision XX)

I=xAInn NunlAar I imarirnk ryangarninn Station Annoy Exelnn NucleaIr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3 Initiating Condition:

Primary Containment Pressure Operating Mode Applicability:

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

LOSS A. Primar;;F containment pressure greater than (site Specific value) due to RCS leakage.1. Drywell pressure >1.68 psig.AND 2. Drywell pressure rise is due to RCS leakage Basis: The (site -p.cific 1.68 psig primary containment pressure is the drywe#Drywell high pressure setpoint which indicates a LOCA by automatically initiating the-ECCS-er equivalent makeup system.The second threshold condition focuses the fission product barrier loss threshold on a failure of the RCS instead of the non-LOCA malfunctions that may adversely affect primary containment pressure.

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

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

A stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered either identified or unidentified leakage by Technical Specification and, therefore, is not applicable to this EAL.There is no Potential Loss threshold associated with Primary Containment Pressure.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. T-101 RPV Control 3. T-102 Primary Containment Control -Bases Month 20XX LGS 3-33 EP-AA-1008 (Revision XX)

I imarielt (' Zonaratin Af2finn Annow IP:valn n N,,r-la~r I i~ri~k ~n~~*nn$ain nvFrI hiim RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC4 Initiating Condition:

RCS Leak Rate Operating Mode Applicability:

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

LOSS Al. UNISOLABLE Main Steam Line (MSL), HPCI, Feedwater, RWCU, or RCIC line break. iA ANY of

,,,,.ng (it;+ .....f ~ eM ..... poeta .. ..;+,,GF,+;, ...... ;,y OR 82. Emergency RPV Depressurization is required.POTENTIAL LOSS 3A. UNISOLABLE primary system leakage that results in EITHER of the following

a4. Secondary Containment area temperature

> T-103 1 SAMP, Max Norm Op Value (MNO)MA. -Ne Nrm'iaQ .pe.at+;, T e...peFatufe.

OR b2. Secondary Containment area radiation level > T-103 I SAMP, Max Norm Op Value (MNO)Max Normal Operating Area Radiation Level.Basis: UNISOLABLE:

An open or breached system line that cannot be isolated, remotely or locally.Classification of a system break over system leakage is based on information available to the Control Room from the event. Indications that should be considered are:* Reports describing magnitude of steam or water release.* Use of system high flow alarms / indications, if available,* Significant changes in makeup requirements,* Abnormal reactor water level changes in response to the event.The use of the above indications provides the Control Room the bases to determine that the on going event is more significant than the indications that would be expected from system leakage and therefore should be considered a system break.Month 20XX LGS 3-34 EP-AA-1008 (Revision XX)

I imariek rZonarnfin Afnfinn Annov F:valnn N~irhlnr I i~rt~kflnaratnn$atn nvFolnMuIr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Loss Threshold

1 Basis-3.Large high-energy lines that rupture outside primary containment can discharge significant amounts of inventory and jeopardize the pressure-retaining capability of the RCS until they are isolated.

If it is determined that the ruptured line cannot be promptly isolated from the Centrol Room, the RCS barrier Loss threshold is met.Loss Threshold

2 Basis-34.B Emergency RPV Depressurization in accordance with the EOPs is indicative of a loss of the RCS barrier. If Emergency RPV Depressurization is performed, the plant operators are directed to open safety relief valves (SRVs) and keep them open. Even though the RCS is being vented into the suppression pool, a Loss of the RCS barrier exists due to the diminished effectiveness of the RCS to retain fission products within its boundary.Potential Loss Threshold-

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

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

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

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

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

13,A (after a containment isolation) and a General Emergency when the Fuel Clad Barrier criteria is also exceeded.Month 20XX LGS 3-35 EP-AA-1008 (Revision XX)

I=xelon Nuclear I imprirck Genersatinn Sta~tion Annex Exellon NuceIa~r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. SAMP-2, Containment and Radioactivity Release Control 3. T-103, Secondary Containment Control Month 20XX LGS 3-36 EP-AA-1008 (Revision XX)

I lmmri r-L- (-'gingrnfinr Q$f*irin A nnnv F:vgalnn Mime:rlAsr is RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC5 Initiating Condition:

Primary Containment radiation Operating Mode Applicability:

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

LOSS Drywell radiation monitor reading > lOOR/hr.A. containment radiation reading greater than (Site pc;ificr value).Basis: The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC5 Loss tThreshold-4A-since it indicates a loss of the RCS Barrier only.There is no RCS Potential Loss threshold associated with Primary Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor Reading Indicative of Loss of RCS Barrier Month 20XX LGS 3-37 EP-AA-1008 (Revision XX)

I irngsrio-h-ftdingsrýfin Q#!mfien Anngv I::vslrnn f, " glx:r I ~ ~ ~*~4ii~ui A uiv~av Fv~Inn IJ.mrI~nr.~uEE.~3 ~ ~ E~E U~IU E~I ~W5.I~UI 5~~U El E~I~ ----s-s. U ~RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC7 Initiating Condition:

Emergency Director Judgment.Operating Mode Applicability:

1,2,3'Fission Product Barrier (FPB3) Threshold:

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

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

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

Basis Reference(s):

1 .NEI 99-01 Rev 6, Table 9-F-2 Month 20XX LGS 3-38 EP-AA-1008 (Revision XX)

Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2 Initiating Condition:

RPV Water Level Operating Mode Applicability:

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

POTENTIAL LOSS A Plant conditions indicate Primary GContainment flooding is required.Basis: Potential ILarr 2 A The Potential Loss threshold is identical to the Fuel Clad Barrier FC2 Loss threshold RPV Water Level. 2-.The Potential Loss requirement for Primary Containment Flooding indicates adequate core cooling cannot be restored and maintained and that core damage is possible.

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

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. T-BAS (INTRO) Introduction To Trips And Samps -Bases 3. T-1 11, Level Restoration

/ Steam Cooling -Bases 4. T-1 16, RPV Flooding -Bases 5. T-1 17, Level/Power Control -Bases Month 20XX LGS 3-39 EP-AA-1008 (Revision XX)

F:yAInn N.clAar I imprirnk ranabratinn Station Annex Fxelnn Nuleaar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 Initiating Condition:

Primary Containment Conditions Operating Mode Applicability:

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

LOSS Al. UNPLANNED rapid drop in primary containment pressure following primary containment pressure rise.OR 82. Primary containment pressure response not consistent with LOCA conditions.

POTENTIAL LOSS A3. PFima~y GDrywellentainment pressure greater than (site specific value)> 55 psig and rising.OR 84. (site Specifc explosive mixtur) exists inside PrimAv;, containment

a. Drywell or Suppression Pool Hydrogen concentration

> 6%.AND b. Drywell or Suppression Pool Oxygen concentration

> 5%.OR G5. HTLG-Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.Basis: UNPLANNED:

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

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

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

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

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

The unexpected (UNPLANNED) response is important because it is the indicator for a containment bypass condition.

A pressure suppression bypass path would not be an indication of a containment breach.Month 20XX LGS 3-40 EP-AA-1008 (Revision XX)

Limerick Generatina Station Annex Exelon Nuclear Limerick..Genera.....

SIta.ion..Annex..E....on..Nucle..r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Potential Loss 4-AThreshold

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

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

A pressure of this magnitude is greater than those expected to result from any design basis accident and, thus, represent a Potential Loss of the Containment barrier.Potential Loss 4-BThreshold

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

5 Basis The WHeat Capacity TemperFabture Lim"it (HCTL) is the highest eupr.e;cen peol temperature fromff Which EmRergencGy RPV Qepr curzation will not raice:* Spprccin haMber temperature above the maximum temperature capability o the~~~ Gupeco hamber and equipment within the supprecciGn cham~ber Whic may be required to operate when the RPV i,,,.uie, OR*Sppeco cham:ber pressure above Primary Containm~ent Pressure Limnit-Al whil~e the- r-ate Of energy transf-er fro-m the RPV to the containm~ent is grcater thn the capacity Of the containment Yent.The HCTL is a function of RPV pressure, suppression pool temperature and suppression pool water level. It is utilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintain plant parameters below the limit constitutes a potential loss of containment.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. UFSAR Section 6.2.1 3. DBD L-T-12, Design Basis Accidents, Transients and Events 4. DBD L-S-25A, Primary Containment Pressure Suppression System 5. DBD L-T-02, Containment, Section 3.2.14 6. T-102 Primary Containment Control -Bases Month 20XX LGS 3-41 EP-AA-1008 (Revision XX)

I imnrif-k I' Znnnrnfin Qfafinn Annnv F::alnn Nnrllar I inp1 fn~~*nn~**in nnv vannM~r222 RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT5 Initiating Condition:

Primary Containment Radiation Operating Mode Applicability:

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

POTENTIAL LOSS A. Primary containment radiatien monitor reading greater than (sitc cpecifc value)Drywell radiation monitor reading > 4.35 E+02 R/hr.Basis: There is no Loss threshold associated with Primary Containment Radiation.

Potential Less 4.,A.The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that 20% of the fuel cladding has failed. This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds.

NUREG-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 7 there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. Core Damage Assessment Methodology

3. Technical Specifications Table 3.3.7.5-1 4. DBD L-S-43, Radiation Monitoring System 5. ST-2-026-418-1 Accident Monitoring

-Primary Containment Post -LOCA Radiation Division III Calibration (RE-26-191A)

6. ST-0-026-640-*

Alternate Monitoring for Inop Post-LOCA Radiation Monitors Month 20XX LGS 3-42 EP-AA-1008 (Revision XX)

I=xelon Nuclear Limeric~k Generatina Station Annex Exelon Nuclanr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 Initiating Condition:

Primary Containment Isolation Failure Operating Mode Applicability:

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

LOSS Al. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal.OR B2. Intentional Pprimary Ceontainment venting/purging per EOP's or SAGs due to accident conditions.

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

1-a. Secondary Containment area temperature

> T-103 I SAMP, Max Safe Op Value (MSO).Ma F.a. T..empe.atu.e OR 2b. Secondary Containment area radiation level > T-103 I SAMP, Max Safe Op Value (MSO)Max Safe Operating Radiation Level.Basis: UNISOLABLE:

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

Loss 3AThreshold

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

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

Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.Month 20XX LGS 3-43 EP-AA-1008 (Revision XX)

F=galnn I imaprirk rioarnnrainn tAtninn AnnaY vn mx~c2 RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Following the leakage of RCS mass into primary containment and a rise in primary containment pressure, there may be minor radiological releases associated with allowable primary containment leakage through various penetrations or system components.

Minor releases may also occur if a primary containment isolation valve(s)fails to close but the primary containment atmosphere escapes to an enclosed system.These releases do not constitute a loss or potential loss of primary containment but should be evaluated using the Recognition Category A-RICs.Loss 3&BThreshold

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

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

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

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

Loss 3-,CThreshold

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

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

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

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

3 3A this threshold would result in a Site Area Emergency.

There is no Potential Loss threshold associated with Primary Containment Isolation Failure.Month 20XX LGS 3-44 EP-AA-1008 (Revision XX)

Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. T-103, Secondary Containment Control 3. T-102, Primary Containment Control 4. T-200, Primary Containment Emergency Vent Procedure 5. T-228, Inerting / Purging Primary Containment Month 20XX LGS 3-45 EP-AA-1008 (Revision XX)

Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT7 Initiating Condition:

Emergency Director Judgment.Operating Mode Applicability:

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

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

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

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX LGS 3-46 EP-AA-1008 (Revision XX)

NuclAar Simeric~k (Ganeratinn Staition Annex Exelon Nuclea~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSG1 Initiating Condition:

Prolonged loss of all Off-site and all On-Site AC power to emergency busses.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the General EMcgecY -vent promptly upon determining that (site hours) the applicable time has been exceeded, or will likely be exceeded.1-a. Loss of ALL offsite :and LL onsi"o AC power to unit (site spe..ft" emergencY buses)4KV safeguards Buses.AND 2. Failure of Dl 1(21), D12(22), D13(23), and D14(24) Emergency Diesel Generators to supply power to unit 4KV safeguards Buses.AND 3b. EITHER of the following:

a. Restoration of at least one unit emeegeAcyAKV Safeguards bu&-Bus -in < 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is notves than (site specific hours) is not likely.OR b. RPV water level cannot be restored and maintained

> -186 inches.*(Site specific indication of an inability to adequately remove he-at fro-m the core)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 one or moreany fission product Month 20XX LGS 3-47 EP-AA-1008 (Revision XX)

Simeric~k (GAneratinn Stsation Annex Exelon Nucla~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS 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 FGI. This will allow additional time for implementation of offsite protective actions.Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation.

Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.Basis Reference(s):

1. NEI 99-01 Rev 6, SG1 2. UFSAR Section 8.2, Offsite Power System 3. E 10/20 Loss of Offsite Power 4. DBD L-S-05, 4KV System 5. DBD L-T-03, Electrical Issues 6. T-101 RPV Control Month 20XX LGS 3-48 EP-AA-1008 (Revision XX)

Fvamlnn Nimlanr Simernick (Anersatinn Station AnnexEAn N~~Ai RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSSI 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 Emergency Action Level (EAL): Note: The Emergency Director should declare the Site Area E=..egenyevent promptly upon determining that the applicable time 415miiwtes-has been exceeded, or will likely be exceeded.1. Loss of ALL offsite and ALL on;ito AC Power to (site spocific emergency bucc,)unit 4KV Safeguards Buses. for 15 minutes or lo.ger.AND 2. Failure of Dl 1(21), D12(22), D13(23), and D14(24) Emergency Diesel Generators to supply power to unit 4KV Safeguards Buses.AND 3. Failure to restore power to at least one unit 4KV Safeguards 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 RAG1, FG1-er-MSG1, or MG2.Month 20XX LGS 3-49 EP-AA-1008 (Revision XX)

Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, SS1 2. UFSAR Section 8.2, Offsite Power System 3. E 10/20 Loss of Offsite Power 4. DBD L-S-05, 4KV System 5. DBD L-T-03, Electrical Issues 6. T-101 RPV Control Month 20XX LGS 3-50 EP-AA-1008 (Revision XX)

FxAInn N.nlAar Limeric~k Ganer~atinn Stzation Annex Exelnn Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA1 Initiating Condition:

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

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the eventA~e promptly upon determining that the applicable time 45- iiiutes-has been exceeded, or will likely be exceeded.1. AC power capability to unit 4KV Safeguards Buses reduced to only one of the following power sources for > 15 minutes.* 101 Safeguards Transformer

102 Safeguards Transformer SDl 1(21) Diesel Generator* D12(22) Diesel Generator* D13(23) Diesel Generator* D14(24) Diesel Generator a. AG poWer eapabilit' to (Site SpSG~fiG emergencY bUcoc) is reduced to a single poW8 e~r ourc fonr I15 m~inutesA o-r longer.AND 2b. Any additional single power source failure will result in a loss of -all-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 MSUl.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.Month 20XX LGS 3-51 EP-AA-1008 (Revision XX)

Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS" 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.Escalation of the emergency classification level would be via IC MS$1.Basis Reference(s):

1. NEI 99-01 Rev 6, SA1 2. UFSAR Section 8.2, Offsite Power System 3. E 10/20 Loss of Offsite Power 4. DBD L-S-05, 4KV System 5. DBD L-T-03, Electrical Issues Month 20XX LGS 3-52 EP-AA-1008 (Revision XX)

I imarink rZonarntinn Atntinn Annay Fvplnn NJn.Ianr I imoria~k (~~inm2~nn

~t~atinn Ann~&v Fvnlnn MmIv~I~2r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU1 Initiating Condition:

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

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Event vent promptly upon determining that the applicable time 15-min4e&-has been exceeded, or will likely be exceeded.4-.Loss of ALL offsite AC power capability to unit 4KV Safeguards Buses (site-specifi eM.rgency bue ...for > 15 minutes-Ger-eia.

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.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.Escalation of the emergency classification level would be via IC MSA1.'Basis Reference(s):

1. NEI 99-01 Rev 6, SU1 2. UFSAR Section 8.2, Offsite Power System 3. E 10/20 Loss of Offsite Power 4. DBD L-S-05, 4KV System 5. DBD L-T-03, Electrical Issues Month 20XX LGS 3-53 EP-AA-1008 (Revision XX)

Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSG281 Initiating Condition:

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

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the General E.- ,--gencY vent promptly upon determining that the applicable time 15-niutes-has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to unit 4KV Safeguards Buses.AND 2. Failure of D11(21), D12(22), D13(23), and D14(24) Emergency Diesel Generators to supply power to unit 4KV Safeguards Buses.AND 3. Indicated voltage is < 105 VDC on unit 125 VDC battery busses 1(2)FA, FB, FC, and FD.AND 4. ALL AC and Vital DC power sources have been lost for > 15 minutes.1. aa Les ofALntt nd m vA nnrm.v

POve (648 lH G veift e wefv-buses) for 15 Minutes or longer.-AND b. Indicated voltage is loe6 than (cite Specific bus voltage value) onAL (site specific.

Vital DCG busses) for 15 minutes Or longer.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.

Month 20XX LGS 3-54 EP-AA-1008 (Revision XX)

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

1. NEI 99-01 Rev 6, SG8 2. UFSAR Section 8.3.2, DC Power Systems 3. DBD P-L-01A, 125/250 VDC System 4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA 5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB 6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC 7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS IFD 8. UFSAR Section 8.2, Offsite Power System 9. E 10/20 Loss of Offsite Power 10. DBD L-S-05, 4KV System 11. DBD L-T-03, Electrical Issues Month 20XX LGS 3-55 EP-AA-1008 (Revision XX)

Nuclear Limeric~k Generatinn Station Annex Exelon Nuiclern RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS28 I Initiating Condition:

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

.1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the Site Area Eme.gency.vent promptly upon determining that the applicable time 41mintees-has been exceeded, or will likely be exceeded.

is < 105 VDC le's than (site Specfic. bus voltage 'value) on 125 VDC battery busses 1(2)FA, FB, FC, and FDALL (sito specific Vital DG busses) for > 15 minutes-e-F loeF.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 RAG1, FG1 or MSG28.Basis Reference(s):

1. NEI 99-01 Rev 6, SS8 2. UFSAR Section 8.3.2, DC Power Systems 3. DBD P-L-01A, 125/250 VDC System 4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA 5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB 6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC 7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS 1FD Month 20XX LGS 3-56 EP-AA-1008 (Revision XX)

I imarink rZanarnfinn Atnfinn AnnpX ExAIon Nuclear I imrirk (~~r~inn tatnn An~~Exelnn Nucilear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS361 Initiating Condition:

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

1,2 Emergency Action Level (EAL): 1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 4%.AND 2. All-ALL manual / ARI actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 4%.AND 3. EITHER of the following conditions exist:* RPV water level cannot be restored and maintained

> -186 inches OR* Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.(Site ntion of an to adequately ,emo'e heat from; the c.re)(Site 6pecific indication of. an ibliyto adequately remove heat fromn the RCS)Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron injection~all subsequent operator actionn to manually shutdown the reactor 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 I 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.Month 20XX LGS 3-57 EP-AA-1008 (Revision XX)

I impriuck (GAneraina Stt~ion Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Escalation of the emergency classification level would be via IC RAG1 or FGI.Basis Reference(s):

1. NEI 99-01 Rev 6, SS5 2. T-101 RPV Control -Bases 3. T-1 17 Level/Power Control -Bases 4. T-102 Primary Containment Control -Bases Month 20XX LGS 3-58 EP-AA-1008 (Revision XX)

I imarit-k (' ganartifin Qf!mfinn Annav I:'V--I#n K, ,0-I.-or I~a _ _ý5in 4*ý An5 *** E t n**l .U t.* tS S*BUu RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA31 Initiating Condition:

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

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

1. An-aAutomatic or manual scram did not shutdown the reactor as indicated by Reactor Power > 4%.AND 2. Manual / ARI actions taken at the reactor Gcntrol cnc,-cl Reactor Console are not successful in shutting down the reactor as indicated by Reactor Power > 4%.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor to shutdown the reactor are also I unsuccessful.

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

If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the reactor G9,*trl consoles (e.g., locally opening breakers).

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

Taking the Reactor Mode Switch to SHUTDOWN Shutdown is considered to be a manual scram action.The plant response to the failure of an automatic or manual reactor scram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged Month 20XX LGS 3-59 EP-AA-1008 (Revision XX)

I FVirndr.i&

f(-rsarafinn Q*f$nrin Annov Fvlnn N"Mar*S .Y.I 5

I w... ~n3 f RECOGNITION CATEGORY SYSTEM MALFUNCTIONS enough to cause a challenge to the RPV water level or RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC MSS35. Depending upon plant responses and symptoms, escalation is also possible via IC FSI. Absent the plant conditions needed to meet either IC MSS35 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. T-101 RPV Control -Bases 3. T-1 17 Level/Power Control -Bases Month 20XX LGS 3-60 EP-AA-1008 (Revision XX)

I imarif-L-e' A2nA2rtx#in Qftsfirtn Annnv IRvainn Miulnar I viai.I ~~ir~uj ~~iE nA llV vIrnMi.~nr*****

U U*U UUfl UamS*RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU31 I Initiating Condition:

Automatic or manual scram 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. An-aAutomatic scram -did not shutdown the reactor as indicated by Reactor Power > 4%..AND b. A-sSubsequent manual / ARI action taken at the reactor contro!GenselesReactor Console is successful in shutting down the reactor.OR 2. a. A-mManual scram -did not shutdown the reactor as indicated by Reactor Power > 4%.AND b. EITHER of the following:

1. A-sSubsequent manual / ARI action taken at the reactor control GOnseGeeReactor Console is successful in shutting down the reactor.OR 2. A-sSubsequent automatic scram / ARI is successful in shutting down the reactor.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor eetFrI consoles or an automatic scram is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.EAL #1 Basis Following the failure on an automatic reactor scram, operators will promptly initiate manual actions at the reactor Ge,-,tc! onsoles to shutdown the reactor (e.g., initiate a manual reactor scram). 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 LGS 3-61 EP-AA-1008 (Revision XX)

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

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

Taking the Reactor Mode Switch to Shutdown is considered to be a manual scram action.The plant response to the failure of an automatic or manual reactor tscram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor GGAFGI consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MSA35. Depending upon the plant response, escalation is also possible via IC FAI. Absent the plant conditions needed to meet either IC MA35 or FA1, 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 scram signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that creates a real condition that should have included an automatic reactor scram and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated." If the signal generated as a result of plant work does not cause a plant transient but should have generated an RPS scram signal and the scram failure is determined through other means (e.g., assessment of test results), then this IC and the EALs are not applicable and no classification is warranted.

Basis Refernce(s):

Month 20XX LGS 3-62 EP-AA-1008 (Revision XX)

Limerick Generating Station Annex RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Exelon Nuclear 1.2.3.NEI 99-01 Rev 6, SU5 T-101 RPV Control Technical Specifications Table 3.3.1.1-1 Month 20XX LGS 3-63 EP-AA-1008 (Revision XX)

I imariek (Zanarnfinn A#2finn Annoy IF:lrlnn Nw-lor I im~riaIe (~nor2tinn

~t~tinn Ann~v Fv~Inn hIIIr~Io2r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA42 Initiating Condition:

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

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the eventAle4t promptly upon determining that the applicable time 45 miiutes-has been exceeded, or will likely be exceeded.1. a:-AA-UNPLANNED event results in the inability to monitor one er-moroANY Table Mlef- the f--llc..wii" parameters from within the Control Room for > 15 minutes 9F-l.ngeF.

see -belew RRe-actor-Power__________________

Table M1 Control Room Parameters RPV Watr- Level , Reactor Power* RPV Water Level RPV Pressure* Drywell Pressure Primary Containment

.Suppression Pool Level........ .Suppression Pool Temperature Suppression Pool Le.-ve SUPPrcssion Pool Tempcrattur-AND 2. b--Any-ANY Table M2ef transient events in progress." Automati; or Manual ,1 rubak greate than -250% thoW/1rmal re-actor po pwer" Elec-trical load rejection greater than 25%fuPlltelecrtricali lo2d-Reateto40p

---V \V/*V Il Month 20XX LGS 3-64 EP-AA-1008 (Revision XX) l=l(Alnn Limeric~k fleneratinn Staition Annex Exelnn NucleInar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Table M2 Significant Transients" Automatic or Manual Runback > 25% thermal reactor power" Electrical Load Rejection

> 25% full electrical load" Reactor Scram" ECCS Actuation* Thermal Power oscillations

> 10%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 ne er mer-eany of I 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, RPV-leve!RPV water level and RCS heat removal.Month 20XX LGS 3-65 EP-AA-1008 (Revision XX)

Limerick Generating Station Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS The loss of the ability to determine oeo r. mereany of these parameters from within the Control Room is considered to be more significant than simply a reportable condition.

In addition, if all indication sources for one O-r mreany of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for RPV water level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.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 RAS1.Basis Reference(s):

1. NEI 99-01 Rev 6, SA2 2. DBD L-T-06, Human Factors, Section 6.1.1 3. T-101 RPV Control 4. T-102 Primary Containment Control 5. ON-122, Loss of Main Control Room Annunciators

-Bases Month 20XX LGS 3-66 EP-AA-1008 (Revision XX)

I=YAInn Limeric~k (GAneratinn Station Annex Fxuainn Nucler~k RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Initiating Condition:

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

1,2,3 Emergency Action Level (EAL): MSU421 Note: The Emergency Director should declare the Unusual Event vent promptly upon determining that the applicable time 1-5 -inutes-has been exceeded, or will likely be exceeded.a- AR-UNPLANNED event results in the inability to monitor onO or- moeANY Table M1 parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters

Reactor Power" RPV Water Level* RPV Pressure" Drywell Pressure* Suppression Pool Level* Suppression Pool Temperature

--.t JLL -- t--ll .... !---OT inn milowna nirnmoiornfrom wnnin m alonrlKo ri~mn~E f OF 'Rgef------------------

2. [B WR par~mct 3. 142WR parametcr 4. Rea.tor Pwe 6. Reactor- Power-8. -RPVN Waterp L" 9. -R CESh L e: IK 10-. _RPA -Pressurce

11. RCS PrEessur-e

42. P 1a~ 13.In COre/Corc CeetonmentExit Temperature iI ss~u 0 14. Suppression Pol5. Ll;'cs in at ....t Leve (site speeil 1 6. Supprcssion Poo 17. St-a-m GCenerator-empe,.twe Aui,.tle or-___e___en Feead I ~ ~ ~ ~ ~ ~ ~ ~ ~ atv YJA,*I Month 20XX LGS 3-67 EP-AA-1008 (Revision XX)

I imarink rtanarnfinn Afnfinn Annoy I imrirk (c~n~ntin

~~tin Anc~~Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis: UNPLANNED:

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

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

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

For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)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 eone Or mereany of these parameters from within the Control Room is considered to be more significant than simply a reportable condition.

In addition, if all indication sources for one er-moreany 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 MSA42-.Month 20XX LGS 3-68 EP-AA-1008 (Revision XX)

Limerick Generatina Station Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis Reference(s):

.1. NEI 99-01 Rev 6, SU2 2. DBD L-T-06, Human Factors, Section 6.1.1 3. T-101 RPV Control 4. T-102 Primary Containment Control 5. ON-122, Loss of Main Control Room Annunciators

-Bases Month 20XX LGS 3-69 EP-AA-1008 (Revision XX)

ML14164A068

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