Text

Response to Request for Additional Information: 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
	ML18194A252
Person / Time
Site:	FitzPatrick
Issue date:	07/12/2018
From:	David Gudger; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
	JAFP-18-0068
	Download: ML18194A252 (106)
	v • d • e

Exelon Generation ~ 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp com 10 CFR 50.90 10 CFR 50, Appendix E JAFP-18-0068 July 12, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 Docket No. 50-333 James A. FitzPatrick Nuclear Power Plant Independent Spent Fuel Storage Installation General License SFGL-12 Docket No.72-012

Subject:

Response to Request for Additional Information 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"

References:

1) Letter from David T. Gudger (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission - 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," dated January 31, 2018 (ML18037A786)

2) Electronic Mail Request from Tanya Hood (U.S. Nuclear Regulatory Commission) to Richard Gropp, et al. (Exelon Generation Company, LLC) -

Draft RAls - FitzPatrick - LAR to Adopt EAL Schemes Pursuant to NEI 99-01, Revision 6, dated June 7, 2018

3) Electronic Mail Request from Tanya Hood (U.S. Nuclear Regulatory Commission) to Bryan Hanson et al. (Exelon Generation Company, LLC) -

FitzPatrick RAls - LAR to Adopt EAL Schemes Pursuant to NEI 99-01, Revision 6, dated June 13, 2018(ML18164A365)

By letter dated January 31, 2018 (Reference 1}, Exelon Generation Company, LLC (Exelon) submitted a License Amendment Request (LAR) to support changes to the Emergency Plan for the James A. FitzPatrick Nuclear Power Plant (FitzPatrick). Specifically, the proposed changes involve revising the Emergency Plan for FitzPatrick to adopt the Nuclear Energy lnstitute's

U.S. Nuclear Regulatory Commission Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes Docket No. 50-333 and 72-012 July 12, 2018 Page 2 (NEl's) revised Emergency Action Level (EAL) schemes described in NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," which have been endorsed by the NRC as documented in an NRC letter dated March 28, 2013 (ML12346A463).

Appendix E, Section IV.B.2, of 10 CFR 50 stipulates that a licensee desiring to change its entire EAL scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. The currently approved Emergency Plan EAL schemes for the cited facilities are based on the guidance established in NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels." Exelon is proposing to adopt the EAL schemes based on the latest NRC-endorsed guidance, which is described in NEI 99-01, Revision 6.

In a U.S. Nuclear Regulatory Commission (NRC) electronic mail message dated June 7, 2018 (Reference 2), the NRC indicated that it had reviewed the information submitted in the Reference 1 letter pertaining to the proposed LAR and requested additional clarifying information to support its continued review. The Reference 2 electronic mail request contained a draft NRC questions, which were further discussed during a June 13, 2018, teleconference between Exelon and NRC representatives. Subsequently, in an electronic mail message dated June 13, 2018 (Reference 3), the NRC formally issued its Request for Additional Information (RAI) related to the amendment request and requested a response within 30 days.

Accordingly, Attachment 1 provides Exelon's response to the RAI contained in the Reference 3. includes revised redline and revised clean pages for the affected EAL Basis documents along with revised procedure matrix pages for FitzPatrick.

Exelon has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in the Reference 1 submittal. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Furthermore, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the State of New York of this RAI response by transmitting a copy of this letter and the supporting attachments and enclosures to the designated State Official.

There are no regulatory commitments contained in this submittal.

U.S. Nuclear Regulatory Commission Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes Docket No. 50-333 and 72-012 July 12, 2018 Page 3 If you have any questions concerning this submittal, please contact Richard Gropp at (610) 765-5557.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 12th day of July 2018.

R;]spetfully, ~

. ~

~ ---- '~

J yu-David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: - Response to the Request for Additional Information - 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" - Revised Radiological Emergency Plan Annex Information for James A.

FitzPatrick Nuclear Power Plant

Enclosure 2B - Revised Redline EAL Basis Document Pages

Enclosure 2C - Revised EAL Clean Basis Document Pages

Enclosure 2E - Revised Procedure Matrix Pages cc: w/ Attachments/Enclosures Regional Administrator - NRC Region I NRC Senior Resident Inspector- James A. FitzPatrick Nuclear Power Plant NRC Project Manager, NRR - James A. FitzPatrick Nuclear Power Plant A. L. Peterson, NYSERDA

ATTACHMENT 1 Response to the Request for Additional Information 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" Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes James A. FitzPatrick Nuclear Power Plant Page 1 of XX Response to Request for Additional Information 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" By letter dated January 31, 2018 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a License Amendment Request (LAR) to support changes to the Emergency Plan for the James A. FitzPatrick Nuclear Power Plant (FitzPatrick). Specifically, the proposed changes involve revising the Emergency Plan for FitzPatrick to adopt the Nuclear Energy lnstitute's (NEl's) revised Emergency Action Level (EAL) schemes described in NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," which have been endorsed by the NRC as documented in an NRC letter dated March 28, 2013 (ML12346A463).

Appendix E, Section IV.B.2, of 10 CFR 50 stipulates that a licensee desiring to change its entire EAL scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. The currently approved Emergency Plan EAL schemes for the cited facilities are based on the guidance established in NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels. " Exelon is proposing to adopt the EAL schemes based on the latest NRC-endorsed guidance, which is described in NEI 99-01, Revision 6.

In a U.S. Nuclear Regulatory Commission (NRC) electronic mail message dated June 7, 2018 (Reference 2), the NRC indicated that it had reviewed the information submitted in the Reference 1 letter pertaining to the proposed LAR and requested additional clarifying information to support its continued review. The Reference 2 electronic mail request contained a draft NRC questions, which were further discussed during a June 13, 2018, teleconference between Exelon and NRC representatives. Subsequently, in an electronic mail message dated June 13, 2018 (Reference 3), the NRC formally issued its Request for Additional Information (RAI) related to the amendment request and requested a response within 30 days.

The questions included in the Reference 3 electronic mail message are restated below followed by Exelon's response.

Response to NRC Questions Section 4.3, "Instrumentation Used for EALs," to NE/ 99-01, Revision 6, states: "Scheme developers should ensure that specific values used as EAL setpoints are within the calibrated range of the referenced instrumentation." Confirm that all setpoints and indications used in the FitzPatrick EAL scheme are within the calibrated range(s) of the stated instrumentation and that the resolution of the instrumentation is appropriate for the setpointlindication.

Response to Request for Additional Information License Amendment Request Adoption of NEl 99-01, Revision 6 EAL Schemes James A. FitzPatrick Nuclear Power Plant Page 1 of 10 Response to Request for Additional Information 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" By letter dated January 31, 2018 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a License Amendment Request (LAR) to support changes to the Emergency Plan for the James A. FitzPatrick Nuclear Power Plant (FitzPatrick). Specifically, the proposed changes involve revising the Emergency Plan for FitzPatrick to adopt the Nuclear Energy lnstitute's (NEl's) revised Emergency Action Level (EAL) schemes described in NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," which have been endorsed by the NRC as documented in an NRC letter dated March 28, 2013 (ML12346A463).

Appendix E, Section IV.B.2, of 10 CFR 50 stipulates that a licensee desiring to change its entire EAL scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. The currently approved Emergency Plan EAL schemes for the cited facilities are based on the guidance established in NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels." Exelon is proposing to adopt the EAL schemes based on the latest NRG-endorsed guidance, which is described in NEI 99-01, Revision 6.

In a U.S. Nuclear Regulatory Commission (NRC) electronic mail message dated June 7, 2018 (Reference 2), the NRC indicated that it had reviewed the information submitted in the Reference 1 letter pertaining to the proposed LAR and requested additional clarifying information to support its continued review. The Reference 2 electronic mail request contained a draft NRC questions, which were further discussed during a June 13, 2018, teleconference between Exelon and NRG representatives. Subsequently, in an electronic mail message dated June 13, 2018 (Reference 3), the NRC formally issued its Request for Additional Information (RAI) related to the amendment request and requested a response within 30 days.

The questions included in the Reference 3 electronic mail message are restated below followed by Exelon's response.

Response to NRC Questions Section 4.3, "Instrumentation Used for EALs," to NE/ 99-01, Revision 6, states: "Scheme developers should ensure that specific values used as EAL setpoints are within the calibrated range of the referenced instrumentation." Confirm that all setpoints and indications used in the FitzPatrick EAL scheme are within the calibrated range(s) of the stated instrumentation and that the resolution of the instrumentation is appropriate for the setpointlindication.

Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes James A. FitzPatrick Nuclear Power Plant Page 2of10

Response

As part of Exelon's Emergency Action Level Scheme change process each threshold that is derived from plant instrumentation has been verified to be within the instrument's range in accordance with EP-AA-120-F-08, "Emergency Action Level (EAL) Numerical Change." For Exelon EAL HU6.5, the 255-foot threshold value is determined by lake water level in the screen well intake structure at the 255-foot floor level elevation.

The proposed EAL RA3. 1 includes either the Central Alarm Station (GAS) or the Secondary Alarm Station (SAS) as threshold criteria. If the GAS and SAS can both provide access to areas required to assure safe plant operations, explain why the EAL does not provide an "AND" logic to the GAS and SAS, or select the primary station as the threshold value as provided in accordance with endorsed guidance.

Response

The primary station has been selected as the Central Alarm Station (CAS), and the Secondary Alarm Station (SAS) has been removed from EAL RA3.1.

The Basis discussion for EAL RU3 states, in part: "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."

Explain how a decision-maker can quickly and accurately determine whether or not a letdown radiation monitor alarm is due to clad damage. Altemative/y, revise the EAL RU3 basis to remove the identification of fuel cladding degradation as a criterion.

Response

The following sentence has been removed from the Basis discussion for EAL RU3.

"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."

The proposed Fission Product Barrier EAL CT3 - Potential Loss 3 threshold value includes the qualifier "and rising" to the maximum containment pressure. NE/ 99-01, Revision 6, provides that the values used to assess EALs should be valid. The fact that containment pressure has reached the maximum design pressure represents itself a potential loss of containment. The inclusion of "and rising" could result in classification delays for valid containment pressure Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01 , Revision 6 EAL Schemes James A. FitzPatrick Nuclear Power Plant Page 3of10 conditions that are substantially above the maximum design pressure because the pressure was not continuing to rise.

Remove "and rising" from the proposed Fission Product Barrier CT3 - Potential Loss 3 threshold value, consistent with the endorsed guidance, or explain how a containment pressure in excess of design pressure, with a lowering pressure due to barrier degradation, would be appropriately assessed.

Response

The qualifier "and rising" has been removed from the threshold for EAL CT3 - Potential Loss 3.

The proposed EALs MA 1 and CU1 imply that emergency diesel generator (EOG) A, EOG B, EOG C, and EOG O are independent power supplies, each of which is capable of powering emergency buses 10500 and 10600. This is consistent with the first bulleted example in the Basis section. However, the FitzPatrick Technical Specifications and Final Safety Analysis Report indicate that FitzPatrick has two subsystems capable of powering emergency buses 10500 and 10600. These subsystems each consist of two emergency diesel generators.

Explain whether or not the four EOGs provided in the threshold value for EALs MA 1 and CU1 can independently provide required power for a spectrum of events. If the EOGs cannot independently provide required power for a spectrum of events, then revise the MA 1 threshold value and Basis discussion as appropriate.

Response

Although an Emergency Diesel Generator (EOG) "Subsystem" is defined as a pair of EDGs which have the capability to power their respective emergency bus, the FitzPatrick EOG and emergency electrical distribution systems are designed such that a single EOG can be operated to power its respective emergency bus and power a reduced compliment of safety-related loads.

The normal Operating Procedure for the EDGs (i.e., OP-22), specifically allows for operation of a single EOG tied to its respective emergency bus.

This ability is even part of the automatic starting sequence design of an EOG Subsystem during a Loss of Coolant Accident (LOCA). If the EDGs fail to come up to speed as a matched pair, the EOG tie breaker will not auto-close (both engines must activate their 200 rpm relays within three seconds to allow force parallel closure of the tie breaker). In this case, when the first EOG reaches 90% of rated voltage, its output breaker will close to repower the emergency bus and the other EOG output breaker would be blocked from auto-closing onto the emergency bus.

This circuit logic is essentially looking for a failure of one EOG to start for any reason.

In either case, a single EOG rating is normally 2600 kW (provisions are available to operate above rated load for limited periods of time). In a LOCA situation, 2600 kW is sufficient to power a single Core Spray pump and a single Residual Heat Removal Pump, which are automatically re-sequenced onto the emergency bus after it is repowered by the single EOG .

Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes James A. FitzPatrick Nuclear Power Plant Page 4of10 The second Residual Heat Removal pump powered from that emergency bus is blocked from automatically re-sequencing onto the bus to prevent overloading the bus during initial EOG loading. Operation of additional emergency loads is then performed at the discretion and direction of the operating shift within the allowed loading limits of the single EOG.

This single EOG capability is generically described in UFSAR Section 8.6-5, Step 6. The lead-in sentence: "Although no credit for accident mitigation is taken, the design of the EOG system is such that if either diesel generator of an emergency AC power source fails to start in response to the automatic start signal. .. ," simply means that no credit is taken in the Technical Specifications for that train as far as accident mitigation is concerned. As part of the Emergency Plan, a single EOG will power a single emergency bus and will provide sufficient power to operate safety systems including multiple low-pressure Emergency Core Cooling System (ECCS) injection pumps.

a. For EALs MAS and CA2, Exelon proposed a wording modification to the NRG guidance contained in EPFAQ 2016-02, "Clarification of Equipment Damage as a Result of a Hazardous Event." 5 This modification affects a note for the threshold values. The key wording change is identified in bold as follows:

EPFAQ 2016-02 If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Exelon proposed For SAFETY SYSTEMS with multiple trains if the hazardous event only resulted in VISIBLE DAMAGE or degraded performance to the one train, then this emergency classification is not warranted.

This is a change of intent from the NRG guidance contained in EPFAQ 2016-02, which was that an Alert should not be declared unless there was VISIBLE DAMAGE resulting from the hazardous event, with no indications of degraded performance. Without this condition, an Alert could be declared even if the affected equipment was not currently required to be in operation. Align EALs MAS and CA2 EALs with the intent of EPFAQ 2016-0,2 or provide a justification that supports the revised MAS and CA2 in EAL notes.

b. For EALs MAS and CA2, Exelon proposed a wording modification to the NRG guidance contained in EPFAQ 2016-02. This modification affects threshold value 2.a. The key wording change is identified in bold as follows:

Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes James A. FitzPatrick Nuclear Power Plant Page 5of10 EPFAQ 2016-02 Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode.

Exelon proposed Event damage has caused indications of degraded performance or VISIBLE DAMAGE to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.

This is a change of intent from the NRG guidance contained in EPFAQ 2016-02. As the threshold value includes "or VISIBLE DAMAGE," an Alert could be declared when the only impact is visible damage to both trains. Revise EALs MA5 and CA2 to align with the intent of EPFAQ 2016-02, or provide a justification that supports the revised MA5 and CA2 EAL notes, as provided by Exelon, for Fitz Patrick.

c. Exelon proposes the addition of the following alternative condition to threshold value 2.b for EALS MA5 and CA2:

An additional train of the SAFETY SYSTEM is inoperable or out of service.

It appears that the above additional threshold value is intended to require the declaration of MA5 or CA2 whenever a hazardous event has caused degraded performance or visible damage to one train of a SAFETY SYSTEM, whenever an additional train of the safety system is inoperable or out of service. The intent of EPFAQ 2016-02 is to declare an Alert if the hazardous event has resulted in degraded performance to the one train, and VISIBLE DAMAGE or degraded performance of the second train. Additionally, it appears as though the above alternative condition proposed by Exelon for EALs MA5 and CA2 would not result in an Alert declaration based on the addition of the following note:

For SAFETY SYSTEMS with multiple trains if the hazardous event only resulted in VISIBLE DAMAGE or degraded performance to the one train, then this emergency classification is not warranted."

Revise EALs MA5 and CA2 to align with the intent of EPFAQ 2016-02, or provide a justification that supports the revised MA5 and CA2 EAL notes, as provided by Exelon, for Fitz Patrick.

5 ADAMS Accession No. ML17195A299

Response

EALs MA5 and CA2 have been revised as described below to clarify their applicability to SAFETY SYSTEMS with two (2) or more trains, where at least one train exhibits degraded performance and the other train has either visible damage or degraded performance. The Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes James A. FitzPatrick Nuclear Power Plant Page 6of10 following terminology changes were made to be consistent with terminology used by Operators and to minimize confusion. The word "needed" was changed to "required" in the Initiating Condition (IC) and to "required by Technical Specification" in the EAL, and the reference to the phrase "out of service" was removed. The changes are consistent with the NRG-endorsed NEI 99-01, Revision 6, guidance as clarified by the NRC's response described in Emergency Preparedness Program Frequently Asked Question (EPFAQ) 2016-002 and further discussed during an April 10, 2018, teleconference between Exelon and NRC representatives. Therefore, there should no longer be any potential ambiguity in applying these EALs.

Revised the wording for EALs MA5 and CA2 as follows:

Note:

This EAL is only applicable to SAFETY SYSTEMs having two (2) or more trains.

If the affected SAFETY SYSTEM train was already inoperable before the hazardous event occurred, then this emergency classification is not warranted.

If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

If a hazardous event occurs and it is determined that the conditions of MA5 [CA2J are not met, then assess the event via HU3, HU4, or HU6.

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

Other events with similar hazard characteristics as determined by the Shift Manager AND

b. Event damage has caused indications of degraded performance to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.

AND

c. EITHER of the following:

Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.

OR

Event damage has resulted in VISIBLE DAMAGE to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.

Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01 , Revision 6 EAL Schemes James A. FitzPatrick Nuclear Power Plant Page 7of10

a. For EALs MU7 and CU4, it appears that if only Out-of-Plant cellular phones were available, then FitzPatrick site would not be able to communicate with onsite personnel as needed to conduct routine operations. Additionally, it does not appear that Out-of-Plant cellular phones would support communications with offsite organizations and the NRG without resorting to relaying of information.

Justify using Out-of-Plant cellular phones as a means to support Onsite, Offsite, and NRG communications if no other communication method is available, or revise accordingly. This justification should explain how communications could be completed without resorting to extraordinary means as discussed in the proposed FitzPatrick Emergency Classification Technical Basis Document.

b. For EALs MU7 and CU4, the staff could not determine whether Plant Satellite Phones, refers to the TSC satellite phone, the handheld satellite phones, or both. Additionally, it does not appear that Plant Satellite Phones would support communications with offsite organizations and the NRG without resorting to relaying of information.

Justify using Plant Satellite phones as a means to support Offsite and NRG communications if no other communication method is available, or revise accordingly. This justification should explain how communications could be completed without resorting to extraordinary means as discussed in the proposed FitzPatrick Emergency Classification Technical Basis Document.

Response

a. FitzPatrick maintains installed out-of-plant cellular phones in the Control Room Shift Manager's Office (1), Technical Support Center (TSC) (3), Operations Support Center (OSC) (1), and CAS/SAS (1). The out-of-plant cellular phones are configured within each location to function like a normal desk telephone, but are not connected to the site phone switch and access cellular service via remote installed antennae. These devices are included in periodic surveillances of communications equipment, are in an always-ready state, and are included in the Emergency Telephone Directory as backup phone numbers in these locations. No extraordinary method is required to make use of the devices, they function as a normal desk phone and the user does not need to leave the buildings to use the devices.

Communication with onsite personnel via installed out-of-plant cellular phones would be limited during times of normal phone system failure to other cellular devices (fixed and hand-held) and satellite phone devices (e.g., installed device in Control Room, hand-held, and deployable) that are available at the station including personal cellular phones and spare site maintained cellular phones. Additionally, out-of-plant cellular phones and satellite phones are maintained as backup communications at the Emergency Operations Facility (EOF).

Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes James A. FitzPatrick Nuclear Power Plant Page 8of10

Installed out-of-plant cellular phones support external communications with offsite organizations without the need to relay information. The cellular phones bypass the site hardline telephone system so that during times of system failure the cellular phones are available to be used to directly contact outside agencies (e.g., NRC, vendors, State and County agencies, etc.) utilizing the cellular phone provider network and are strategically placed in the Control Room, CAS/SAS, TSC, and OSC as mounted desk phones.

The out-of-plant cellular phones function as normal desk phones to the user but bypass the site's hardline and Voice over Internet Protocol (VoIP) phone systems so they are not affected by system outages that could affect these other phone systems.

b. Plant satellite phones include: 1) the fixed permanently installed unit in the Control Room, which functions without additional setup; 2) portable handheld satellite phones staged in the emergency facilities including Control Room, EOF, TSC and OSC; and 3) deployable satellite phones staged in the emergency response facilities.

The fixed satellite phone in the Control Room can be utilized from the Control Room without resorting to relaying of information. The unit is maintained in a ready-state for use and no setup, cabling or relocation to outside is required to use this device.

Deployable satellite phones require some setup (i.e., running cables to external antennae, and the handheld satellite phones require the user to be outside.

Communication utilizing the installed out-of-plant cellular phones and installed satellite phone (Control Room Shift Manager Office area) ensure communications can be made to the offsite agencies, NRC and between emergency facilities when loss of hardline and VOiP phone systems occur without the need for extraordinary means such as relaying. Additionally, staged satellite phones (deployable and hand-held) are available for setup to provide additional service in the emergency facilities and from outside if needed. The titles in Tables M-3 and C-1 have been revised to specify "Installed Out-of-Plant Cellular Phones" and "Plant Satellite Phones (Installed in CR or deployable)."

Explain how the term "Security Force" is equivalent to "security supervision," as the intent of EALs HU1.1, HA 1.1, and HS1.1, is to ensure an individual specifically trained to identify a hostile action and communicate with the control room is tasked with this responsibility, or revise accordingly.

Response

The term "Security Force" has been replaced with "Security Supervisor" in the FitzPatrick EALs HU1.3, HA1.2, and HS1.

Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes James A. FitzPatrick Nuclear Power Plant Page 9of10 Concerning EAL HS2, the Basis discussions include the following:

The time period to establish control of the plant starts when either:

a) [c]ontrol of the plant is no longer maintained in the Control Room Or b) [t]he last Operator has left the Control Room, whichever comes first.

The first condition implies that as soon as control of the plant is no longer maintained in the Control Room, that the time period to establish control at the alternate location starts. It is not clear to the NRG staff whether this time should start "when control of the plant cannot be maintained." It appears that the second condition would provide a more clear and consistent start time for the declaration of EAL HS2. Provide clarification to address NRG staff's concern, or revise accordingly to provide a clear 30 minute start time that supports a timely and consistent event declaration.

Response

The phrase "Control of the plant. .. " was changed to "Control of needed safety functions ... " to more clearly identify when the time to establish control of key safety functions starts.

RAl-10 The proposed EAL HU4.2.b, requiring validation of the seismic event, is not consistent with NE/

99-01, Revision 6. Specifically, the proposed EAL criterion HU4.2.b does not include that the occurrence of a seismic event is confirmed by the Shift Manager, as provided in the NE/ 99-01, Revision 6, Developer's Notes.

a. Add a condition that the Shift Manager confirms the occu"ence of a seismic event, as provided by NE/ 99-01, Revision 6, or provide further justification as to why this variance from endorsed guidance is acceptable.

b. Explain why the basis discussion includes typical lateral acceleration values instead of site-specific values, or revise accordingly.

Response

a. The following bullet has been added to EAL HU4.2.b:

If the above bullets are not able to be confirmed, then the occurrence of a seismic event is confirmed in manner deemed appropriate by the Shift Manager or Emergency Director.

Response to Request for Additional Information License Amendment Request Adoption of NEI 99-01, Revision 6 EAL Schemes James A. FitzPatrick Nuclear Power Plant Page 10of10

b. The typical lateral acceleration value was removed from the affected EAL Basis section.

Site personnel will be able to readily feel and recognize a seismic event consistent with the operating basis earthquake as discussed in the Basis statement noted below:

"Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event..."

RAl-11 The FitzPatrick EAL alternative method (e.g., wall board) for presenting EAL scheme information is not consistent with the proposed EAL Technical Basis document. For example, the FitzPatrick Technical Basis document threshold value for MA4 is EGGS Injection instead of EGGS Actuation as identified on the FitzPatrick EAL alternative method. This could lead to inaccurate or delayed emergency classifications. Explain how the method is technically accurate and addresses human factors issues that could impact timely and accurate EAL assessments.

Response

The Fitzpatrick EAL alternative method (e.g., wall board/procedure matrix) has been reviewed and revised to ensure consistency with the Fitzpatrick Technical Basis.

References

1. Letter from David T. Gudger (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - 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," dated January 31, 2018(Ml18037A786)

2. Electronic Mail Request from Tanya Hood (U.S. Nuclear Regulatory Commission) to Richard Gropp, et al. (Exelon Generation Company, LLC) - Draft RA ls - FitzPatrick - LAR to Adopt EAL Schemes Pursuant to NEI 99-01, Revision 6, dated June 7, 2018

3. Electronic Mail Request from Tanya Hood (U.S. Nuclear Regulatory Commission) to Bryan Hanson et al. (Exelon Generation Company, LLC) - FitzPatrick RAls - LAR to Adopt EAL Schemes Pursuant to NEI 99-01, Revision 6, dated June 13, 2018(Ml18164A365)

ATTACHMENT 2 REVISED RADIOLOGICAL EMERGENCY PLAN INFORMATION FOR JAMES A. FITZPATRICK NUCLEAR POWER PLANT EP-AA-1014 Enclosures

Enclosure 28 - Revised EAL Redline Basis Document Pages

Enclosure 2C - Revised EAL Clean Basis Document Pages

Enclosure 2E - Revised Procedure Matrix Pages

Enclosure 28 Revised EAL Redline Basis Document Pages

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. Dose rate > 15 mR/hr in ANY of the areas in Table R3.

Table R3 Areas Requiring Continuous Occupancy

Main Control Room - (by survey)

Central Alarm Station - (by survey)

Secondary Alarm Station - (by survey)

OR

2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the areas in Table R4.

Table R4 Areas with Entry Related Mode Applicability Entry Related Mode Area Applicability

Reactor Building East Crescent

Reactor Building West Crescent

Reactor Building 272 Elevation Mode 3, 4, and 5

Reactor Building 300 Elevation

Relay Room

North Cable Room Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

RA3 (cont)

Basis:

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

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine if another IC may be applicable.

Assuming all plant equipment is operating as designed, normal operation is capable from the Main Control Room (MCR). The plant is also able to transition into a hot shutdown condition from the MCR, therefore Table R4 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown. This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room.

For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the elevated radiation levels preclude the ability to place shutdown cooling in service. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding beyond that required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is not warranted if any of the following conditions apply.

The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation rise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

RA3 (cont)

Basis (cont):

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 R, C or F ICs.

Basis Reference(s):

1. JAFNPP Safe Shutdown Analysis

2. NEI 99-01 Rev 6, AA3 Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

RU3 Initiating Condition:

Reactor coolant activity greater than Technical Specification allowable limits.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

1. Offgas radiation > hi-hi alarm OR

2. Specific coolant activity > 2.0 µCi/gm I-131 dose equivalent.

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.

Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category R ICs.

Basis Reference(s):

1. DVP-01.02 Offsite Dose Calculation Manual Specification 3.6.1

2. Technical Specification 3.7.5

3. Technical Specification 3.4.6

4. Technical Specification Bases 3.4.6

5. OP-31 Process Radiation Monitoring

6. NEI 99-01 Rev 6, SU3 Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

CT3 Initiating Condition:

Primary Containment Pressure / Conditions Operating Mode Applicability:

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

LOSS

1. UNPLANNED rapid drop in Primary Containment pressure following Primary Containment pressure rise.

OR

2. Primary Containment pressure response not consistent with LOCA conditions.

POTENTIAL LOSS

3. Primary Containment pressure > 56 psig and rising.

OR

4. a. Primary Containment hydrogen concentration > 6%.

AND

b. Primary Containment oxygen concentration > 5%.

OR

5. Heat Capacity Temperature Limit (HCTL) (EOP-11) 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 Threshold #1 and #2 Basis Rapid UNPLANNED loss of primary containment pressure (i.e., not attributable to Drywell spray or condensation effects) following an initial pressure rise indicates a loss of primary containment integrity. Primary containment pressure should rise 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 JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

CT3 (cont)

Basis (cont):

Potential Loss Threshold #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 Threshold #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 Threshold #5 Basis The HCTL is a function of RPV pressure, Torus temperature and Torus 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. FSAR Update Section 5.2.3

2. EOP-4 Primary Containment Control

3. UFSAR 14.6.1.3.3

4. BWROG EPG/SAG Revision 3, Sections PC/G

5. FSAR section 5.2.3.14

6. FSAR Table 7.3-6

7. BWROG EPG/SAG Revision 3, Section 18

8. EOP-11 EOP and SAOG Graphs

9. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

MA5 Initiating Condition:

Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Note:

This EAL is only applicable to SAFETY SYSTEMs having two (2) or more trains.

If the affected SAFETY SYSTEM train was already inoperable before the hazardous event occurred, then this emergency classification is not warranted.

If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

If a hazardous event occurs and it is determined that the conditions of MA5 are not met, then assess the event via HU3, HU4, or HU6.

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

Other events with similar hazard characteristics as determined by the Shift Manager AND

b. Event damage has caused indications of degraded performance to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.

AND

c. EITHER of the following:

Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.

OR

Event damage has resulted in VISIBLE DAMAGE to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.

If the only affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then this emergency classification is not warranted.

Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

For SAFETY SYSTEMS with multiple trains if the hazardous event only resulted in VISIBLE DAMAGE or degraded performance to the one train, then this emergency classification is not warranted.

If it is determined that the conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.

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. a. Event damage has caused indications of degraded performance or VISIBLE DAMAGE to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.

AND

a. ANY of the following for SAFETY SYSTEMS with multiple trains:

Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.

OR

Event damage has resulted in VISIBLE DAMAGE to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.

OR

An additional train of the SAFETY SYSTEM is inoperable or out of service.

Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

MA5 (cont)

Basis:

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

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

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

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

This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. In order to provide the appropriate context for consideration of an Alert classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues. Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has degraded performance for criteria 1.b of this EAL; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.

Indications of degraded performance address damage to a SAFETY SYSTEM train that is in operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

Operators will make a determination of VISIBLE DAMAGE based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

Escalation of the emergency classification level would be via IC FS1 or RS1.

Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

If a hazardous event occurs and the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.

This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. In order to provide the appropriate context for consideration of an Alert classification, the hazardous event must have caused indications of degraded performance or VISIBLE DAMAGE. For single train SAFETY SYSTEMS, in addition to the occurrence of the hazardous event, only 2.a of this EAL need be satisfied. In SAFETY SYSTEMS with multiple trains there must be either indications of degraded performance with the second SAFETY SYSTEM train, VISIBLE DAMAGE to the second train, or the second train is inoperable or out of service. Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has degraded performance or VISIBLE DAMAGE for criteria 2.a of this EAL; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.

Indications of degraded performance address damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

MA5 (cont)

Basis (cont):

Operators will make a determination of VISIBLE DAMAGE based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

Escalation of the emergency classification level would be via IC FS1 or RS1.

If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.

Basis Reference(s):

1. NEI 99-01, Rev 6 SA9 Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

MU7 Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

1. Loss of ALL Table M3 onsite communication capabilities affecting the ability to perform routine operations.

OR

2. Loss of ALL Table M3 offsite communication capabilities affecting the ability to perform offsite notifications.

OR

3. Loss of ALL Table M3 NRC communication capabilities affecting the ability to perform NRC notifications.

Table M3 Communication Capabilities System Onsite Offsite NRC Page/Party System (Gaitronics) X Control Room/Portable Radio X Plant Telephones (all VOIP, switched, non-switched) X X X Installed Out-of-Plant Cellular Phones X X X Plant Satellite Phones (Installed in CR or deployable) X X RECS X Dedicated Phone Lines (ENS) X X HPN and FTS 2001 X X Basis:

This IC addresses a significant loss of onsite, offsite, or NRC communication capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

MU7 (cont)

Basis (cont):

EAL #1 Basis Addresses a total loss of the communication methods used in support of routine plant operations.

EAL #2 Basis Addresses a total loss of the communication methods used to notify all Offsite Response Organizations (OROs) of an emergency declaration. The Offsite Response Organizations (OROs) referred to here are listed in procedure EP-CE-114-100-F-05, JAF Notification Fact Sheet .

EAL #3 Basis Addresses a total loss of the communication methods used to notify the NRC of an emergency declaration.

Basis Reference(s):

1. NY State Emergency Operations Center

2. NY State Warning Point

3. Alternate State Warning Point

4. State Department of Health

5. SEMO Regional Office

6. Oswego County EOC

7. Oswego County E-911 Center (Warning Point)

8. Nine Mile Point Control Rooms

9. Nine Mile Point TSC and EOF

10. JAFNPP Control Room

11. JAFNPP TSC

12. JAFNPP EOF

13. SEMO Technical Resources

14. NEI 99-01 Rev 6, SU6 Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

CA2 Initiating Condition:

Hazardous event affecting SAFETY SYSTEM required for the current operating mode.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

Note:

This EAL is only applicable to SAFETY SYSTEMs having two (2) or more trains.

If the affected SAFETY SYSTEM train was already inoperable before the hazardous event occurred, then this emergency classification is not warranted.

If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

If a hazardous event occurs and it is determined that the conditions of CA2 are not met, then assess the event via HU3, HU4, or HU6.

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

Other events with similar hazard characteristics as determined by the Shift Manager AND

b. Event damage has caused indications of degraded performance to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.

AND

c. EITHER of the following:

Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.

OR

Event damage has resulted in VISIBLE DAMAGE to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.

If the only affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then this emergency classification is not warranted.

Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

For SAFETY SYSTEMS with multiple trains if the hazardous event only resulted in VISIBLE DAMAGE or degraded performance to the one train, then this emergency classification is not warranted.

If it is determined that the conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.

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. a. Event damage has caused indications of degraded performance or VISIBLE DAMAGE to one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.

AND

b. ANY of the following for SAFETY SYSTEMS with multiple trains:

Event damage has caused indications of degraded performance to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.

OR

Event damage has resulted in VISIBLE DAMAGE to a second train of the SAFETY SYSTEM required by Technical Specifications for the current operating mode.

OR

An additional train of the SAFETY SYSTEM is inoperable or out of service.

Month 20XX JAF 2-XX EP-AA-1014 Addendum 3 (Rev X)

CA2 (cont)