Text

Enclosure 5: Vogtle Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 4
	ML16071A170
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	03/03/2016
From:	; Southern Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML16071A108	List: ML16071A110; ML16071A126; ML16071A132; ML16071A136; ML16071A137; ML16071A140; ML16071A144; ML16071A146; ML16071A147; ML16071A149; ML16071A150; ML16071A152; ML16071A153; ML16071A158; ML16071A160; ML16071A166; ML16071A170; ML16071A174; ML16071A176; ML16071A180; ML16071A181; ML16071A184; ML16071A185; ML16071A187; ML16071A188; ML16071A193; ML16071A195; ML16071A198; NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 1 of 4; NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 2 of 4; NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 3 of 4; NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 4 of 4; NL-15-1898, Enclosure 3: Hatch EAL Calculations - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 3; NL-15-1898, Enclosure 3: Hatch EAL Calculations - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 2 of 3; NL-15-1898, Enclosure 3: Hatch EAL Calculations - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 3; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 2 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 4 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 5 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 6 of 6; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 2 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 4 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 5 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 6 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 7 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 8 of 8; NL-15-1898, Enclosure 5: Vogtle Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 4; ... further results
References
	NL-15-1898
	Download: ML16071A170 (44)
	v • d • e

I'WRv ULAI IIARKILK Potential Loss 6.A This threshold addresses any other factors by the emergency director in determining whether the fuel clad barrier is potentially lost. The emergency director should also consider whether or~--re4to declare the barrier potentially lost in the event that barrier status cannot be monitored.

94 P-WR-RCS BARRIER THRESHOLDS:

The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.1. RCS or SG Tube Leakage Loss l.A This threshold is based on an UNISOLABLE RCS leak of sufficient size to require an automatic or manual actuation of the Emergency Core Cooling System (ECCS). This condition clearly represents a loss of the RCS Barrier.This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location -inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

A steam generator with primary-to-secondary leakage of sufficient magnitude to require a safety injection is considered to be RUPTURED.

If a RUPTURED steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold I .A will also be met.Potential Loss l.A This threshold is based on an UNISOLABLE RCS leak that results in the inability to maintain pressurizer level within specified limits by operation of a normally used charging (makeup) pump, but an ECCS (S4-)-actuation has not occurred.

The threshold is met when an operating procedure, or operating crew supervision, directs that a standby charging (makeup) pump be placed in service to restore and maintain pressurizer level.This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location -inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment, If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold I .A will also be met.Potential Loss I.B This condition indicates an extreme challenge to the integrity of the RCS pressure boundary due to pressurized thermal shock -a transient that causes rapid RCS cooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).

95 PWR RCS BARRIER THRESHOLDS:

Devel6~ef-Note~*

bee~4A Actuatien ef the ECCS may also be referred to as apprcpriate site specific term.Petential Less I .A Satety (SI) actuationJ or ether Potential Less thresshold.

If used, the thresheld shou~d reflect that the detennination cf Petential Loss l.B ceoldov.n the PCS is in Mode 3 or higher (i.e., het and pressurizcd).

These t"i typicallyp...ameters.

and--, values.....

t... t would.....

..' require operaters to take prompt action to address a cierita (e.g., an EOP use. te ..e.p..d tan ..........

RCS, m....ay not .... nkd or For that have implemen-'ted Westi.nghouse O--ners Greu:p Emergency, Response Guidelines, enter the parameters and v'alues used in the RCS !ntegri..'

Red P~ath. Becau-se of the cemple::ity of ee~ain dee!sion points wi~thin the Red Path of this CSFST, developers at these plants may elect to not include the specific parameters an'd values, anzd instead foliocw; the simiar t. "R,,,C TS Inegit Red entry .onditi....met" in acc.r.anc with..; the guidance the front EOP trans'tion'¢cntrW decision peints or condition criteria.

Fer example, a thre-sheld

2. Inadequate Heat Removal There is no Loss threshold associated with Inadequate Heat Removal.PWRT RCS DARDIERD TI Potential Loss 2.A IRESMObD&96 This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold is identical to Fuel Clad Barrier Potential Loss threshold 2.B; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and increase RCS pressure to the point where mass will be lost from the system.Potsnia 3.A 2 ETrthe raiatio moniito r~meeadnorespand lus that dinstananeousreleas ofhallengatorth abilitnt rmassint thea fromnthinent, iassmn thtam gnreator coolan acivi typicualls b paechnitcsand Spleifthatio alouald elirits Thisratuers towe thanprp tacti tpeciaddfre thil FC lad thatrihrvLo implhme nto d 3.A sicit indhutes aloss roup t meRCSnByrrierponly.

Thvoere ishnouPtnld conssdricldn threshold asoitdwthesma, orS Ac ivity t ontaineaSnt

.RCAciiyIC tanetRadiation.

D L oss ADDI7DT IU"I!I.D.~pe~-Nete~*

be~3A 97 4.5.The reading shauld bc dc~crmir..xl assuming the instantan~jrJ~.~.

and dispereal afthc rcactar ezalant nablc gas and iadinc invcntary.

with RCS activity at Tcchnical Specificatian dllawcHc limits, ir.ta thc cantainment atmasphcrc.

Using RCS activity at Technical Spacification allawabic limits aligns this threshald with !C SU3. Alsa, RCS activity at this lcvcl will typically result in cantainnient radiatian

!cvcls that can be marc rcadily dctcctcd by containment radiatian manitars.

and marc rcadily differentiated fram these caused by piping ar eampanent "shine" saurces. If dcsirc~ a plant may use a !csser value aFRCS activity for datermining this value.In some cases, the sitc specific physical lacation and sensitivity of thc centainment radiatian manitor(s) may bc such that radiatian fram a claud of relcascd RCS gases~annot be distinguished fram radiation emanating fram piping and companants antaining clevatcd reactar ezalant activity.

If sa, rcfcr to thc Dcvclzpcr Natcs fcr Loss/Potential Lcss 5.A and determine Wan altcmatc indicatian is available.

Containment Integrity or Bypass Not Applicable (included for numbering consistency)

Other Indications Not ~ppIicable (inclu&d For nuinhcriiv coiM~nc)Lass aml'or Patential Lass 5.A This subcategory addrcsses athcr sitc specific threshalds that may be ineludcd ta indicate lass ar potential lass afthc RCS barrier based on plant specific desigr. charactcristics nat~ansidercd in the gencric guidance.De~epef-Ne#eM Lass an~'ar Potential Loss 5.A Develapers shauld dctcrminc if ather rcliable indicatars esist ta cvaluate the status af this fissian praduet barrier (e.g., rcvic~ accident ana!yses dcscribcd in the site Final Safety Analysis Report, as updated).

Thc gaal is ta identify any unique ar shc specific indicatians that will pramate timely and accurate asscssmcnt af barrier status.Any addcd threshalds shauld rcprcsent appra~Imatcly the same relative thrcat ta thc barrier as the ather thrcshalds in this column. Basis informatian for the ather thrcshalds ma'.'h~ u~dt~ ~'m~-~ rI-i- retnti'~ knrri~mrthr'~it Hi DPW' DS BARDDILER TLHDUSIJIOLDS!:

6. Emergency Director Judgment Loss 6.A This threshold addresses any other factors that ma~y-be-used by the emergency director in determining whether the RCS Barrier is lost.98 Potential Loss 6.A This threshold addresses any other factors m.e,-be-used by the emergency director in determining whether the RCS Barrier is potentially lost. The emergency director should also consider whether or--net-to declare the barrier potentially lost in the event that barrier status cannot be monitored.

De-veleper Notes: Nkefi 99 PW.R-CONTAINMENT BARRIER THRESHlOLDS:

The Containment Barrier includes the containment building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve. Containment Barrier thresholds are used as criteria for escalation of the ECL from Alert to a Site Area Emergency or a General Emergency.

1. RCS or SG Tube Leakage Loss 1l.A This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment.

The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier Potential Loss I .A and Loss l .A, respectively.

This condition represents a bypass of the containment barrier.FAULTED is a defined term within the NEI 99-01 methodology,-.

This determination is not necessarily dependent upon entry into, or diagnostic steps within, an EOP. For example, if the pressure in a steam generator is decreasing uncontrollably

[part of the FAULTED definitionl and the faulted steam generator isolation procedure is not entered because EOP user rules are dictating implementation of another procedure to address a higher priority condition, the steam generator is still considered FAULTED for emergency classification purposes.The FAULTED criterion establishes an appropriate lower bound on the size of a steam release that may require an emergency classification.

Steam releases of this size are readily observable with normal Control Room indications.

The lower bound for this aspect of the containment barrier is analogous to the lower bound criteria specified in IC SU3 for the fuel clad barrier (i.e., RCS activity values) and IC SU4 for the RCS barrier (i.e., RCS leak rate values).This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steam generator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant and sustained release of radioactive steam to the environment (w.d-efre hus; similar to a FAULTED condition).

The inability to isolate the steam flow without an adverse effect on plant cooldown meets the intent of a loss of containment.

Steam releases associated with the expected operation of a SG power operated relief valve or safety relief valve do not meet the intent of this threshold.

Such releases may occur intermittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stable condition and prepare to initiate a plant cooldown.

Steam releases associated with the unexpected operation of a valve (e.g., a stuck-open safety valve) do meet this threshold.

100 PWR CONTAINMENT BARRIER THRESIIOLDS:

Following an SG tube leak or rupture, there may be minor radiological releases through a secondary-side system component (e.g., air ejectors, glad seal exhausters, valve packing, etc.). These types of releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.The emergency classification levels resulting from primary-to-secondary leakage, with or without a steam release from the FAULTED SG, are summarized below.Affected SG is FAULTED Outside of Containment?

Yes No P-to-S Leak Rate Less than or equal to 25 gpm Greater than 25 gpm feI-er--l-h Requires operation of a standby charging (makeup)pump (RCS Barrier Potential Loss)Requires an automatic or manual ECCS (SI) actuation (RCS Barrier Loss)No classification Unusual Event per SU4 No classification Unusual Event per SU4 Site Area Emergency per FS 1 Site Area Emergency per FS 1 Alert per FAI Alert per FAI There is no Potential Loss threshold associated with RCS or SG Tube Leakage.rA ..... ,g.......... ......~ : r, !ni.-f ratn may alo',3 bac rcfrrc .... o wi atg., ri wa!!beardi er ether !ceaticnz

..their bazi ..un....101 iVW.,] UU .i 1 ,

A 1 I UA KL I ,lllR~IL 2. Inadequate Heat Removal There is no Loss threshold associated with Inadequate Heat Removal.Potential Loss 2.A This condition represents an IMMINENT core melt sequence w,,iehthat, if not corrected, could lead to vessel failure and an increased potential for containment failure. For this condition to occur, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. If implementation ofra procedure(s) to restore adequate core cooling is not effective (successful) within 15 minutes, it is assumed that the event trajectory will likely lead to core melting and a subsequent challenge of the Containment Barrier.The restoration procedure is considered "effective" if core exit thermocouple readings are decreasing eBron~r if reactor vessel level is increasing.

Whether ei-iie~the procedure(s) will be effective should be apparent within 15 minutes. The emergency director should escalate the emergency classification level as soon as it is determined that the procedure(s) will not be effective.

Severe accident analyses (e.g., NUREG-1 150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damage scenarios, and that the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide 15 minutes beyond the required entry point to determine if procedural actions can reverse the core melt sequence.dri,,e actions (e.g., 5 C2Ts .... ag gr......r than ic required befere transitionring to an... "in .....u..e.c.r .oin prc..ur...

a maint....in.

consistency with EOPs. th'0+,..e Potential Lose 2.A. I CETs may also be used.t-ar F.'ants tflat na;ve wastinagn Guidelines, enter the paramaters and values usa O~ars Group Emergency Re used in the Care Cooling Red Path 102

..... t PWK~f~U~MF~IIiXIIIK IIKLv l#1l h: gui:danee at the front ef thie 3. RCS Activity / Containment Radiation There is no Loss threshold associated with RCS Activity / Containment Radiation.

Potential Loss 3.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that 200%- percent 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.

NUJREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 20-%percent in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment would then escalate the emergency classification level to a General Emergency.

NUPEG 1228, Soe.-e.e Du:r.ng !.ncide.t Response to. A+'u:e!e Po;wer.Pla.'t. +'.leicnc~c:, pr'evidee th'e bac+ for+. uc.ing the "2/ cladding failur ....u.. gac and iodinae inv'enter' with- 20%, fruel clad failure into the

4. Containment Integrity or Bypass Loss 4.A These thresholds address a situation where containment isolatioa is required and one of two conditions exists as discussed below. UWere are remin!d'ed that tI here may be accident and release conditions that simultaneously meet both thresholds 4.A. 1 and 4.A.2.103 PWR CONT"AINMENT BARRIER THRESilOLDS:

4.A. I -Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or-sometimes referred to as design leakage).

Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop in containment pressure.

Recognizing the inherent difficulties in determining a containment leak rate during accident conditions, it is expected that the emergency director will assess this threshold using judgment, and with due consideration given to current plant conditions, and available operational and radiological data (e.g., containment pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.).R-efeoqevwo sinpliified examples arc provided in the middle piping run of Figure 90-F-41. Tw-o simp!ified e-xmples are pro-'ided.

One is leakage from a penetration and the other is leakage from an in-service system valve. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure.Another example a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment.

In this case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components.

These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.4.A.2 -Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment.

As used here, the term "environment" includes the atmosphere of a room or area, outside the containment, that may, in turn, communicate with the outside-the-plant atmosphere (e.g., through discharge of a ventilation system or atmospheric leakage).

Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure.Reei4Sec dhe simplified example in the top piping run of Figure 96-F-41. -ti Am.pli.,ficd, exam7,plc.

tl he inboard and outboard isolation valves remained open after a containment isolation was required (i.e., containment isolation was not successful).

There is now an UJNISOLABLE pathway from the containment to the environment.

The existence of a filter is not considered in the threshold assessment.

Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.PWR CONTAINM.ENT B.ARRIER THRESHOLDS:

104 Leakage between two interfacing liquid systems, by itself, does not meet this threshold.

R~ef4e--A simplitied t-,ample is shoxvn in the bottom piping run of Figure 96-F-41. thLa Implitbda, eample, II ~eakage in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building.

The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met. If the pump or system piping developed a leak that allowed steam/water to enter the Auxiliary Building, then threshold 4.B would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the four monitors depicted in the figure and cause threshold 4.A.1 to be met as well.Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components.

Minor releases may also occur if a containment isolation valve(s) fails to close but the containment atmosphere escapes to a closed system. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.The status of the containment barrier during an event involving steam generator tube leakage is assessed using Loss Threshold 1 .A.105 Loss 4.B Containment sump, temperature, pressure and/or radiation levels will increase if reactor coolant mass is leaking into the containment.

If these parameters have not increased, then the reactor coolant mass may he leaking outside of containment (i.e., a containment bypass sequence).

Increases in sump, temperature, pressure, flow and/or radiation level readings outside of the containment may indicate that the RCS mass is being lost outside of containment.

Unexpected elevated readings and alarms on radiation monitors with detectors outside containment shtdwill be corroborated with other available indications to confirm that the source is a loss of RCS mass outside of containment.

If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not increase significantlyt-.

hi lowever, other unexpected changes in sump levels, area temperatures or pressures, flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of the containment.

Refe~to4ln the simplified example in the middle piping run of Figure 46-F-lA41

--n-s.... .... exmpea leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building.

Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause threshold 4.A. I to be met as well.To ensure proper escalation of the emergency classification, the RCS leakage outside of containment must be related to the mass loss that is causing the RCS Loss and/or Potential Loss threshold 1 .A to be met.PWR? COiNTA I~kLNMET 0 A DIEII T[IREISH-OCI LDS: Potential Loss 4.A If containment pressure exceeds the design pressure, there exists a potential to lose the Containment Barrier. To reach this level, there must be an inadequate core cooling condition for an extended period of time; therefore, the RCS and Fuel Clad barriers would already be lost. Th**-t lhis threshold is a discriminator between a Site Area Emergency and General Emergency since there is now a potential to lose the third barrier.Potential Loss 4.B The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity.

It therefore represents a potential loss of the Containment Barrier.Potential Loss 4.C This threshold describes a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating 106 per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible.

This threshold represents a potential loss of containment containment heat removal/depressurization systems (e.g., containment sprays, ice condenser fans, etc., but not including containment venting strategies) are either lost or performing in a degraded manner.Less4A.A threehold.

Erpeectod monitor alarms or readinge may alec bc included.Potential Loes l..A Guidelince, the ...........

alu in Ptntial:., LoeI. A ic th+....at ucod fr th C.n.in. n R ...d Path. !f thec Contai':nmnt CSFST contains m..r. th ..n. Rod Pot,, du to... othr PWR CONTAINM.ENT BARRIDER THRESHOLDS:

Potential Loec l.B Uce-lo'pere may ernter tfle m..n..m .. cotimn ...............

hlyrogen c.ncent..t..n nececay t supor a'" hydro.. bum (ie. th low!-er deflagration' limit). A ..n.urr.nt containment ooygen concentration may be included if the plant hac thie indication aval~able in the Control Room.Potential Loss 4,C can also be entered (e.g., a containment spin:, fisow rate loss than a certain value).Tie t~nhro,:chdj ERot Pp!iebct heUS vluinr'P;tRatr(ER ei 107

5. Other Indications NtApplicable (included lrnumbering osstny Thic add.reeeee ether ci.te z~efie threchalic th-at may be included ta indicate l1o ..r ... t...... la..... .ce af the Containment bah'et b~aed an plant epecifie design....................

en .........n.t.. gui.danee..

Lace° and'r Lace 5.A af preventing eata~trephie failure, a Lace threchald ehauld be included fer the IMMIN'.ENT.

Containment venting, ac p......r....r.a..........

........i.ac ..dan De;'etopers should if ether reliable indicaters e-,:st ta ev'alute the statu-e ofthie ind'eatancn that -will pramtet timely and accurate a.sceesme."t af barrer etatuac.1)lWR DIRRIE) T IRHO )o Any aJe1e~1 thresicakie chauld rerrecent at~vrexImatelv the came relative threat te the..o barrier ac the ather threeheldc in thic ealumn. Bacis inbnciatian far the ather threchalde may ha used t~ cauge the ralativg hMrier threat level.6. Emergency Director Judgment Loss 6.A This threshold addresses any other factors that-may-be-used by the emergency director in determining whether the Containment Barrier is lost.Potential Loss 6.A This threshold addresses any other factors that-mey-'be-used by the emergency director in determining whether the Containment Barrier is potentially lost. The emergency director should also consider whether ef-aet-to declare the barrier potentially lost in the event that barrier status cannot be monitored.

108 Figure 9(i-F-41:

PWR Containment Integrity or Bypass Examples 4.A.2 -Airborne Efflsnit -yr .t. r~easefrom V V Auxiliary Building LM2P!~~t :t Vent 109

1.07 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS GENERAL SITE AREA EMRENY EMRENYALERT UNUSUAL EVENT HG1 HOSTILE HS1 HOSTILE HA1 HOSTILE HlU1 Confirmed ACTION resulting in ACTION within the ACTION within the SECURITY loss of physical PROTECTED AREA. OWNER CONDITION or control of the facility.

Op. Modes:" All CONTROLLED threat.Op. Modes: All AREA or airborne Op. Modes: All attack threat within 30 minutes.Op. Modes: All HU2 Seismic event greater than OBE levels.Op. Modes: All H1U3 Hazardous event.Op. Modes: All HU4 FIRE potentially degrading the level of safety of the plant.Op. Modes: All HA5 Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.______________Op.

Modes: All HS6 Inability to H1A6 Control Room control a key safety evacuation resulting in function from outside transfer of plant the Control Room. control to alternate Op. Modes: All locations.

Op. Modes: All 110 GENERAL SITE AREA EMRENY EMRENYALERT UNUSUAL EVENT HG7 Other HS7 Other HA7 Other 11U7 Other conditions exist which conditions exist which conditions exist which conditions exist in the judgment of the in the judgment of the in the judgment of the which in the emergency director emergency director emergency director judgment of the warrant declaration of warrant declaration of warrant declaration of emergency director a General Emergency.

a Site Area an Alert. warrant declaration of Op. Modes: All Emergency.

Op. Modes: All a (NO)UE._________Op.

Modes: All _ _______Op.

Modes: All 111 HGI ECL: General Emergency Initiating Condition:

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

All Emergency Action Levels: (I) a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by security shift s Ulerv"isionth (site ... pecific security zhifi AND b. EITHER of the following has occurred: I. ANY of the following safety functions cannot be controlled or maintained.

Reactivity control* Core cooling-f4

'-]* RCS heat removal OR 2. Damage to spent fuel has occurred or is IMMINENT.Basis: I lOSt fIlIE ACITION: An act torward a nuclear powver plant (NPP 5) or its personnel that includes the use of violent three to destroy equipment.

take t I()S J'AGES, and/or intimidate the licensee to achieve an end. This includes attack by air. land. or water using gulns, explosives, IPROJCI [IlIEs. vehicles, or other devices used to deliv~er destructive force. Other acts that satisfy, the overall intcnt may be included.

I IOSHIII7 ACTION should not be construed to include acts of civil disobedience or Ijizonious acts that arc not panl of a concerted attack on the NPP. Non-terrorism-based FAI~s should be used to addtess such activities (i.e.. this may include violent acts between individuals in the owvner controlled area (OCA)).IMMINENT:

The trajectory of evetnts or conditions is such thtat an [AL wvill be met vv.iihin a relatively, shtort period of tune regardless of mitigation or correctix e actions.PROTEC I17.) AREA (PA): The area that encotmpa~sses all controlled areas w\ithin the security protected area l~nce.This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions.

It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to 1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls, etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot be maintained.

112 Timely and accurate communications between security shift supervision and the control room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.suer'Lio ef the on chift, P cerit foce Emrenypln adimlm .tn pr...re ar publi......c deucnc ...r.f.r. , : E c2 e ... eu..d................

a....................,.....

ac the pzieulae eneernga peevfte th...at...

LCL Accienrncnt Attributec:

3.1.1.1)k 113 HG7 ECL: General Emergency Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of a General Emergency.

Operating Mode Applicability:

All Emergency Action Levels: (1) Other conditions exist which in the judgment of the emergency director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Basis: I lOSTIII.I AC I lION: An act tow\ard a nuclear poxver plant (NIPl) or its personnel that includes the use of' violent lorce to destroy equipment.

take t lOSTAGES.

and/or intimidate the licensee to achieve an end, This includes attack by air. land, or water using guns. explosives.

I'ROJEC ['llEs. vehicles, or other devices used to deliver destructive torce. Other acts that satist\' the o, erall intent may be included.

IItOSTII E AC IlION should not be construed to include acts of civil disobedience or tchnious acts that are not part of a concerted attack on the NPP. Non-terrorism-based

[Al,s should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area (OCA)).IMMINENI':

The trajectory of events or conditions is such that an ILAI. will he met within a relatively short period of titne regar'dless of mitigation or corrective actions.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist whieb-that are believed by the emergency director to fall under the emergency classification level description for a General Emergency.

114 HS1 ECL: Site Area Emergency Initiating Condition:

HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:

All Emergency Action Levels: (1) A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the-securitv shift super,,ision(&itc zpeziftc security sh.i.t Basis: tlOSIlIIE ACTIO N: An act towxard a nuclear powser plant (NPP) or its personnel that includes the use o1 violent tbrce to destroy equipment.

take ttOS IAGES. andior intimidate the licensee to achieve an end. [his includcs attack by air, land. or \sater using guns. explosives, PROJtECIlI.Is, vehicles, or other devices used to delis er destructise force. Other acts that salisl'x thte overall intent max be included.

t!IOSlIIIE ACI[ION should not he construed to include acts of eis il disobedience ot felonious acts that are not ptar of a concerted attack on the NPP. Non-terrorism-based EAI~s should he used to addrcss such activities (ice.. this may include violent acts between individuals in the oxyner controlled area (OCA)).PROlI EU l't) AREA (PA); ['he area that cncomtapsses all controlled areas ss ithin the security protected area tl~nce.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA (PA I. This event will require rapid response and assistance due to the possibility for damage to plant equipment.

Timely and accurate communications between security shift supervision and the control room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).

The Site Area Emergency declaration will mobilize ORO resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.

This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA (PA); such an attack should be assessed using IC HAl. It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.115 Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level w;eiui k e....sc ICHl I)',zepe r Nero::...p...'i:ion of hc an chift cecurity forcc.n...t inoroato ScLurty c -"ordeal inoma"S iorl.... Th 2, i 5 -udc infrato that may.. ......trat lsch eation. Security ,se PRTEvCinraTiE A hudREA.indi nnpblcdcuet EU L Aos i:' ennwt A ttibut¢es;:

3.1,3.D)116 HS6 ECL: Site Area Emergency Initiating Condition:

Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:

All Emergency Action Levels: INote: The emergency director s4oeud~x ll declare the Site Area Emergency promptly upon determining that (;!tr~e :cifiz ;f 15 minutes-)

has been exceeded, or will likely be exceeded.(1) a. An event has resulted in plant control being transferred from the control room to the remote shutdow~n panels due to a control room evaeuation.(eite-spee~fl AND b. Control of ANY of the following key safety functions is not reestablished within... itec: :pcie numbe .... t5 minutes-).

Reactivity control* Core

RCS heat removal Basis: This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time.The determination of whether or'-hot-"control" is established at the remote safe shutdown location(s) is based on emergency director judgment.

The emergency director is expected to make a reasonable, informed judgment within tth,.. time fcr .....cr , I., S,--'. minutes as 10 whether eir--n~the operating staff has control of key safety functions from the remote safe shutdown location(s).

Escalation of the emergency classification level weu,44.be vieuses IC FGI or CGI.De~opeNe117 ECL A&zignrncnt Attribut~z:

3.I.3.B 118 HS7 ECL: Site Area Emergency Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of a Site Area Emergency.

Operating Mode Applicability:

All Emergency Action Levels: (I) Other conditions exist which in the judgment of the emergency director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Basis: tlOS OILI, )N: An act toward a nuclear pow\er plant or its personnel that includes ihe use of violent tharee to dcstro\ equipment, take I lO S lAGiLS, and/or intimidate the licensee to achiev e an end. this includes attack by air. land. or water using guns. explosi\ es, PR{0JFlCTlIEs.

\ ehicles, or other devices u~sed to deliver destructive Ibrce. Other acts that satists the overall intent may bye included.

lO I 5 ILL A( 1ION should not be construed to include acts of civ il disobedience or Ielonious acts that are not part of a concetied attack on the NPP. Non-terrorism-based FLALs should be used to address such activities (i.c.. this max includeacts bewveen indix iduals in the owvner controlled area (0(A)).This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist whie-that are believed by the emergency director to fall under the emergency classification level description for a Site Area Emergency.

119 HA1 ECL: Alert Initiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.Operating Mode Applicability:

All Emergency Action Levels: (1 or 2)(I) A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by t-he-security shift supcrx

..p fi c, (2) A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.Basis: I [OSTlll,-

ACTION; An act toward a nuclear power plant tN PPI or its personnel that includes the use of,,iolent force to destroy. equipment.

take I lOS IlA(tiLS.

and/or intimidate the licensee to aehieve an end. This includes attack hy air, land, or water using ,guns. explosiveCs.

PROI [C [LLs.Es 'ehicles.

or other dev ices used to delixer destructive toree. Other acts that satistv the overall intent may be included.

tOI 1IltL ACTION should not be construed to include acts of civil disobedience or fe~lonious acts that are not part of a concerted attack on the NIP. Non-terrorism-based LAI~s should be used to address such activities (i.e.. this max' include violent acts between individuals in the ow\ner controlled area (()CA)).OWN LR CONTROLLIEI)

AREA the site property owned by or otherwise under the control of V L'(ilP security.This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA (PA), or the need to prepare the plant and staff for a potential aircraft impact.Timely and accurate communications between security shift supervision and the control room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).

The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.120 Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL # 1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA (OCA). This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA ( PA).EAL #2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness.

This EAL is met when the threat-related information has been validated in accordance with s atL io pioc:dtire.,;...

i .... spcii ......u. ).The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA (OCA) was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level we'.u!d-be-;4auses IC HS 1.Te(sitc specific ...curi, t..y ..hift suevso n). it, ttea hea hf niiua epnil supe~isin afthe n sifi ecurty fr 21 ECL A3cignmznt Attributz~:

3.I.2.D 122 HA5 ECL: Alert Initiating Condition:

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

All Emergency Action Levels: SNote: 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 anye4e fellewift I able Ill plant rooms or areas: AND b. Entry into the room or area is prohibited or impeded.Table III Applicable Building Room Number Mode I CB-226, IUB-A\45, 3 2CBi-223 2CB-A22 ICiB-A77.

ICt-B61, I1CB-B76, JCB-B379 2Ct3-A79, 2CB3-B0 I (ontrol Building 2C13-B04.

2( 1-B 18 I CB-226, tCB-A45 ICB3-B84, 2C13-B85 4 2CB-223. 2CB-A22 1CB-A48. ICB-A50 2CB-A15, 2CB-A16 -AFW Pump O)peration and standbyPump house Readiness

-1. 2, 3 IAB-A28,_2AB-A7212 A-level demain vessel 'valve galleries 1A13-A24, 2AB3-A773 lAtB-A08.2At3-A I 01 Auxiliar).

Building 1 AB-C85, lAB-C894 2AB-C38, 2A13-C44 ________1AB-BI5 MEZZ ltAB-BI9 MIEZZ 2AB-BI 17 MEiZZ_____________2AB-B1 19 MEZZ________

Basis: 123 This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to maintain normal plant operation, or required for a normal plant cooldown and shutdown.

This condition represents an actual or potential substantial degradation of the level of plant safety -4f he plan+.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 at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the emergency director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards.Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

An emergency declaration is not warranted if any of the following conditions apply.* The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release).

For example, the plant is in Mode I when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.* The gas release is a planned activity that includes compensatory measures -o address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).* The action fe.-whiehthat room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels.Most commonly, asphyxiants work by isplacing air in an enclosed environment.

This reduces the concentration of oxygen below the normal level of around 1 9%r, percent, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that automatically or manually activate a fire suppression system in an area.Escalation of the emergency classification level -weald-be-i~auscs Recognition Category R, C or F ICs.~ope~124 repairs, cerreetive meazurec or emergency operatione).

In additien.

the liet ehauld cpccify the plant made(s) during wh~eh entry woold be required fcr each reem ar area.The lict cheuld net ir.elude raem~ er ar.z~ for which entry i~ reqaired eddy te pcrfcrrn aetiene af an adminis*trati~e ar record keeping nature (e.g.. narma! raunde er reutine inepect~enz).

The liet need not ine!ude the Centre! Ream if adequate engineered zafcty!dezign fcamre~ are in place ta preelude a Control Ream evacuaticn due to the releaee of o hazardouc gac. Such featurce may include, but are not limited te, capabili~'

te dmw air from mu!tiple air intake: at different and ceparate loeat~enc.

inner and outer atmeepheric baundarie:, or the eapability te acquire and maintain pasitive preecure ;~ithin the Central Roam envelope.If the equipment in the lieted roem ar area woe already incperable, or out af zer.iec, before the event occurred, then ne emergency ehould be declared cince the event will have ne adverse impact beyond that already allowed by Technical Specification:

at the time cf the event.LCL Aeattnmcnt AttrIbute::

.3. J 2.8 125 HA6 ECL: Alert Initiating Condition:

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

Operating Mode Applicability:

All Emergency Action Levels: (1) An event has resulted in plant control being transferred from the control room to the rem]Ote shutdown panels due to a control room evacuation.,'it pa........

ov mz" .. ... ..peane and lzca! =ontra! ztaticna).

Basis: This IC addresses an evacuation of the control room that results in transfer of plant control to alternate locations outside the control room. The loss of the ability to control the plant from the control room is considered to be a potential substantial degradation in the level of plant safety.Following a control room evacuation, control of the plant will be transferred to alternate shutdown locations.

The necessity to control a plant shutdown from outside the control room, in addition to responding to the event that required the evacuation of the control room, will present challenges to plant operators and other on-shift personnel.

Activation of the ERG and emergency response facilities will assist in responding to these challenges.

Escalation of the emergency classification level weii'-!dbe-;4auses IC HS6.Thc "sitz remzte pan'zc! and !ozal control stutians" are the panels and ccntralrefereneed in plan't reed to and ehutdcwtn the plant from a 126 HA7 ECL: Alert Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of an Alert.Operating Mode Applicability:

All Emergency Action Levels: (1) Other conditions exist which, in the judgment of the emergency director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Basis: 1IOS 111I1 ACI( I)N: An act toxxard a nuclear pooecr plant (NIPI) or ifs personnel that includes thle usc o oo'ilcnt lircc to destroy equipmecnt.

take I lOS!! AGiILS. and/or intimaidate thc licensec to achice c an end. Ihis includes attack hx air, land, or ,ataer using guns. cxplosixcs.

IPROJI( [ILEs.

or other devices used to deliver destructive t'orcc. Ot her acts that sat isfx' thc o\ erall intent may bc included, IttOS [IIL, A(7 IION should not be construed to include acts of civil disobedience or acts that are not part of' a concerted attack on the NPP. Non-terrorism-hased EAI ~s should be used to address such actis itics tice.. this may include xijolcut acts hcetwecn in1di,, iduals in the owner controlled ar'ea (OCA f).This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the emergency director to fall under the emergency classification level description for an Alert.127 HU1 ECL: Notification of Unusual Event Initiating Condition:

Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:

All Emergency Action Levels: (I or 2 or 3)(1) A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by 4wo-security shift i suevsinst "peifi "eurt "hf "pr.iiz (2) Notification of a credible security threat directed at the-sileV LOGP.(3) A validated notification from the NRC providing information of an aircraft threat.Basis: SE(II R IIVY C(ON DI'ITION:

An3 Security F'.ent as listed in thle approved securitx contingencN plan that constitutes a threat/compromise to site sec'urity, thieatirisk to site personnel, or a potential degradation to the level of sal~ty of the platnt. A SI (CI/RIlY (ONI)l [ION does not in,,olve a 1t0IOSTIIE A(Ilt )N.I nsIIll.! ACiIION: An act tox'.ard a nuclear powe.~r platnt (NI P) or its personnel that includes the use of' jolent foree to destro'. equipment.

take 15 ttOl AIS and/or intimidate the Ilieensee to achieve art end. I his inecludes attaek b) air, land, or x,\ater using gutns. explosives.

IPROJI-/C

[IL~Ls, vehicles, or other devices used to deltser destruetive foree. Other acts that satisfy3 the o'.erall intent tnay be ineluded.

IfOSTII I, AC I ION should not be constrtted to include acts of' civil dlisohedietnee or Unlnious aets that are not part of a eoneerted attack on the NPP. Non-terrorism-based L'AI~s shottld be used to address such aeti,,ities (i.e., this tnav include violent acts betw~een individuals in the owAner eontrolledl area (OCA)).This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and t-Irs-represent a potential degradation in the level of plant safety. Security events whieht-t hat do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HGI.Timely and accurate communications between security shift supervision and the control room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 references secutritN shift super'.ision(aitc epecife ahift superv.'icin) because these are the individuals trained to confirm that a security event is occurring or has occurred.Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.39 information.

128 EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with stat ion proccdtircstsite specific proceduare).

EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with station pro~ccdures,,sitc+

..p;cific procedure).

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level ..... ,ld-be.-4a..c IC .l, ~f the on hift, ...uri.y forc..-...

The (sit ....i.i pro... dur.. +th pr....dure.+)

u...d by.'- Co.ntrol Roo and.. r Se_.curi..ty p.....nn l to if .... secrit threat is credibl, a..d tI validat receipt.. f. .irr.. 4threa i.fe....etie--

Emer....n.y pln and. implemI nti.. proeedurc.&.

a....... puli.c d ..um.n.; th. refore, E[2 sh +ould.I thret ocation.+^

Sc ..ity sen......

shoul be cotie non p+.ublic documents With.... du conideratio g.... to the ..b.ove developer n... te, E1 ... may ..... tai alpha ... numbere p.-roced+ures.

Suc.h referen..e.

shc., ..... contai a rec...nizable descr.ti.

+.. f. t*he e...t. For...... ', an EAL may be'. .....e ..as a:Sce.....

e:en ..... #5+ or #9 is reporte by.. the ( ....pecific...... A .. ... u ..7.' lo.. .A .U ..129 HU2 ECL: Notification of Unusual Event Initiating Condition:

Seismic event greater than OBE levels.Operating Mode Applicability:

All Emergency Action Levels: (1) Seismic event greater than Operating Basis Earthquake (OBE) as indicated by thc f~itc srecitic indication that a ~tmic event met or e-~cceded (J~E Basis: This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake An earthquake greater than an OBE but less than a Safe Shutdown Earthquake should have no significant impact on safety-related systems, structures and componentst-.

hI lowever, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections).

Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of plant safety Event verification with external sources should not be necessary during or following an OBE.Earthquakes of this magnitude should rcadil be r-eeily-felt by on-site personnel and recognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g). The Shift Manager or emergency director may seek external verification if deemed appropriate (e.g., a call to the USGS; or check ol" internet news however, the verification action must not preclude a timely emergency declaration.

Depending upon the plant mode at the time of the event, escalation of the emergency clasifiatin lvel eti4-"-:4usc' IC CA6 or SA9.classificationclevel indicatio tha "a

mceen sr ~ OElmi"zoldh a on_.th:ea a c.. alacrms! and ..........

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lnictin decibdinth ELThul b imte o hae ht reimeiael aalal0t Fcr altec that +/-~ fl~t flx.c rca1z~v a~aI~c U8E indicaticn~

witt~in thc Uzntrcl Rccm.(1') a. Central PRcm pc ......f...... a............n..............cn....., AN'D b.. .......urr.n... f... ...... .............

n..rm ...n ....n.r ....m .appropriate b m...r ...ncy ....... ..may oee ..t.... v .erification if dceemed appr..priate (e.g., a call to timeI[) emergency declmar~atin, it ic recognizcd that this altematc EAL v'ording may caocc a cite The ....abov ....hcrnate. .... wordi£ng may also e u.c .... --.to de;clop a compe:natcor EAL for ....

pcriocd ;;hen a seismic montrng c yctem~v. .... capabic of dctccting OBE ic w,....t. of , ....ic A-ECL Accig......

Attibuec ....... .,,A 131 HU3 ECL: Notification of Unusual Event Initiating Condition:

Hazardous event.Operating Mode Applicability:

All Emergency Action Levels: (1 or 2 or 3 or 4 or 5)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 (PA) 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) Sustained hurricane force winds greater than 74 mph forecast to he at thme plant site in the next tour hours.(Sire

....fi t r ef natra .... r ..........

a h, ...... .....t.)Basis: PRol()I'ElIE AREA (PA\): The area thant encompasses all controlled areas within the security protected areca t~nce.SAFE 2 LY SYSItNM: A sy'stemn required tbr safe plant operation, cooling down the plant and/or placing it in the cold shutdownl condition, including the [(CS. These are typically' systems classified as sa h~tv-related.

This IC addresses hazardous events that are considered to represent a potential degradation of the level of plant safety-ef he plant.EAL # 1 addresses a tornado striking (touching down) within the PROTECTED AREA (PA I EAL #2 addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.

Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.EAL #3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA (PA).132 EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, or dam failure, oe=e-or an on-site train derailment blocking the access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011!.EAL #5 addresses the phenomena of the hurricane based on the sc~ere weather mitiuation procedure(site specific dc.... ticn).Escalation of the emergency classification level based on ICs in Recognition Categories A, F, S or C.may..~ a.. prccur;or tc a u csgnfcn ......r...ndiian..n..th.t...................h. ,t aprctwt~ andie thceee cnrckto

+pheical inldc uEAba!!.ae.t cii is fnaua....a esr impalgialhzad cvt" --zoud nc i.......d" ...........

d ...n. fo which thcied daatent .h daag ad hereul-n ..... uenee an b..... adeqtermnd-ihi rselatiely-'

hert+ tim.. framinreaseinri to he peublic.t o 0 F 5.2 133 HU4 ECL: Notification of Unusual Event Initiating Condition:

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

All Emergency Action Levels: (1 or 2 or 3 or 4)Note: The emergency director sheI~ill 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 lig-Iabie 112 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 Tew~iiablc 11t2 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 PROiL'CIED)

AREA (PA) or ISFSI nt r .....a..........

oW sidc the Proetcted A~rea] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.

(4) A FIRE within the plant PROFFTED'E A REA, (PA) or ISFSI Lfrplan wi,- .....,,,th a,.n e'uleidc ....lan r..e.t..........

rea PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

134

[able 112 (ontaimnnint Building NSCW (onling Toxiers D iesel (Generator Build inc Au'iliary Control Buildine D~iesel Fuel Oil Storace lank Punmphouse Au'iliary tlcedxi ater F'uinphouseJ Basis: FIRFI C onbustion characterized b\ heat and light. Sources of smoke such as slipping drix e belts oi overheated electrical equipment do not constitute FIRE;S. i)bserx ation of tl~ame is prelferred hut is NO I required if large quantities of smoke andi heat are obsers ed.PRO I 1.0' CII) ARI A (PA): t he area thai encompasses all controlled areas wi thin lhe security proteeted area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of a p~otential degradation of the level of plant safety- 4f*heplan.

EAL # 1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE eeotd-binclude a drop in fire main pressure, automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment-pweie, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed.

Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.If an actual FIRE is verified by a report from the field, then EAL # 1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this 135 verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

EAL #3 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA tPA) not extinguished within 60-minutes may also potentially degrade the level of plant safety. This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA (I A).[nten.........

n.v wit.............i~

the pla~nt P.-actxtd .A.-a.]EAL #4 If a FIRE within the plant or ISFSI p/.a:nts w:ith an: !SFS! oz:dsidc t!:c plant P&ateeted A~rea]PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded.

The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish.

Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

In dd~iecinAppendix R to 10 CFR 50, requires, among other considerations, the use of I-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergency classification level we'i:!d-be.-'iaijses IC CA6 or SA9.136 A. r^.ztz in thc nnd Basis szzticn., incIudc u thc ,erm, ISFSI o:÷c Ato hc .............

i ECL .A.;i~nz.-nt ,A.ributc3:

.1. I.A 137 I'WRv ULAI IIARKILK Potential Loss 6.A This threshold addresses any other factors by the emergency director in determining whether the fuel clad barrier is potentially lost. The emergency director should also consider whether or~--re4to declare the barrier potentially lost in the event that barrier status cannot be monitored.