ML18041A029

Forwards Emergency Action Level Verification & Validation Rept.

ML18041A029
Person / Time
Site:	Nine Mile Point, Indian Point, Ginna, FitzPatrick
Issue date:	07/06/1994
From:	Bram S CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17059A362	List: ML17059A361 ML18041A029
References
NUDOCS 9407210039
Download: ML18041A029 (853)

Text

PR.ICIER.I EY' CCELERATED RIDS PROCESSING) 0~

,.REGULATORY INFORMATION DISTRIBUTION SYSTEM (RXDS)

ACCESSION NBR:9407210039 DOC.DATE: 94/07/06 NOTARIZED: NO DOCKET FACIL:50-220 Nine Mile Point Nuclear Station, Unit 1, Niagara Powe 05000220 50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 50-247 Indian Point Station, Unit 2, Consolidated Edison Co. 05000247 50-286 Indian Point Station, Unit 3, Power Authority of Stat 05000286 50-333 James A. FitzPatrick Nuclear Power Plant, Power Autho 05000333 50-410 Nine Mile Point Nuclear Station, Unit 2, Niagara Moha 05000410 AUTH. NAME AUTHOR AFFILIATION BRAM,S.B. Consolidated Edison Co. of New York, Inc.

RECIP.NAME RECIPIENT AFFILIATXON Document Control Branch (Document Contro Desk)

SUBJECT:

Forwards "Emergency Action Level Verification 6 Validation Rept."

DISTRIBUTION CODE: A045D COPIES RECEIVED:LTR ENCL TITLE: OR Submittal: Emergency Preparedness Plans, Imp ement'g Procedures, SIZE: 94 6 ~ C NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPXES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDl-1 PD 1 1 PD1-3 PD 1 1 BRINKMAN,D. 1 1 JOHNSON,A 1 1 WILLIAMS,F 1 1 CONXCELLA,N. 1 1 MENNING,J 1 1 BRINKMAN,D 1 1 INTERNAL: NR~R- -DRSSJ PEPB 1 1 NUDOCS-ABSTRACT 1 1 01 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM PI-37 (I:.XT. 504-2083 ) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS I'OR DOCUMENTS YOU DON"-I'EED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL 13

4 P

StephenB.Bram Vice President

~

. Consolidated Edison Company of New York, Inc.

Indian Point Station July 6, 1994 Broadway 8 Bleakley Avenue Buchanan, NY 10511 Re: Indian Point Unit No. 2 Telephone (91 4) 734-5340 Docket No. 50-247 Document Control Desk US Nuclear Regulatory Commission Mail Station Pl-137 Washington, DC 20555

SUBJECT:

NUMARC/NESP-007 Based Emergency Action Levels Transmitted herewith are upgraded Emergency Action Levels (EALs) for Indian Point Unit No. 2. Consolidated Edison Company of New York, Inc., (Con Ed) and the, other New York State utilities have developed EALs which are based on the guidance provided in NUMARC NESP-007, "Methodology for Development of Emergency Action Levels" and are similar for each site.

In accordance with 10 CFR 50, Appendix E Section IV.B, these EALs are hereby submitted for NRC review and approval. This submittal consists of the enclosed EAL Generation Package which includes the Plant Specific EAL Guideline, the Fission Product Barrier Evaluation, the EAL Binning Document, the EAL Technical Bases Document, and the actual proposed EALs in tabular format. The associated Verification and Validation Report is also included to assist your review.

Should you have any questions regarding this matter, please contact Mr. Charles W. Jackson, Manager, Nuclear Safety and Licensing.

Very truly yours, Enclosure 9407210039 940706 PDR ADOCK 05000220 F PDR

Mr. Thomas T. Martin Regional Administrator Region I US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Francis J. Williams, Jr., Project Manager Project Directorate I-1 Division of Reactor Projects I/II US Nuclear Regulatory Commission Mail Stop 14B-2 Washington, DC 20555 Senior Resident Inspector US Nuclear Regulatory Commission PO Box 38 Buchanan, NY 10511

OSSI 93.402A-10-IP2 g4 r>I~

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Consolidated Edison Company Indian Point Station Unit 2 EAL Generation Package QSSX Operatlbns SUItQOrt SdWIO05, Inc.

233 Water Street 2nd Floor Plymouth, MA 02360

Table of Contents NYS EAL Upgrade Project EAL Generation Package Book 1 Section l Introduction Section 2 Plant Specific Emergency Action Level Guideline (PEG)

Section 3 Fission Product Barrier Evaluation Section 4 Emergency Action Level Binning Document Section 5 Emergency Action Levels Technical Bases Document Section 6 Emergency Action Levels Book 2 Section 7 Verification and Validation Report

U a When the NRC accepted NUMARC/NESP-007, entitled "Methodology for Development of Emergency Action Levels," as an acceptable alternative to the NUREG 0654 EAL guidance, the four nuclear utilities in New York State decided to jointly implement the new methodology. This upgrade project involved the following plants:

o Nine Mile Point Unit 1 (NMPC) o Nine Mile Point Unit 2 (NMPC)

James A. Fitzpatrick Nuclear Power Plant (NYPA) o Indian Point Unit 2 (Con Ed)

Indian Point Unit 3 (NYPA) 0 R.E. Ginna Nuclear Power Station (RGEE)

Although the upgraded EALs are site specific, one of the upgrade project's objectives was to enhance maximum conformity and consistency between the sites.

The following site specific EAL developmental documents supporting the EAL review process are enclosed:

0 Indian Point Unit 2 Plant-Specific EAL Guideline (PEG) (Section 2)

The PEG is the Indian Point Unit 2 interpretation of the NUMARC methodology for developing EALs. The PEG distinguishes from the NUMARC methodology by striking out, words and phrases that do not apply to Indian Point Unit 2. Additions are identified by underlining new words and phrases. The source of documents for PEG changes from the NUMARC methodology are listed in the references section of the PEG' Indian Point Unit 2 Fission Product Barrier Evaluation (FPBE)

(Section 3)

NESP-007 prescribes example EALs for each of the three fission product barriers. An EAL is defined by one or more plant conditions. Each EAL may consist of one or more conditions representing either a loss of barrier or a potential loss of the barrier. Some EALs may have only loss conditions, others only potential loss conditions, and some may have both loss and potential loss conditions.

Based on the number of example EALs and the number of loss and potential loss conditions, the set of conditions that can yield a given emergency classification can be determined. An evaluation of each condition or set of conditions was made to determine if it properly defines the appropriate threshold of the classification.

If a condition or set of conditions was appropriate, a comment reflecting this conclusion was recorded in this document. If a condition or set of conditions was determined to be inappropriate, it was lined out, and the reason for this conclusion was similarly recorded. The result of this evaluation is a discrete set of quantifiable EALs representing the NUMARC fission product barrier loss matrices.

Indian Point Unit 2 EAL Binning Document (Section 4)

Because the format presented in NUMARC/NESP-007 is inadequate for implementation, the EALs defined by the PEG and FPBE must be binned into categories and subcategories which support ease of use. The binning document identifies where, within the presentation scheme, each PEG/FPBE initiating condition is addressed.

Indian Point Unit 2 EAL Technical Bases Document (Section 5)

The EAL Technical Bases Document provides an explanation and rationale for each of the EALs included in the EAL Upgrade Program. It is also intended to facilitate the review process of the Indian Point Unit 2 EALs and provide historical documentation for future reference. This document is also intended to be used as a technical reference and aid in EAL interpretation by those individuals responsible for implementation of the event classification procedure.

Indian Point Unit 2 Verification 6 Validation Report (Section 6)

The Indian Point Unit 2 Verification 0 Validation Report documents the process conducted to verify and to validate the Indian Point Unit 2 EALs and supporting documentation. This document also included the comments received during validation along with comment resolutions.

The verification process was performed to ensure that the Indian Point Unit 2 EALs and classification procedures are technically correct. The Indian Point Unit 2 EAL verification was conducted prior to the EAL validation exercises. The technical accuracy of the upgraded EALs was verified through tabletop reviews which addressed the following EAL attributes:

Human engineering factors of the EAL Writer's Guide Format, appearance and terminology consistent, to the extent possible, among BWR and PWR plants involved in the EAL Upgrade Project EAL structure Clear and well defined EAL terminology Technical completeness and appropriateness for each classification level Potential for classification upgrade only when there is an increased threat to public health and safety Logical progression in classification for combinations of multiple events

The validation process ensures that the Indian Point Unit 2 EALs and classification procedures are usable and correct. It also ensures that emergency response personnel are able to consistently interpret EALs under similar conditions. The EALs were validated through observation of .emergency response organization personnel responding to simulated emergency events. The group of EALs selected for validation was sufficiently representative of all the EALs. The following attributes were tested:

User friendliness Ease of place-finding Ease of place-keeping Ease of upgrading and declassifying Potential for classification upgrade only when there is a significant increase in the potential for a threat to public health and safety Technical completeness and appropriateness for each classification level Logical progression in classification for combinations of multiple events

EQL U o golf'8(oIS pit'Qo]SC Plant Specific EAL Guideline (PEG)

Indian Point Unit 2 Operations Support Services, Inc.

233 Water Street 2nd.Floor Plymouth, MA 02360

Plant Specific EAL (IIdeline (A,H,S)

Indian Point Unit 2 IC¹: AU1 Any unplanned release of gaseous or Ilquld radloactlvlty to the environment that exceeds two times the radlologlcal Technical Specifications for 60 minutes or longer.

Op. Mode Appllcablllty Q1 (Pwr Ops) Q 2 (HSB) Q3 (HSD) Q4 (CSD) Q 5 (Refuel) Q 6 (Defuel) ~ All AU1.1 AU1.2 A valid reading on one or more of the following monitors that exceeds the "value shown" Confirmed sample analyses for gaseous or liquid releases indicates concentrations or release rates with a release duration of 60 minutes or longer in excess of two.

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'ahamas.

Mahm BZHzd&Y5fafhmbhoihz ELKHani~Gaa~hhaihx

~

IrmtimaalKEB29.hamdixQ.Iahh JLQ~titfma 2.rtr uQilml hr rfiaartluuf rtr arttraiitarfrtghhrtaaaa ER.EashDhmal Bctuatxhhoihz Gaattuua Bahama@

~599!mimmMYitxbhaihz 3KQmrmuhzrdzhhzfy.artff KKmr~raitirr rfrtaa futm ~i gaaaa Note: If the monitor readings'ra sustained for hnger than 60 minutes and the required XE mrm5r aror zmn fuun BZ. 823. tritium aorf aartiadataa liraa miih 8 rfm half assessments cannot be completed within this period, then the declaration must be made based on the valid reading. lhm rhaittrtrtbhgaaaa inrtaaftrttfartffhaith; 1Rttr mrati gamma l 2QLatr mratfhata 2Qamkhrtamma L&mradhzhftia Ihtaa ararhtftrmirrftrf m mfttbrttfain Zl&Z

Plant Specific EAL Meline (A,H,S)

Indian Point Unit 2 Bases The term Unplanned; as used in this context, includes any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions (e. g., minimum dilution flow, maximum discharge fhw, alarm setpoints, etc.) on the applicable permit.

Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

Unplanned releases in excess of two times the site technical specifications that continue for 60 minutes or hnger represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very hw in the Unusual Event emergency dass) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes. Therefore, it is not intended that the release be averaged over 60 minutes. For example, a release of 4 times TIS for 30 minutes does not exceed this initiating condition. Further, the Emergency Director should not wait until 60 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or will IRely exceed 60 minutes.

l Monitor indications arts chouf4ko calculated on the basis of the methodohgy of JLUEZ.

used whoca4lowed.

f Qgiftrmjngfjgn gf ~~gnjitafn rtf Qftfft~natf gloat~ to demonstrate compliance with 10CFR20 andloc 10CFR50 Appendix I requirements. Annual average meteorohgy 4uwddho ~

Ihaalaan adultjf& fgr Qm Ihhd mnni1gar am mnamaihfftjtr M in fiat iht,~mdugjai.

Iftghnigal5mtgifjm1hnmtfhmgihtiix mlmm limihnm ngi mgftft&tf. Itm ~ ~fgr~ mgni1gr hum Ihamlmmignfttf inEELhU12zahaaui nn httn 1imm Jhow Ittt hahal Gattrifhaiinn mlm ghutn jn; EziljiyQuftraijnaliaam Ha. DEKE hauttndix. Ixhnjnnl5mifjnn~ &zijnn R2 JE2dmiaudumngiuiilimtfftmftiftiftffnftrjtaftiftratntljigr lP2rfmigndumaai uiTiimmizmtihrftaLtima~ammaftni.

Plant Specific EAL deline (A,H,S) indian Point Unit 2 IC¹: AU2 Unexpected Increase In plant radlatlon or airborne concentration.

Op. Mode Applicability Q1(pwrops) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) RAII AU2.1 AU2.2

~~

AU2.4 Valid ~ dh

~lalatttf. direct area IIM radiation monitor readings p

Plant Specific EAL beeline (A,H,S)

Indian Point Unit 2 BaSeS Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

All of the above events tend to have hng lead times relative to potential for radiological release outside the site boundary, thus impact to public health and safety is very low.

In light of Reactor Cavity Seal failure, incidents at two different PWRs and loss of water in the Spent Fuel Pit/Fuel Transfer Canal at a BWR all occurring since 1984, explicit coverage of these types of events via EALs ¹1 and ¹2 is appropriate given their potential for increased doses to plant staff. Classification as an Unusual Event is warranted as a precursor to a more serious event.

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uuuh~allirrariiQIMilrrti asmnhlha DtmaiQiQrr aurrtrftrthxmahC Irrftrfrrhhtftrt aa it hrIQrtmmx. hh22iftrrtlirmrhahratirtn rtf QQ hhriiftttrr ftrrtihmma rrQQrtmftd.

EAL 40~ applies to plants with licensed dry storage of older irradiated spent fuel to address degradation of this spent fuel.

~ ~~

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EALL addresses unplanned increases in inhalant radiation levels that represent a degradation in the control of radioactive material, and represent a potential degradation in the level of safety of the plant. JQfjgatirtQ gf Qrhr rQriigtigQ g rQlritiQikref ~gimQL ifQrith jzrftQ~g Q

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~gjQt rtr Qii~Qifrh ttrtrm ~zf+ tiff~ thrall Qrgifr afgfilg idggfjQigIQ QzQ f!GER titty RfRHB ~giQt 5K QifKQikillQrQYM92 Klrtrrtl!YIIJIIQttiiiftlrttg@ This EAL escalates to an Alert per IC AA3, if the increases impair the ifQrfti gf safe operation. Qaly grgigQgftri 393bdifIQgr~ Qifr SZulgjriftrQrijQ ihh E8. 0 BYWAY IrQQIIQI~KBftigRQKrtrt@>~rl rhrr tie rQIIQIrtQtarx @Qadi tftmugmrxmrhttirtQ lmh tbathtriftfhr mmmd 22fimm tttrt ahrm adartiQL

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Plant Specific EAL rOdeline (A,H,S)

Indian Point Unit 2 IC¹: AA1 Any unplanned release of gaseous or llquld radloactlvlty to the environment that exceeds 200 times radlologlcal Technical Speclflcatlons for 15 minutes or longer.

Op. Mode Appllcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All AA1.1

~

AA1.2 A valid reading on one or more of the following monitors that exceeds the "value shown" IBla!

or release rates tttitb a LhuilHftlhimz

~~pa ftf mitttt~ gr, Igmtt: in excess of ~

Confirmed sample analyses for gaseous or liquid releases indicates concentrations

~

BZHaat ~ YkhEhxe Jdzhz ELKEhoi~Qaahfmy! hhnitz 5Xla9z 5XluGpa 2ahs2xaxE 2Kum1KEB29.haufttz8xLIabh JLQglttttm 2

~E2uGilmlbr dimbfftfiat:mtmittftftnahh aam ER.Eash DhauaalhatYidxhhaihz 2KiuBz Gaaaum Ehhmm;

~RahnhmhctiYhxbhaihz 22BuEz 1K aunt@ Mihah huChand KQ aunhx~ dam fatm nlthhaaap ZQ am5x zx zun fatm L121. L122. tfitittmzd u tttiathim nilh ~ Rdax huE Note: If the monitor readings' sustained for hnger than 1 5 minutes and the required Ihuu assessments cannot be completed within this period, then the declaration must be made based on the valid reading.

AA1.3 AA1.4 reater-than-

Plant Specific EAL (deline (A,H,S)

Indian Point Unit 2 Bases Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

This event escalates from the Unusual Event by escalating the magnitude of the release by a factor of 100. Prorating the 500 mR/yr criterion for both time (6766 hr/yr and the 200 multiplier, the associated site boundary dose rate would be 10 mR/hr. The required release duration was reduced to 15 minutes in recognition of the increased severity.

Monitor indications shoufd4e nil calculated on the basis of the methodohgy of average meteorohgy chouktko m used wheca4lowecL IL32QLJ29i9rminaiian Qf Ihtt magrliilldR uf BttIQQRR mf EHEmlre ~ Annual Ihanlarm aaiauinh hr Ihalhbd munihza amaummihrttlx miinmmm Iaahnlmlkmaifiaalhn Ladi~iiYiiv.mbma limihnrtt ntti ma tt~hd.

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2. 2199Z.lhittrmhaIIgnttf Ihahhmiiuhaf BttlmfrnntfEmma 2

Plant Specific EAL (deline (A,H,S) indian Point Unit 2 IC>>: AA2 Major damage to Irradiated fuel or loss of water level that has or will result In the uncovering of Irradiated fuel outside the reactor vessel ~

Op. Mode Applicability Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All AA2.1 AA2.2 Qgnlifmfttlmlninttflalarm on one or more of the following radiation monitors D5ltiilngIEQl fllQlilnmngft QKREI tnt KlllQfRQ Qtiiftflheal hZlglnQ QfnHM:

EZK.~QantainmftnthmaHzilm EH.Ettftl2zagft ihildiaahrmhhnihz EL222L~QnntainmttnIBighB@lintinn hraa hhuuhzr.

AA2.3 AA2.4

@later-lave Wess4ha+sit he-spent-fuel!-and4uel-transfer-

Plant Specific EAL Celine (A,H,S)

Indian Point Unit 2 Bases This IC applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage, which is discussed in NUMARC IC AU2, "Unexpected Increase in Plant Radiation or Airborne Concentration."

NUREG4818, "Emergency Action Levels for Light Water Reactors," forms the basis for these EALs.

irradiated fuel is kcated such as reactor cavity, reactor vessel, or spent fuel pool.

~+lrft EALs arfLrlftfjagfby the specific area where haauzrtalrgjhfituftihzifjjjaaituzm'hd tfjaftrfaamx farftaigr aafiYiixrthiftrihihrramftmftai rtlirmrjiaiftrltuftl mhhh rftmflhia uafttfaftuied rtr uruzairrthflamBhas Ibh iftrrrIIartjum huhtftamkhallymhfmf iamxjurjfrmihiaaiftfljat;rftam jaarftamdia&ta jfarfthma rftmfjtufzfhmmufurfaftrfia~mrfj.tagft ~murmftriarggftdurmfjurjag iftjuftjjaguaftraijrta~

There is time available to take corrective actions, and there is little potential for substantial fuel damage. In addition, NUREG/CR-4982, Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82," July 1987, indicates that even if corrective actions are not taken, no prompt fatalities are predicted, and that risk of injury is low. In addition, NRC Information Notice No. 9048, "KR-85 Hazards from Decayed Fuel presents the following it its discussion:

In the event of a serious accident involving decayed spent fuel, protective actions would be needed for personnel on site, while offsite doses (assuming an exclusion area radius of one mile from the plant site) would be well behw the Environmental Protection Agency's Protective Action Guides. Accordingly, it is important to be able to properly survey and monitor for Kr-85 in the event of an accident with decayed spent fuel.

~~ h jafjggijrta lb' jfarftjja ibid ufhftlmmmm.EBLhh22hutlaftumm. Srmihmhaa

~ juftlgartlur rftjuftjjagrdadilr ~

jfarftljafjjualjaamhm rjigaaftft ia i'farftjrtf ~ tutti rtijlftrisa + ~ ~tftargfjrta, ~ ~ ~~ ~ ~

jaihahftlimmlftrmnuL~uhamalha rtf Rmitf rmhr lfarftjmuhialm& rftrtuii:rj.~A u~gLiia h

Thus, an Alert Classification for this event is appropriate. Escalation, if appropriate, would occur via Abnormal Rad IeveVRadiological Effluent or Emergency Director judgement.

Ehiftrftam;

l Plant Specific EAL (deline (A,H,S)

Indian Point Unit 2 IC¹: AA3 Release of radioactive material or Increases In radlatlon levels wlthln the faclllty that Impedes operation of systems required to malntaln safe operations or to establish or malntaln cold shutdown.

Op. Mode Appllcablllty 01(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All AA3.1 AA3.2 VaM ~ggjtttt~m radiation monitor reading greater than 15 mR/hr in bursae-requiring-greater than/cite-specific) 9 ~~

maintain plant safety functions.

radiation monitor readings in areas requiring infrequent access to MGI

Plant Specific EAL (deline (A,H,S)

Indian Point Unit 2 Bases Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

daalarufiaaduft Qmumatuw.mfhmamfy.mdiahaalmhihathrhflxREhr.

~ gfgjz~@I ~ thtfiIIK ~ aft02dQEIIII IQ khan EhL ik sKHd KEQ~RQK QQ19CKE'y.

This IC addresses increased radiation levels that impede necessary access to operating stations, or other areas containing equipment that must be operated manually, in order to maintain safe operation or perform a safe shutdown. It is this impaired ability to operate the plant that results in the actual or potential substantial degradation of the level of safety of the plant. The cause and/or magnitude of the increase in radiation levels is not a concern of this IC. The Emergency Director must consider the source or cause of the increased radiation levels and rates in the containment due to a LOCA. In this latter case, an SAE or GE may be indicated by the fission product barrier matrix ICs.

appropriate if the increase impairs operations at the operating unit.

"<< 0 ""i" " i 'IU.

determine if any other IC may be involved. For example, a dose rate of 15 mR/hr in the control room may be a problem in itself. However, the increase may also be indicative of high dose This IC is not meant to apply to increases in the containment dome radiation monitors as these are events which are addressed in the fission product barrier matrix ICs. Nor is it intended to apply to anticipated temporary increases due to planned events (e. g., incore detector movement, radwaste container movement, deplete resin transfers, etc.)

ay refer to44+4ta's IP-2's Abnormal Operating Instructions, emergency operating procedures, the 10CFR50 Appendix R analysis, identifying areas containing safe shutdown equipment.

Areas requiring continuous occupancy roomam Central Alarm Station g~ include the control room an

~~~gndZy EgZm5fgfjgg~ The value of 15 mR/hr is derived from the GDC 19 value of 5 rem in 30 days with adjustment for expected occupancy times. Although Section III.D.3 of NUREG-0737, Clarification of TMI Action Plan Requirements, provides that the 15 mR/hr value can be averaged over the 30 days, the value is used here without averaging, as a 30 day duration implies an event potentially more significant than an Alert.

ased on gbZZGZI radiation levels which result in exposure control measures intended to maintain doses within normal occupational exposure guidelines and limits (i. e., 10CFR20), and in doing so, will impede necessary access.

10

Plant Specific EAL (deline (A,H,S)

Indian Point Unit 2 IC>>: AS1 Boundary dose resulting from an actual or imminent release of gaseous radloactlvlty exceeds 100 mR Whole Body or 500 mR Child Thyroid for the actual or projected duration of the release.

Op. Mode Appllcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All AS1.1 AS1.2 A valid reading on one or more of the following monitors that indicates the need to assess the release with Z. Jhlftrminalhartflhfr hhgaitttdaaf fhlhtmmdfzartmmBah" hmgf ihm ggtfilfhattmtff inauuurtdirtamfhimlrugfhmin JL3HZxdfhaaartamriafft XuLQiamamdmautl!m~hrttta!M.

Note: lf the monitor reading(s) is sustained for longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading.

AS1.3

~

Valid dose assessment capability indicates dose consequences greater than 100 mR who!cbody or 500 mRchikf thyroid.

~ AS1.4 Field survey results indicate site boundary dose rates exceeding 100 mR/hr indicate child ~

~

expected to continue for more than one hour; or analyses of field survey samples thyroid dose commitment of 500 mR for one hour of inhalation.

11

Plant Specific EAL eline (A,H,S)

Indian Point Unit 2 Bases Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

~

The 100 mR IEQp integrated dose in this initiating condition is based on the proposed 10CFR20 annual average population exposure. This value also provides a desirable gradient (one order of magnitude) between the Alert, Site Area Emergency, and General Emergency dasses. It is deemed that exposures less than this limit are not consistent with the Site Area Emergency

~

class description. The 500 mR integrated chi144hyroid QQE thyroid.

dose was established in consideration of the 15 ratio of the EPA Protective Action Guidelines for ICE whoto-body and based The FSAR source terms applicable to each monitored pathway should be used in conjunction with annual average meteorology in determining indications for the monitors on that pathway.

f.BXatftmDmaiafignHa. 12.Bfttt.3. Badialhn bfgnitariaaGXafam. EK 2.JLi99LBfu.5.MI~jgngf fhahhgnjlzhgf Bftfft~~EzummBatft" Cfftf;fitft22~r 2.2mh5am.~k2 KLeEazfuunD.Snhh@B.Bum 12

Plant Specific EAL deline (A,H,S)

Indian Point Unit 2 ICff: AG1 Boundary dose resulting from an actual or imminent release of gaseous radioactivity exceeds 1000 mR Whole Body or 5000 mR Child Thyroid for the actual or proJected duration of the release using actual meteorology.

Op. Mode Appllcablllty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII AG1.1 AG1.2 A valid reading on one or more of the following monitors that FEZ.Jhfttrmiflalignuf fhabhaoitutfttaf EhlmltanCEmmumBah" hmuf fhttmt guuitfhaumttfiaazitm~fignttdlhimltu~ia JLK9Zmdfhtmurgariaftt XuLQtuamudmaat fhamftthzuuhu.

Note: If the monitor reading(s) is sustained for longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading.

AG1.3 Valid dose assessment capability indicates dose consequences whole-body or 5000 mR @}E4Nd thyroid.

greater than 1000 mR ~ AG1.4 Field survey results indicate site boundary dose rates exceeding 1000 mR/hr indicate child ~

~

expected to continue for more than one hour; or analyses of field survey samples thyroid dose commitment of 5000 mR for one hour of inhalation.

13

Plant Specific EAL deline (A,H,S) indian Point Unit 2 Bases Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

indicated if the dose exceeds 1 rem ~

The 1000 mR3EQQMoh4ody and the 5000 mR QQf cd wtNo4ody or 5 rem thyroid integrated dose are based on the EPA protective action guidance which indicates that public protective actions are QQE~ thyroid. This is consistent with the emergency class description for a General Emergency. This level constitutes the upper level of the desirable gradient for the Site Area Emergency. Actual meteorology is specifically identified in the initiating condition since it gives the most accurate dose assessment. Actual meteorology (including forecasts) should be used whenever possible.

bo based on site boundary doses for either whoto4c4y TEDE or~kl44yroilg~ggjrf, whichever is more limiting (depends on source term assumptions(s).

The FSAR source terms applicable to each monitored pathway should be used in conjunction with annual average meteorohgy in determining indications for the monitors on that pathway.

JLRdmurtgfmafftjfttnafftrttd rt trjalftfftrrrtgrtifm.

3.5mhunDmaiu&u kh.i2.Ebu.2.Badiatign Hgrtitzirtg Smfftm.KK 2.~Z. Btu.S.Jhfttrminufhrt ref fbi hhuliftttffrrtf Btthaw~Ezrtttmrfr Bah " Hftgfitrtr52921 2.Iaah5uaa.lagfIgn X2 LLatacfrgrnD.GmithfuELBurm 14

Plant Specific EAL kleline (A,H,S) indian Point Unit 2 fc¹: .HU1 Natural and destructive phenomena affecting the protected area.

Op. Mode 4ppffcabflitV Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) %All HU1.1 HU1.2 Report by plant personnel of tornado~ within ~ protected area Qgtfft! zy.

HU1.3 HU1.4 Assessment by the control room that an nutgrgl event Vehicle crash into, gf; ftLftiftgljjfttldtjgh jaggy+ plant structures or systems within has occurred. protected area boundary.

HU1.6 HU1.5 muslim Report by plant personnel of an unanticipated explosion within protected area boundary resulting in [visible damage to ~laj permanent structure or equipment. httdzgfm.

~

Report of turbine failure rgitjfjttghrbjtta lrjfiresulting in casing penetration or damage to turbines-generator seals r~jfjttgjtt gf jttjttjgg~in +i ftt HU1.?

Bhmr lttttttl ar avatar fhau~LQh5U at aih. Reudm uahr hax huttl hm lhan ~ {GhfSLlat ~

15

I I

Plant Specific EAL deline (A,H,S)

Indian Point Unit 2 Bases The protected area boundary is4ypically that part within the security isolation zone and is defined in the site security plan.

alan.

ahLNull1 Damage may be caused to some portions of the site, but should not affect ability of safety functions to operate. Method of detection can be based on instrumentation, validated by a reliable source, or operator assessment. As defined in the EPRI-sponsored "Guidelines for Nuclear Plant Response to an Earthquake, dated October 1989, a "felt earthquake" is:

An earthquake of sufficient intensity such that: (a) the inventory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic monitors of the plant are activated. For most plants with seismic instrumentation, the seismic monitors are set at an acceleration of about 0.01 g.

22dum aai hamm:~ imirumftafaiignmfhdftgftgfhnfmll2mfrumftoiaihn fg audirm unmdbauakammi.

EAL ¹QLQ 2 is based on the assumption that a tornado striking (touching down) within the protected boundary may have potentially damaged plant structures containing functions or systems required for safe shutdown of the plant. If such damage is confirmed visually or by other in-plant indications, the event may be escalated to Alert.

EAL ¹~ allows forgo control room ggagmutj to determine that an event has occurred and take appropriate action based on personal assessment as opposed to verification (i. e., an EAL ¹~4 is intended to address such items as plane or helicopter crash,,

earthquake is felt but does not register on any plant-specific instrumentation, etc.).

ocbargo~fftrg~ crash, ~ ~~gg~ jggggf that may potentially damage plant structures containing functions and systems required for safe shutdown of the plant. If the crash is confirmed to affect a plant vital area, the event may be escalated to Alert.

For EAL ¹~5, only those explosions of sufficient force to damage permanent structures or equipment within the protected area should be considered. As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to nearby structures and materials. No attempt is made in this EAL to assess the actual magnitude of the damage. The occurrence of the explosion with reports of evidence of damage (e. g., deformation, scorching) is sufficient for declaration.

The Emergency Director also needs to consider any security aspects of the explosion, if applicable.

EAL ¹QlQ.6 is intended to address main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator.

Of major concern is the potential for leakage of combustib'le fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs. Actual fires and flammable gas build up are appropriately classified via HU2 and HU3. This EAL is consistent with the definition of an Unusual Event while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment. Escalation of the emergency classification is based on potential damage done by missiles generated by the failure or by the radiological releases ~tAlA

. These latter events would be classified by the radiological ICs or fission product barrier ICs.

EAL ¹~7 covers Itj~iftfti~fake~ e precursors of more serious events.

The high water level (14.5') corresponds to the maximum wave runup as specified in the FSAR.

The hw level (A.5') corresponds to the design minimum service water bay level for design service water flow.

16

Plant Specific EAL 'deline (A,H,S) indian Point Unit 2 ICE: HU2 Fire wlthln protected area boundary not extlngulshed wlthln 15 minutes of detection.

Op. Mode Applicability Q1 (Pwr Ops) Q 2 (HSB) Q 3 (HSD) Q 4 (CSD) Q 5 (Refuel) Q 6 (Defuel) ~ All HU2.1 Qgpiirmafi fire in buildings or areas contiguous to any of the following-(eit~pecNe) areas not extinguished within 15 minutes of control room notification alarm:

Qgridartaaia2zagaIaak

'H55I Goyim)fh(alar ~

BanimEaiar laiaka Giuziura Eual mgiagaBuiidimr Hi East ErimazhuziIiaor BuihfiaaLEaaktum

~QzialomartiBuildimr 89~ Mdduutar I Eh~S Qmim! Quaird Ehm DimlQattaraitz BuildinglEualtanhham

~

huzTiiam Qmdmiar Zemi Builfiria Baiittm Bmu Qmiral hlarm2athn 17

Plant Specific EAL +deline (A,H,S)

Indian Point Unit 2 Bases The purpose of this IC is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. This excludes such items as fires within administration buildings, waste-basket fires, and other small fires of no safety consequence. This IC applies to buildings and areas that are not contiguous or immediately adjacent to plant vital areas. Verification of the alarm in this context means those actions taken in the control room to determine that the control room alarm is not spurious.

Escalation to a higher emergency class is by IC HA2, "Fire Affecting the Operability of Plant Safety Systems Required for the Current Operating Mode".

lMaad JL2~fummmftnadakmi m.huiihftjruzfftibftftmahmnflarhahuuhr anmmhftihftriaammulam. Ihaadftrft a fjrftaarmfrgjimddafbxf flmrtihftrffrtji.

18

Plant Specific EAL deline (A,H,S) indian Point Unit 2 ic¹: HU3 Release of toxic or flammable gases deemed detrimental to safe operation of the plant.

Op. Mode

>pplfcabflftV 9 1 (Pwr Ops) Q 2 (HSB) 9 3 (HSD) Q 4 (CSD) Q 5 (Refuel) Q 6 (Defuel) ~ All HU3.1 Report or detection of toxic or flammable gases that could enter ~ ~ ~

fttt~tf,within the hdhdll d~

HU3.2 Report by local, county or state officials, fthm gait Q. for potential evacuation of site ggrmttml ftr.~ operation of the plant.

19

Plant Specific EAL deline (A,H,S) indian Point Unit 2 Bases This IG is based on releases in concentrations within the@to QfQiftgfg~~ boundary that will affect the health of plant personnel or affecting the safe operation of the plant with the plant being within the evacuation area of an offsite event (i. e., tanker truck accident releasing toxic gases, etc.). The evacuation area is as determined from the DOT Evacuation Tables for Selected Hazardous Materials, in the DOT Emergency Response Guide for Hazardous Materials.

JL2 QEf E2 ~ QQ KORE sfQbf %Sift% htfi ihK EQKKtiYRQfQIKCEfKQ hEQdkflK ifmiffftftibmQftQioaQft Qfm~ Qtttffffafbmt iha afar aih.

~ KEEKitQICQIR JQ 2'!925 IhQEQfQE ii h EMhffti!Ei2 i'f fIR++95k QK 20

Plant Specific EAL (tleline (A,H,S)

Indian Point Unit 2 tCff: HU4 Confirmed security event which indicates a potential degradation ln the level of safety of the plant.

Op. Mode Appilc>>titty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Deiuel) QAII HU4.1 HU4.2 Bomb device discovered within plant protected area and trout outside the fgfiuMtjmrplant vital Other security events as determined from areaa. Contingency Plan.

Qgrtdaltaata RgragaIanh.EMGLkmhaEahr JrttakaGtmtura. Hmhr Qa~im qatar MmEREaat. Qml GhzagaluiiriilihMnarxhutriliaz JhiifiasLEartlhm.~

Quint tirimarttluilriiltRMZaltlmitdlgaarEhumKrtntrgl Quihfiag}.Qahhlramfiog Baun ard Eiagtrigal tuorud. Qaatm! Quntml Elm. DimlQartaratrz Buildirta aorf Euallaahhma.

huzTiiarx Eaarlttratar Bana MdirtgHain Ream Eoaktaura. Batbm Bmm{Grtrttutt Ihildirtrr3Z 9 alatrathrt). central hhrmRathrt. Gamuibr. Emargaacx Died.

21

Plant Specific EAL deline (A,H,S)

Indian Point Unit 2 Bases This EAL is based o defined in th

'~~? Qz~pgjg~g~~yggrtlitggggy.Qgg. Security events which do not represent at least a potential degradationin the level of safety of the plant, are reported under 10GFR73.71 or in some cases under 10CFA50.72. The plant protected area boundaty iuypic4ly that part within the security isolation zone and is

~gttfifygttfttittgftrtgg~

devices discovered within the plant vital area would result in EAL escalation.

~~~~~~~~~Qjaf~g~gttjfy,ggftftttgft~Qan, Bomb

? Iahhki.~hmmfhlmhzfQ Wttry" 22

Plant Specific EAL Qldeline (A,H,S) indian Point Unit 2 IC¹: HU5 Other condltlons existing which ln the judgement of the Emergency Director warrant declaration of an Unusual Event.

Op. Mode

>PPffcabflfty Q1 (Pwr Ops) Q 2 (HSB) 9 3 (HSD) 9 4 (CSD) Q 5 (Refuel) 0 6 (Defuel) ~ All HU5.1 Qggzyiaz gr ~ lhhh indicate a potential degradation of the level of safety of the plant.

23

Plant Specific EAL Celine (A,H,S)

Indian Point Unit 2 Bases I ~a This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the EQIIl'

'MhS 'III Examples to consider include inadequate emergency response procedures, transient response either unexpected or not understood, failure of unavailability of emergency systems i'ctions.

during an accident in excess of that assumed in accident analysis, or insufficient availability of equipment and/or support personnel.

a '&a altl this list is by no means all inclusive and is not intended to limit the discretion of the site to provide further examples:

i'owever,

~R solely as examples for consideration and it is recognized that actual events may not always follow a preconceived description.

24

Plant Specific EAL deline (A,H,S) indian Point Unit 2 Ic¹: HA1 Natural and destructive phenomena affectin the plant vital area.

pp -

Op. Mode

)f a1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) g6(Defuel) QAtl HA1.1 HA1.2 Eafihguajz jahjiaiulaoihy.rtoartrmgrartrtaraigra BE2 Mfioaiionfuun JMihai anaaiihgualfahaartmrrftddmagniiuda >kKrthgrizgoialQB KKrtmhml HA1.3 HA1.4 EAL ¹~3 shoukl specify(eit~pecific) structures containing systems and functions required for aala ftjaoinltrailon HA1.6 Q~todftftaaia GiftragaIaoi~.BEGLkm'mEatmjoiajfa Girut;turh BmzhzEahr Malm Hi Eaat. Eual 5hzaga BuildioLErimaor huxiliarx BuijdiogLEan ~~Quiiaiomftoi Building.~~Miohgaar. EhpmlGuolrol Buiidiog}.QabhBurftadioa Buomaod Elaotrioal tunnftL~QuntulBmn. Diml<aanftraiZBuijdiagandEuaj taOkhma.huxiTiaOr

'D~

Eftadmatar 2umuBuildioh Ballan EhgmEftoirgl Building 2ZQ ftjfotaiifio).Qh5.565.

HA1.5 Vehicle crash rtr ftrgiagiija jmftagiMectfng EbEh h

~ Qr 2?ujd Oauaa aOX rftQujrad aafaiir Turbine failure generated missile penet

'-damage4eer-mhhh oauaaa rtr aoittniiallx mme aoy. raftuirad aafaihrajaiadayahunnr airuoiurainhtoofna iooftarahla HA1.7 Sit~pea fic)-occurrences Bbtar lmlmtal@rtr graaiftr ihan3Z{9h5llai aiift. QB jniajtaaituOiura jfLrftjjaaaihaniha! rmdiinrtina juaaftf BmiOaEahr fbi'5

l

'I

Plant Specific EAL eline (A,H,S)

Indian Point Unit 2 BaSeS Each of these EALs is intended to address events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage. Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Releases/Radiohgical Effluent, or Emergency Director Judgement ICs.

EAL F51,1 ahould4a is based EAL~ehoWcLbe is based oQci~pecifg o+eit~pociT+ FSAR design basis of ~ hgijZgg@ aad ~ ftffjgai. Seismic events of this magnitude can cause damage to safety functions.

FSAR design basis of 100 mph. Wind loads of this magnitude can cause damage to safety functions.

EAL ¹~3 should specify~~pecifg structures containing systems and functions required for aafft pfaai gaftraiiaa Ihtmftlbmh hx mbhb natural @ad dmfaztjxftahtattmmmaat fadiaafftdiaibftautrgl rmnmadftguafftlxgjxfta bxfbaamamia shah M.~12md 12umdftiftfatiamL Ibftatfufafbftrfthau aftadhr ihhEBJ.

EAL ¹~5 is intended to address such items as plane or helicopter crash, , train crash, or barge ~~i crash, ar. fmaaai af gfajfgl~ into a plant vital area.

EAL~iaiatoadod4aaddressm the threat to safety related equipment imposed by missiles generated by main turbine rotating component failures. Th ' '

areas (RenimEahr 5mfftm. Qgzfmah Rzagft tunhaadajuinL fhfuftliagEver Ghzagft IaokaadajaiaLlhhldlffaJl aata. P h.l. Elaprigaj aftaftfmfjgama. DimlRmutratgr~aad Qgntzlgggrgf ~should indude all areas containing safety-related equipment, their controls, and their power supplies. This EAL is, therefore, consistent with the definition of an ALERT in that if missiles have damaged or penetrated areas containing safety-related equipment the potential exists for substantial degradation of the level of safety of the plant.

EAL ~5~covers high -iaftjmlake muiiia Rm gf xiiaf alaai am~umaaL Khan lmmh ~K ff.aumaga~hia fjagdfftxfthibahiifjrtftjaltxifaiaauigmftai. laiakadafgturft lftxftlsiha! amiag ohms Gmimuahr fhmibrftalmu gaftrabiliixaf utuat xiiaf muiamftai.

Ehfarmzfta;

1. hhaurmal Quaraiiag Jmiazlfaa 28JULLftx.5. affftaiixftdafa21Z21{Eatibauakel

2. EKRabdx&ajuaiigaHftggd.11L2629.~ammQ 5 SQI ~ ~2.

2. Iahhkl.2Cital hamBxlxaft BrdQatmum Malhrml

5. LlahfftdER48~1Q.hmtaffix1$ Iurbiaa gxmaftftd zialxm~ amm14522 IllERKKGZLEQBKB6XIQH.12LUB9.

Z. Iffy@ma Gmfha R14LHuuiaaaft hhrQ fL UadafftdESEBaztha KK 26

Plant Specific EAL deline (A,H,S)

Indian Point Unit 2 IC¹: Ha2 Fire or explosion affectin the operablllty of plant safety systems required to establish or malntaln safe shutdown.

Op. Mode Applf~abillty Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII HA2.1 The folhwing conditions exist:

a. Fire or exphsion in any of the following-(eC~~Tie) areas:

Qzlttfartaata GtaraaaIaohBEGLRmjimEahrIrttalra Gtiuafurft.lmimEatar ~Pit Emf. Qml ltaraaaQuilffinaEriaiaty.huziTiartr JhildirtalEaalhm.lacer Qaittaiamftitt IhMiiiL~~ltmtabaftarHaamEarttral Quilfiaa}.Qahh&utafina Haamarifl Ehdriaal uurtrtftLQmimlQuatul Haam. DimlRmftiatarihihiirIaaod Qml Iaolt hma. hutEiaz Ettadmatar Banu IhiidioLQatbux HaamiGuatral Ihilditta GZZ&~ratlatt).Qantml hlarm Statue.

AND b.

Qauafta ar aatftrttlalltr aamumzraauirad aalatlr mlatftft atfatamar rtuztura tahzatrta iriaaarahh 27

Plant Specific EAL Celine

'""'"'.~

(A,H,S) indian Point Unit 2 Bases

lIMN '

for equipment and plant areas required for the applicable mode. This will make it easier to determine if the fire or explosion is potentially affecting one or more redundant trains of

llhl""'onsulted safety systems. Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Releases/Radiological Effluent, or Emergency Director Judgement ICs.

With regard to exphsions, only those exphsions of sufficient force to damage permanent structures or equipment required for safe operation within the identified plant areas should be considered. As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to nearby structures and materials. The indusion of a "report of visible damage" should not be interpreted as mandating a lengthy damage assessment prior to dassification. No attempt is made in this EAL to assess the actual magnitude of the damage. The occurrence of the explosion with reports of evidence of declaration of an Alert and the activation of the TSC will provide the Emergency Director with the resources needed to perform these damage assessments. The Emergency Director also needs to consider any security aspects of the explosions, if applicable.

2J. ~hens. Bxinmhad Qahgftu 28

f lp

Plant Specific EAL eline (A,H,S) indian Point Unit 2 IC¹: HA3 Release of toxic or flammable gases within a facility structure which jeopardizes operation of systems required to maintain safe operations or to establish or maintain cold shutdown.

Op. Mode Applicability Q1(pwrOps) g2(HSB) Q3(HSD) 94(CSD) Q5(Refuel) j36(Defuel) ~ All

~

HA3.1 HA3.2 Report or detection of toxic gases within eLtttfL{giiftMtittlrfacility structurea in concentrations Report or detection of flammable gases within a thr{tti~jrtg structurea in that will be life threatening to plant personnel: concentrations that will~ fZa&da i@ SluifZtlaQt {QYQQ EhQQ u2QQ QQraQQal QE1fKtlYftNttuiÃltZtQ rtftt:aaaartr {lZ the safe operation of the plant:

Qgndartaata BttzagaIartir. HMtGLkmim avatar Jrttalm Gtazturft.2anhaEahr

~hml BtlzagaBuildiitg. Primly.huttiliaw. Buildittg{EanHum.2auur Qfzttaitlmaftt

~Et Iartk. Eahr irttaifa Ever Q ztdftrtaata Bhaga HMIGLGmiga Btrugturft. {Goyim Bui!dirtL~~Mtt;bgaar Haun Euatfrtl Buildiag).QahhBuraadiag HaunattdE!artful IuartaLQmiml QmfruiHggm. Diml{atmrattz Buiidimtaltd Qad Iaahhum.huttiTiatx

~KitEasi. Eual BttzagaRuiidiItg.2rimauhuttiliary. BuiidIttg{Ean~~

Quntairtmaot Buildina ~~Bnitgbgaar Htzun {GfzttutiBuildirtlt). Quhh Eaadlffatar Ban@ Builditta Batttztr Htttzn Euntrul Buildittg W.Zah~ratitzt}.Qmiml hhrm Ehum arid Fht;tdml turtltaL Qmiml Qurdad HIztm. DRY &marattz Buildirtg and Gtatltt tt. EuatIattk Brea. huttiTiamEaadmtahr Puma BuiidinLBattmx Baum {QtzttrtttBuilding 2Z{Llthmtha). Qmfral hlaun Btatltzt.

29

Plant Specific EAL beeline (A,H,S)

Indian Point unit 2 Bases This IC is based on gases that have entered a plant structure&focting gzglttdjftg ~ g ftgtijftgtftO>ft~~~g + the safe operation of the plant. This IC applies to buildings and areas contiguous to plant vital areas or other significant buildings or areas (i. e., Service Water Pump house). The intent of this IC is not to include buildings (i. e., warehouses) or other areas that are not contiguous or immediately adjacent to plant vital areas. It is appropriate that increased monitoring be done to ascertain whether consequential damage has occurred. Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Releases/Radiohgical Effluent, or Emergency Director Judgement ICs.

30

Plant Specific EAL ideline (A,H,S) indian Point Unit 2 ICN: HA4 Security event In a plant protected area.

Op. Mode Appiic>>iiity D1(PwrOps) 02(HSB) 03(HSD) D4(CSD) g5(Refuel) Q6(Defuel) ~ All HA4.1 HA4.2 intrusion into plant protected area by a-hestileferee ~ +ygr~ Other security events as determined from+ite-specific) ~4afeguards Qg~g Contingency Plan.

31

Plant Specific EAL deline (A,H,S)

Indian Point Unit 2 Bases This class of security events represents an escalated threat to plant safety above that contained in the Unusual Event. For the purposes of this IG, jII~& hX RQ RdYQQRE Z5hfk ihk EEiKISIhEiLhgl!QUATE ~ hk auujtjgrQd a area by a hostile force will escalate this event to a Site Area Emergency.

igmf~ ~IILjiy~. Intrusion into a vital JL2uHIitmiIIIImaa~aaunmgahumfiarxinmnauhm.mf jihmaihh ihataamrjixmfmi iaartftmhmuld afbztibftaihtr.

32

Plant Specific EAL ideline (A,H,S)

Indian Point Unit 2 Ic¹: HA5 Control room evacuation has been Inltlated.

Op. Mode Appllcablllty 0 1 (Pwr Ops) Q 2 (HSB) Q 3 (HSD) g 4 (CSD) Q 5 (Refuel) 0 6 (Defuel) ~ All HA5.1 Entry into 8QJ2LLLEhr.MQQKEQLBQQM GHUIDQEHQQHIBQL32Q55Pfor control room evacuation.

33

Plant Specific EAL 0tfeline (A,H,S)

Indian Point Unit 2 Bases With the control room evacuated, additional support, monitoring and direction through the Technical Support Center and/or other Emergency is necessary.

Inability to establish plant control from outside the control room will escalate this event to a Site Area Emergency.

34

Plant Specific EAL ldeline (A,H,S)

Indian Point Unit 2 IC¹: HA6 Other conditions existing which ln the Judgement of the Emergency Director warrant declaration of an Alert.

Op. Mode APPllcablllty Q1 (Pwr Ops) 9 2 (HSB) Q 3 (HSD) 9 4 (CSD) Q 5 (Refuel) Q 6 (Defuei) ~ All HA6.1 Other conditions existing which in the judgement of the Emergency Director indicate that plant safety systems may be degraded and that increased monitoring of plant functions is warranted.

35

Plant Specific EAL deline (A,H,S)

Indian Point Unit 2 Bases This EAL is intended to address 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 Alert emergency class.

36

Plant Specific EAL eline (A,H,S)

Indian Point Unit 2 IC¹: HS1 Security event In a plant vital area.

Op. Mode Applicability Q1 (Pwr Ops) Q 2 (HSB) Q 3 (HSD) Q 4 (CSD) Q 5 (Refuel) Q 6 (Defuel) ~ All HS1.1 HS1.2 Intrusion into ~gillntting plant aagunttr vital areaa bye-hesQe-force an adtraraanr: Other security events as determined from(eit~peeiTie)

Contingency Plan.

~4afeguarde ~ter Qundanaata Gtttraga ~EMGLRauiaa Eahc Jntaka Rm~ Haatar BahSanfim Eahr ~EEEaat. Qml2gragaRuildinaErimanr BmttTlamlhildinalEanHttuat. Mmr Quntainmantfhildina~~lmitgltgaar BaunKuntrglRuildinrt).Qabhlarftadlng Bmn andElttgtngaltuarmLQm1ml QmizlBmn. DimlGmmtgr Buiiding andEuttl Xankhmu.

huzilianr htadnatar Ban@ JhiidinuHaia2aamEndzatrhQathuEhumiGgntrtdlhlidina2Z ttaitntatittn).Qantmlhhun5tatiun. Smuibr Emargane. Dime.

37

Plant Specific EAL rdeline (A,H,S) indian Point Unit 2 Bases This class of security events represents an escalated threat to plant safety above that contained in the Alert IC in that ahostita4orce aa Q~aafy, has progressed from the protected area to the vital area.

Hahuum Iahia Xf.26falhraaa GxIma hnd QafaaotL" 38

Plant Specific EAL deline (A,H,S)

Indian Point Unit 2 IC¹: HS2 Control room evacuation has been Inltlated and ~at-control gf ~ u}gJlng cannot be established.

Op. Mode APPffcabllltY 91 (Pwr Ops) Q 2 (HSB) 03 (HSD) 04 (CSD) 05 (Refuel) Q 6 (Defuel) %All HS2.1 The folhwing conditions exist:

a. Control room evacuation has been initiated.

AND

b. Control of 4haplant 2LLLBm.1LQQHIBQLBQQhi

~ gZfjag cannot be established per GBUIDQEHQ2KIBQl 12Li6M within~~peeNe) M minutes.

39

Plant Specific EAL deline (A,H,S) indian Point Unit 2 Bases Expeditious transfer of safety systems has not occurred but fission product barrier damage may not yet be indicated.+Sit~el+ ~ time for transfer ~ based on analysis or assessments as to how quickly control must be reestablished without core uncovering and/or core damage. This time should not exceed 15 minutes. In cold shutdown and refueling modes, operator concern is directed toward maintaining core cooling such as is discussed in Generic Letter 88-1 7, "Loss of Decay Heat Removal." In power operation, hot standby, and hot shutdown modes, operator concern is primarily directed toward maintaining critical safety functions and thereby assuring fission product barrier integrity. Escalation of this event, if appropriate, would be by Fission Product Barrier Degradation, Abnormal Rad Releases/Radiological Effluent, or Emergency Director Judgement ICs.

With respect to protection of the public and safe plant operations, "plant control" must focus primarily on the ability to maintain the reactor in a cooled condition. Therefore, it is appropriate to change the IC and EAL so that it emphasizes the need for core cooling when controlling the plant from outside the Control Room.

40

Plant Specific EAL +deline (A,H,S}

Indian Point Vnit 2 IC¹: HS3 Other conditions which In the judgement of the Emergency Director warrant declaration of Site Area Emergency.

Op. Mode APPllcablllty 9 1 (Pwr Ops) Q 2 (HSB) Q 3 (HSD) Q 4 (CSD) Q 5 (Refuel) Q 6 (Defuel) ~ All HS3.1 Other conditions which in the judgement of the Emergency Director warrant declaration of Site Area Emergency.

41

Plant Specific EAL eline (A,H,S}

Indian Point Unit 2 Bases This EAL is intended to address 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 class description for Site Area Emergency.

Multi-unit stations with shared safety functions should further consider how this IG may affect more than one unit and how this may be a factor in escalating the emergency class.

42

Plant Specific EAL +deline (A,H,S)

Indian Point Unit 2 IC¹: HG1 Security event resulting In loss of ablllty to reach and maintain cold shutdown.

Op. Mode APPllcablllty Q1 (Pwr Ops) Q 2 (HSB) Q 3 (HSD) Q 4 (CSD) 9 5 (Refuel) Q 6 (Defuel) ~ All HG1.1 Loss of ~physical control ef BEG

~ the control room due to security event.

HG1.2 Usaf almiaalmnlralaf Iha ramuh ahuldatttaaaaahTiitxduata aamuifx tttttaf.

43

Plant Specific EAL deline (A,H,S)

Indian Point Unit 2 Bases This IG encompasses conditions under which a hostile force has taken physical control of vital area required to reach and maintain safe shutdown.

Wtduttfa thft rmhzmtmuiaiainmmamlimt. ItmmfftmihhM.huhum mdififtffta.mhmt a hmftf ulant antral fuun hath thft.motel rmn und, aunaia~tfhiffa aanah.

~ ~~a htrft ~ tht ~ gf ~

44

Plant Specific EAL 'deline (A,H,S)

Indian Point nit 2 I(A: HG2 Other conditions exlstlng which In the judgement of the Emergency Director warrant declaration of General Emergency.

Op. Mode APPllcablllty Q1 (Pwr Ops) 0 2 (HSB) 9 3 (HSD) Q 4 (CSD) Q 5 (Refuel) g 6 (Defuel) ~ All HG2.1 Other conditions existing which in the judgement of the Emergency Director indicate: (1) actual or imminent substantial core degradation with potential for hss of containment, or (2) potential for uncontrolled radionuclide releases. These releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the site boundary.

45

Plant Specific EAL retleline (A,H,S)

Indian Point Unit 2 Bases This EAL is intended to address 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 General Emergency dass.

46

Plant Specific EAL beeline (A,H,S) indian Point Unit 2 IC¹: SU1 Loss of all offslte power to essential busses for greater than 15 minutes.

Op. Mode Appff<abfiitV Q 1 (Pwr Ops) Q 2 (HSB) Q 3 (HSD) Q 4 (CSD) Q 5 (Refuel) Q 6 (Defuel) Q All SU1.1 The folhwing conditions exist:

a. Loss of power to~~peeifie):

Ratha5mmt Irmhrmra2Q.furdkh tlfiatr 8RLhum 2h2B.5hmf5hmmtbrft!v.

frgmthtt llahzd2atiua hux fmmfzummffuunthft 122ELaaaiurbhmhu for greater than 15 minutes.

AND

b. At least (eit~peeifie) rtrtftgtttttrltttrtgy,rfittmtffttftftrgtgrh Ittthgf mfftgbfirtlrrtltrttrg >

8!Khm 47

Plant Specific EAL eline (A,H,S)

Indian Point Unit 2 Bases Prohnged loss of ~ AC power ~frgttg reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete loss of AC power (station blackout). Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Ehfftrmzh'.

Dftmga Jhm Dugum@Q Qmhr ~ 2 mlttm.

2. Qttttiina Diagram rtf JL2alttglrlaal disiribttllltrt Bfttt.9.19L152l.

48

Plant Specific EAL eline (A,H,S)

Indian Point Unit 2 IC¹: SU2 Inablllty to reach required shutdown wlthln Technical Speclflcatlon Lfmlts.

Op. Mode Appllcablllty ~ 1(pwrpps) g2(HSB) 53(HSD) 04(CSD) D5(Refuel) 06(Defuel) QAII SU2.1 Plant is not brought to required operating mod Specifications LCO Action Statement Time.

~ lltftTechnical 49

Plant Specific EAL Cleline (A,H,S)

Indian Point Unit 2 BaSeS Limiting Conditions of Operation (LCOs) require the Pant to be brought to a required shutdown mode when the Technical Specification required configuration cannot be restored. Depending on the circumstances, this may or may not be an emergency or precursor to a more severe condition. In any case, the initiation of plant shutdown required by the site Technical Specification requires a one hour report under 10CFR50.72 (b) non-emergency events. The plant is within its safety envehpe when being shut down within the allowable action statement time in the Technical Specifications. An immediate Notification of an Unusual Event is required when the plant is not brought to the required operating mode within the alhwable action statement time in the Technical Specifications. Declaration of an Unusual Event is based on the time at which the LCO-specified action statement time period elapses under the site Technical Specifications and is not related to how hng a condition may have existed. Other required Technical Specification shutdowns that involve precursors to more serious events are addressed by other System malfunction Hazards, or Fission Product Barrier Degradation ICs:

50

Plant Specific EAL eline (A,H,S)

Indian Point nit 2 ICA: SU3 Unplanned loss of most or all safety system annunclatlon or Indication In the control room for greater than 15 minutes..

Op. Mode Applicability g 1 (Pwr Ops) g 2 (HSB) ~ 3 (HSD) g 4 (CSD) Q5 (Refuel) Q 6 (Defuel) Q All SU3.1 The folhwing conditions exist:

Huger ~-associatahvitWafety-systems for greater than 15 minutes.

AND AND

c. In the opinion of the Shift Supervisor, the hss of the annunciators or indicators requires increased surveillance to safely operate the unit(e).

AND

d. Annunciator or indicator hss does not result from planned action.

51

Plant Specific EAL beeline (A,H,S)

Indian Point Unit 2 Bases This IC and its associated EAL are intended to recognize the dNiculty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.

Recognition of the availability of computer based indication equipment is considered "Unplanned" loss of annunciators or indicator excludes scheduled maintenance and testing activities.

"Compensatory non-alarming indications: in this context includes computer based information such as SPDS . This should include all computer systems available for this use depending on specific plant design and subsequent retrofits. Ib a-1 fjftf;hmtiga oft khaki bead un jbjftrhm.

Quantification of Most" is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost there is an increased risk that a degraded plant condition could go undetected; It is not intended that plant personnel perform a detailed count of instrumentation lost but ~ use gf thaval~ judgement hy ~2}551gi~m m

~ threshold for determining the severity of the plant conditions. This judgement is required to provide increased monitoring of system operation to safely operate the unit~.

supported by the specific opinion of the Shift Supervisor that additional operating personnel will be It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. White failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by their specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFR50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on SU2, Inability to Reach Required Shutdown Within Technical Specification Umits."

Annunciators or indicators for this EAL must include those identified in the Abnormal Operating procedures, in the Emergency Operating Procedures, and in other EALs (e. g.,

area, process, and/or effluent rad monitors, etc.).

Fifteen minutes was selected as a threshold to exclude transient or momentary power hsses.

Due to the limited number of safety systems in operation during cold shutdown, refueling, and defueled modes, no IC is indicated during these modes of operation.

This Unusual Event will be escalated to an Alert if a transient is in progress during the hss of annunciation or indication.

52

Plant Specific EAL deline (A,H,S)

Indian Point Unit 2 lC¹: SU4 Fuel clad degradatlon.

Op. Mode ApplfcabllltY Q1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) ~ All SU4.1 SU4.2 3hm han aradialahih adiahhradiafian maahar ahrdIaa ihat aaukihamad lnamdiat fhhritggraaaf fuaidaf dagradafian. ELkLhraa radialian meatier iaftmQmmiarr Rumuaml~hamu~fiiniaarrta~

53

,iP Plant Specific EAL deline (A,H,S}

Indian Point unit 2 Bases This IC is included as an Unusual Event because it is considered to be a potential degradation in the level of safety of the plant and a potential precursor of more serious problems.

EAL ¹~1 addresses (site-specific) radiation monitor readings such as BWR air ejector monitors, PWR failed fuel monitors, etc., that provide indication of fuel clad integrity.

EAL ¹5ll43 addresses coolant samples exceeding coolant technical specifications Escalation of this IC to the Alert level is via the fission product barrier degradation monitoring ICs.

54

Plant Specific EAL (deline (A,H,S)

Indian Point Unit 2 IC>>: Su5 RCS leakage.

Op. Mode

>PPIioabiiitY g1(PwrOps) ~ 2(HSB) 53(HSD) g4(CSD) Q5(Refuel) Q6(Defuel) QAII SU5.1 Either of the folhwing conditions exist:

a. Unidentified or pressure boundary leakage greater than 10 gpm OR

b. Identified leakage greater than 25 gpm.

55

Plant Specific EAL eline (A,H,S)

Indian Point Unit 2 Bases This IC is included as an Unusual Event because It may be a precursor of more serious conditions and, as a result, is considered to be a potential degradation of the level of safety of the plant. The 10 gpm value for the unidentified and pressure boundary leakage was selected as it is observable with normal control room indications. Lesser values must generally be determined through time-consuming surveillance test (e. g., mass balances). The EAL for identified leakage is set at a higher value due to the lesser significance of identified leakage in comparison to unidentified or pressure boundary leakage. In either case, escalation of this IC to the Alert level is via Fission Product Barrier Degradation ICs or IC SA3, "Inability to Maintain Plant in Cold Shutdown."

Only operating modes in which there is fuel in the reactor coolant system and the system is pressurized are specified.

56

Plant Specific EAL (eline (A,H,S)

Indian Point Unit 2 iC¹: SU6 Unplanned loss of all onslte or offslte communications capabllltles.

Op. Mode AppffcabifftY 9 1 (Pwr Ops) Q 2 (HSB) 9 3 (HSD) 9 4 (CSD) 9 5 (Refuel) Q 6 (Defuel) ~ All SU6.1 Either of the folhwing conditions exist:

hlhlh ability to perform routine operations:

lhl I I h' hhhh Ih~

OR hhll h EmargaamHufifiaatlan Grail LEHSlIar l Ih hlh' 5BG.~

I'hl I ghana hrmmmttalcatlan Ih

~ nthtt:

QKQR. Ideal Gauuamftat Batlh5mfftm.divest Rm Bmhhll Brim ta Dmdmitntnati Bah~

57

Plant Specific EAL (eline (A,H,S}

Indian Point unit 2 Bases The purpose of this IQ and ffs associated EALs is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate problems with offsite authorities. The loss of offsite communications ability is expected to be significantly more comprehensive than the condition addressed by 10CFR50.72.

Ih talkies). "'"'adioshjjralkie and dedicated EPP phone systems. This EAL is intended to be used only when extraordinary means are being utilized to make communications possible (relaying of information from radio transmissions, individuals being sent to offsite locations, etc.).

58

Plant Specific EAL ideline (A,H,S) indian Point Unit 2 iC¹: SU7 Unplanned loss of required DC power during cold shutdown or refueling mode for greater than 15 minutes.

Qp. Mode AppllcabllltY 01(pwrOps) 02(HSB) 03(HSD) 84(CSD) ~ 5(Refuel) 06(Defuel) 0AII SU7.1 Either ~ of the following conditions exist:

b. Failure to restore power to Qcequfred DG buses within 15 minutes from the time of hss.

59

Plant Specific EAL eline (A,H,S)

Indian Point Unit 2 Bases The purpose of this IG and its associated EALs is to recognize a loss of DG power compromising the ability to monitor and control the removal of decay heat during cold shutdown or refueling operations. This EAL is intended to be anticipatory in as much as the operating crew may not have necessary indication and control of equipment needed to respond to the loss.

"Unplanned is included in this IG and EAL to preclude the declaration of an emergency as a result of planned maintenance activities. Routinely plants will perform maintenance on a train related basis during shutdown periods. It is intended that the loss of the operating (operable) train is to be considered. If this loss results in the inability to maintain cold shutdown, the escalation to an Alert will be per SA3 "Inability to Maintain Plant in Cold Shutdown.

Pit~cific} ~ bus voltage shculd4o h based on the minimum bus voltage necessary for the operation of safety related equipment. This voltage value should incorporate a margin of at least 15 minutes of operation before the onset of inability to operate those loads. This voltage is usually near the minimum voltage selected when battery sizing is performed. Typically the value for the entire battery set is approximately 105 volts per cell. For a 56 string battery set the minimum voltage is typically 1.81 volts per cell.

lhuhaBarh DgglfatftntMEhr32KEKGXahun. Ebu.9.11L15iRi.

60

Plant Specific EAL. uideline (A,H,S)

Indian Point Unit 2 IC>>: SA1 Loss of all offslte power and loss of all onslte AC power to essential busses during cold shutdown or refueling mode.

Op. Mode AppllcabllltV Q1(PwrQps) 02(HSB) Q3(HSD) 84(CSD) ~ 5(Refuel) Q6(Defuel) QAII SA1.1

a. Loss of power to-(eit~peeifie):

Rathn&nimImuhramm5.2.2mikhfitHm8HBL~hum5h.2Mb'h aumm1itfttbr AND

b. Failure of (eitrH'peeifle) ~XQimal &uMcatOLR21.22.22 522IQQIK QQ59f 1t? KEYLQl hm (2Mb.%hand,QBl AND

c. Failure to restore power to bus ~MrtrM minutes from the time of loss of both offsite and onsite AC power.

within 15 BS?

laahiBxftt mtmftr amuiad amaulinu mlftmnith ullftrnah filfrttrmuzmhr ~1Kmia.

61

Plant Specific EAL uideline (A,H,S)

Indian Point Unit 2 Bases Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, containment heat removal, Spent Fuel Heat Removal and the Ultimate Heat When in cold shutdown, refueling, or defueled mode the event can be classified as an Alert, because of the significantly reduced decay heat, lower temperature and pressure, increc time to restore one of the emergency busses, relative to that specified for the Site Area Emergency EAL. Escalating to the Site Area Emergency, if appropriate, is by Abnormal Rad Levels/Radiological Effluent, or Emergency Director Judgement ICs. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Plant Specific EAL (deline (A,H,S)

Indian Point Unit 2 ICA: SA2 Op. Mode Protection system setpolnt has been exceeded andIgr. manual ~em frig was not successful, ~

Failure of Reactor Protection system Instrumentatlon to complete or lnltlate an automatic reactorweramirlp once a Reactor flare IR m ganef ggnarmilglL Appllcablllty ~ 1(PwrOps) 2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SA2.1 63

,Ag t

P>>

Plant Specific EAL C'beeline (A,H,S)

Indian Point Unit 2 Bases This condition indicates failure of the automatic andtur rnanttat protection system to friucccaca the reactor fu fba Qitfanf ~

Ibia Ehiaddraaaaaan)r manual friuuratifumafiufriuaignalfultumfhIramanttat friumbhhfaih fuahtifdmmfharaaufur fuanattfanf rautiirinaQmttruanmhurafiun.

Qrauttrdaa fha raaufur hainumada ~ifiuat. This condition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient and thus the plant safety has been compromised, and design limits of the fuel may have been exceeded. An Alert is indicated because conditions exist that lead to potential loss ol fuel clad or RCS.

A.manual frju~

is any set of actions by the reactor operator(s) at the reactor control console which causes control rods to be rapidly inserted into the core and brings the reactor subcritical (e. g., reactor trip button).

Ihh Rand ramlfinuEBLh~rahaanauauiT!Qatt)r mudiTtadfumuraautIrafal)r daIinafbauundifiundaaurihadh)r fbaganariuhamaaauutiadfuurtmurimdmahrraaufura. Ibafahra Qf atifumafiu iniliafiunQfa raaufur 1riu full@mad hxafzuaaaful manual iniliaiiunaufiunanhhh Qanha rauidttr fabian ai fha raaufur Qunfrul Quanta duaa nui Quota a Qufanfiat tulsa Qf aifbar ftiat Qtad Qr BGRhuttndariaa. lib fhaamfinttad Qriftuatiftriindar Qundifiunsrauuinttg a raaufur auram~ Qua+ fha Qufanfial fhraaf iu BRGur ftiat Qtadinfagriftt. ]fan QBBHGE ualh atthh Qn EKi.QBIIIQhLIIY.fbarahaahaanafaitura fuahtif dutImfharaaufur.htifuilhuuiatthsfanfiathaaf uanrtrafiun. Ibad uundifiunarauramtnf a Qufanfial tuu Qf ibafttat Qtadhutia! anr.and fhia~adautarafiun QfhLEBL QKGI Guhzifiualif)r=QBBHGE Qalhhanfttradhaaadunfaittira Qf 1hainfarmttdiafaramafaihu rafa rnunifura fuindiuafa nttuafLra Qr zero fultuminu raaufur fiiL hmanttatfrluiam Mufaufiunahxfharaaufur Quarafurhlaffharaaufur Qunfrut Qunauta~ Qauauuunfrutrudaiuha rauidlxinaaifttdinfufba Quraandhrinua fbaraaufur atihurifiual fan.raaufur filuhtiffunL iflaahu imuurfant funufafbaf fba failmuffbaraaufur Qrufttufiun attafam fuiniiiaia anattfumafiu friuduaanuiinfar aufiral Qr Qufanfiat failure Qf Qfbar at5faina nur hif.in and Qf Ifmtlf.a Qraut/rKr iu fh2un Qrudttuf harnttr dagradafKHL Iha BBS RKraa nu Qfhar aafafK fllnufiunhiii iu lnlialia raaufur iQQK Ibarafura Qnua fba raau!Qr tlat haanattuaaaullx friuuad. faituraa tnfha BERatrafam Qanhatraau Qlant aafafhlmuaQL ifimmadiaiamanttat aufiuna iu 1riu fharaaufur ara atiuaaafut fultumting rauugnifiun Qf an atifumafiu iriu faitura.fbarahnufbraatiuaifbar Qlaniaafaftr Qrfiamun Qiudtiufinfttgrikratafadfufhaatifumafiufriufaitura. IbiaMiafiuniauunahfanfmiihfbaubilumuhxufmatdnuauutirafa n.

Qunaantafira QtmiTiuafiuna.

I. Reeve 1 ElBXBay.16. BE2'QHKZQ %GLED 64

Plant Specific EAL Celine (A,H,S}

Indian Point Unit 2 IC>>: Sa3 Inability to maintain plant In cold shutdown.

Op. Mode APPIIcabillty 9 1 (Pwr Ops) Q 2 (HSB) g 3 (HSD) ~ 4 (CSD) g 5 (Refuel) Q 6 (Defuel) Q All SA3.1 The following conditions exist:

b. Ebmgtgr, azhnt temperature increase that either:

~ Exceeds 200 'F OR

~ Results in uncontrolled temperature rise approaching 200 'F 65

Plant Specific EAL Celine (A,H,S}

Indian Point Unit 2 Bases This EAL addresses complete loss of functions required for core cooling during refueling and cold shutdown modes. Escalation to Site Area Emergency or General Emergency would be via Abnormal Rad Levels/Radiohgical Effluent or Emergency Director Judgement ICs.

"Uncontrolled means that system temperature increase is not the result of planned actions by the plant staff.

The EAL guidance related to uncontrolled temperature rise is necessary to preserve the anticipatory phihsophy of NUREG-0654 for events starting from temperatures much lower than the cold shutdown temperature limit.

Escalation to the Site Area Emergency is by IC SSS, Loss of Water Level in the Reactor Vessel that has or will Uncover Fuel in the Reactor Vessel," or by Abnormal Rad Levels/Radiological Effluent ICs.

3. 2mhkmmhPIftadfltftaf~IabhX1h&um2afk

2. Ixh Ssm Qumilk1 66

Plant Specific EAL 'deline (A,H,S)

Indian Point Unit 2 IC¹: SA4 Unplanned loss of most or all safety system annunclatlon or Indication In control room with either (1) a significant transient In

~

progress, or (2) compensatory non-alarming Indicators are unavailable.

Op. Mode Applicability ~ 1(PwrOps) 52(HSB) g3(HSD) g4(CSD) Q5(Refuel) D6(Defuel) QAII SA4.1 The folhwing conditions exist:

~B '"h Ill l~"""""' A AND

b. In the opinion of the Shift Supervisor, the loss of the annunciators or indicators requires increased surveillance to safely operate the unit(e).

AND

c. Annunciator or indicator loss does not result from planned action.

AND

d. Either of the following:

~ A significant plant transient is in progress OR H3QIEUG. ~ are Is unavailable.

67

Plant Specific EAL Cleline (A,H,S}

indian Point Unit 2 BaSeS This IC and its associated EAL are intended to recognize the dNiculty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a transient. Recognition of the availability of computer based indication equipment is considered (SPDS, plant computer, etc.).

"Planned loss of annunciators or indicators included scheduled maintenance and testing activities.

plant condition could go undetected; It is not intended that plant personnel perform a detailed count of instrumentation lost but

~

~ use gf theat~ judgement +~ ~

Quantification of "Most" is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost there is an increased risk that a degraded Q~zgjmm threshold for determining the severity of the plant conditions. This judgement is supported by the specific opinion of the Shift Supervisor that additional operating personnel will be required to provide increased monitoring of system operation to safely operate the unit+.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFR50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on SU2 Inability to Reach Required Shutdown Within Technical Specification Limits."

(Sf~pecifle) hnnunciators ocMhatcea for this EAL must include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e. g.,

area, process, and/or effluent rad monitors, etc.)..

"Significant Transient" includes response to automatic or manually initiated functions such as scrams, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10% or greater.

Compensatory non-alarming indications" in this context includes computer based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits. If both a major portion of the annunciation system and all computer monitoring are unavailable to the extent that the additional operating personnel are required to monitor indications, the Alert is required.

Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes. No IC is indicated during these modes of operation.

This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress.

68

Plant Specific EAL i+leline (A,H,S)

Indian Point Unit 2 IC¹: SA5 AC power capablllty to essential busses reduced to a single power source for greater than 15 minutes such that any addltlonal single failure would result ln station blackout.

Op. Mode Appllcablllty ~ 1 (Pwr Ops) ~ 2 (HSB) ~ 3 (HSD) g 4 (CSD) g 5 (Refuel) Q 6 (Defuel) Q All SA5.1

~ED921

~ED922 KKEDG22 llait httxiliaa tmmfarmar Rathnhmiliazimmi ramr 322KV.amhuhim 69

Plant Specific EAL (deline (A,H,S)

Indian Point Unit 2 BaSeS This IG and the associated EALs are intended to provide an escalation from IG SU1 "Loss of All Offsite Power to Essential Busses for Greater than 15 Minutes." The condition indicated by this IG is the degradation of the offsite power with a concurrent failure of one emergency generator to supply power to its emergency busses. Another related condition could be the loss of all offsite power and loss of onsite emergency diesels with only one train of emergency busses being kacMed from the unit main generator, or the loss of onsite emergency diesels with only one train of emergency busses being backfed from offsite power. The subsequent hss of this single power source would escalate the event to a Site Area Emergency in accordance with IG SS1 Loss of All Offsite and Loss of All Onsite AG Power to Essential Busses.

Example EAL ¹~1b should be expanded to identify the control room indication of the status gf offsite-specific power sources and distribution busses that, if unavailable, establish a single failure vulnerability.

3. Dmian Bma DmmftnlNBDlhr~ Mmmm. Ebu.9.12L15l91

2. Qmtlin9. Diagmmnf JL2ftladrignl dhlnbttlinn 2.EQ&9<Lau QfhllhGRmrar 70

Plant Specific EAL r eline (A,H,S)

Indian Point nit2 lC¹: SS1 Loss of all offslte power and loss of all onslte AC power to essential busses.

Op. Mode AppflcabllltY ~ 1(PwrOps) ~ 2(HSB) 53(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SS1.1 Loss of all offsite and onsite AG power as indicated by:

a. Loss of power to-(site-specific):

Giuthn&nimIrmhramu25? 553.5Kml. GKhmfiau~lhmu 2hL2h.5B, ard maftaibffth.

AND

b. Failure of+ite-specific) @ad QaaImhinm15.2 tumaulx.

AND

c. Failure to restore power to~of ~~Mar M within 15 minutes from the time of loss of both offsite and onsite AG power.

SK.

labilitxhaaitmr rttauirmf artt amllaumiftmaltdihalittraahmmr zauzmhr ~Amia.

71

Plant Specific EAL rodeline (A,H,S)

Indian Point Unit 2 Bases Loss of all AG power compromises all plant safety systems requiring electric power Prolonged loss of all AG power will cause core uncovering and hss of containment integrity, thus this event can escalate to a General Emergency. Th+sit~ci~ time duration should be selected to exclude transient or momentary power losses, but should not exceed 15 minutes.

3. Dftmgn Bash Drtnltmftrti{DBEhr~mhm.Bm.9.19L15L91 2.Qnftlintt DiagramrtflL2ahatrinalrlhfrihitfian

2. EQMRBu.16.LQSRQEBLLhQRQMEB 72

Plant Specific EAL eline (A,H,S}

Indian Point Unit 2 ICO: SS2 Failure of Reactor Protection system lnstrumentatlon to complete or Initiate an automatic reactorweam~ once a Reactor h

Protection system setpolnt has been exceeded andQK manual eesm frig was not successful, and QZrp pgmgr ggZrgiun.

Op. Mode Appllcablllty ~ 1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SS2.1 6EI~ HIl~

hHDailtmr; Eamrmmmhurafhn hinama1hft Bmcmmnais Pl mRinlkmin. af iailiathartf marmmmhumliun 73

Plant Specific EAL eline (A,H,S)

Indian Point Unit 2 Bases

'hiarztndithnaddraaaaa; hmmanuat tdnnrautgmathtrinlal hlhttfradhxamanua! tria~ faih tnahutdmra thaiaaatgr.

SHE Baaatnr uttttar ~PL Automatic and manual scram are not considered successful if action away from the reactor control console was required to scram the reactor.

QKGIGuhz~BY=BEDnathhantaradhamianfaihirartf azmrangaindigatignMdagraamhtlnlfr Fl fnlluninaaraagtgr tria, Ihhadiuafiha EBLaddraamam manual tringr autnmath'trinmgnalhlhtfradhxa manual trinntxhfaihtn abutdglfrntha rmtgr in that tharmtzlaurrtduninamgiahaatinadfgr~ thaaafattr mtalnammdamgnftd.

an@tant Ihlaatnditinn indimtaa faiturartf hdhihaautnmatin andmanual uratatfnnmtama tn trInihamachzin amiunctinn nith a faihiia rtf a! tftrnatahnrathn mtatttma tn mdum amhz nrttmK halnt~r danaxhaatifnfah. Ihaatmhinatiannf faijurartfhnth frnnt Jinamfhaduln urntaIzinnaltatanx in funt:thn in rmnnnaa tn a aslant trans!ant.ahna Mtithiha anniinuad arndut'tinnrtfhaa1 nnaaaaslimt thraat infuftldadandBQRintagritxandthuamarranhdagiaratignrtf aRtaham Emftiganm.

Although this IG may be viewed as redundant to the Fission Product Barrier Degradation IG, its inclusion is necessary to better assure timely recognition and emergency response. Escalation of this event to a General Emergency would be via Fission Product Barrier Degradation or Emergency Director Judgement ICs.

1. QKGIHL1.5uhzitigality.

2. ELRi. Bing.MHKGEQHKIQEKLEhBZQEEB 74

Plant Specific EAL 'eline (A,H,S}

Indian Point Unit 2 IC¹: SS3 Loss of all vital DC power.

Op. Mode ApplfcabllltV S1(PwrOps) ~ 2(HSB) 53(HSD) D4(CSD) g5(Refuel) Q6(Defuel) QAII SS3.1

" ~uruadialkmafmlhm itttfiH1ianQtt lhRRRitahkhh YQJimal9f far 325~ EgEKEgngh 21.22. 23~ M for greater than 15 minutes 75

Plant Specific EAL eline (A,H,S)

Indian Point Unit 2 Bases Loss of all DC power compromises ability to monitor and control plant safety functions. Prohnged hss of all DC power will cause core uncovering and hss of containment integrity when there is significant decay heat and sensible heat in the reactor system. Escalation to a General Emergency would occur by Abnormal Rad Levels/Radiological Effluent, Fission Product Barrier Degradation, or Emergency Director Judgement ICs. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

fhhrftggh

3. Dmin Bash Dggutmftni{DBEhr~EKSXabun. ~9.13L12R1

2. hOJ2~~2 LQSSQE325&QZQEEB 76

Plant Specific EAL ~leline (A,H,S)

Indian Point Unit 2 IC¹: SS4 Complete loss of function needed to achieve or malntaln hot shutdown.

Qp. Mode Appllcablllty 51(PwrOps) g2(HSB) g3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SS4.1 Complete hss of any-(sit~peeifie) function required for hot shutdown m joffjm~+ QEQ aaih ftn HL3. HEhISHK 77

Plant Specific EAL beeline (A,H,S}

indian Point Unit 2 Bases This EAL addresses complete loss of functions, including ultimate heat sink and reactivity control, required for hot shutdown with the reactor at pressure and temperature. Under these conditions, there is an actual major failure of a system intended for protection of the public. Thus, declaration of a Site Area Emergency is warranted. Escalation to a General Emergency woukl occur by Abnormal Rad Levels/Radiological Effluent, Fission Product Barrier Degradation, or Emergency Director Judgement ICs.

Ehhrttauft; 2mh5umhamadmaarau.152.uaru122mikikhr&fiailjuasf khimttthhttfa.lahh2J.&3.umm1aari2.hruuftrahiTiltr atuujrftmttah.

78

Plant Specific EAL (deline (A,H,S)

Indian Point Unit 2 IC¹: SS5 Loss of QHL water level that has or will uncover fuel In the ~

Op. Mode ApplfcabllltY 51 (Pvvr Ops) ~ 2 (HSB) 53 (HSD) ~ 4 (CSD) ~ 5 (Refuel) 06 (Defuel) Q All SS5.1 Loss of Reactor Vessel water level as indicated by:

EifhihaBmtur.lmalhhttiatmmmLiihmmhd ihat ymhrift~tftimihft Bmiz~h duauiauinanuruznimllmf mattaftf:ml.amzmumh Jilmbt.

79

If IP

Plant Specific EAL Celine (A,H,S)

Indian Point Unit 2 Bases Under the conditions specified by this IC, severe core damage can occur and reactor coolant system pressure boundary integrity may not be assured.

N For PWRs, this IC covers sequences such as prohnged boiling folhwing hss of decay heat removal. infold Thus, declaration of a Site Area Emergency is warranted under the conditions specified by the IC. Escalation to a General Emergency is via radiohgical effluence IC AG1.

llnauarx af iha fuaf irraauaati ra af ihaattant ihat aauaaaauah fuaf uoauanriaiuatiThallttnahna fttr daalarlrtg a GhE. Sam@thar attantamuL4 faatf Q fual urzztary. ahutdatttn ar rafual mudaartthar than a ftturtftfaaaXhtatrammal aauahilittt.it hinanartttzlata in haa iha EKL an thiaanaattant. Ear athar rtrtaratina mttdaa.fual unanttartr ia a lnaa rtf iha BGS anti fuai phdharnaianhhhmuiraaffaalaraihngf alhE.

Bafaranaa;

3. hhnarmalQaaratinlt lnatrugtlttn~Ebu.1Q.LQSRQEBEGJDUhLHEhI BBd&8.5YGZRL2LUL92.

80

Plant Specific EAL Iieline (A,H,S}

Indian Point Unit 2 ICOSI: SS6 Inability to monitor a slgnlf leant transient In progress.

Op. Mode Applicability ~ 1 (Pwr Ops) ~ 2 (HSB) ~ 3 (HSD) Q 4 (CSD) 9 5 (Refuel) Q 6 (Defuel) Q All SS6.1 All of the following conditions exist:

a. Loss of most {gggrgz.

BggmEaaah.

~ gf-(ei~peeiffe) annunciators gr. jrtdjgalgra on any Qgntzl AND

b. QQ~QQ aofI~ are-is unavailable.

AND

c. Indications needed to monitor(eft~~fie) any.g{

functions are unavailable:

BftagIgr Bmr.lftiftrmadialaraggaZlLGuuua Bamt ggurtla. RuuzBattga SJB.Qm IQa.jndigatign g{BQEarurtrtiag. ELKEuilBamtftattf{KnamjgBaogft. BQRErftaaurft. BQR

~{QgjfILmImnuftraturL595ummtBamfalmL Eitht Ehm. RGEmaaurft. Qgalaiamftrtf Emaurft. Qualairtiittftttilaud. Qgtttaliamftrtl Badialjgrt.2ZB Lml AND

d. Transient in progress.

81

Plant Specific EAL beeline (A,H,S)

Indian Point Unit 2 Bases This IC and its associate EAL are intended to recognize the inability of the control room staff to monitor the plant response to a transient. A Site Area Emergency is considered to exist if the control room staff cannot monitor safety functions needed for protection of the public.

(Si~ocific) Annunciators for ~ jttlh;giga this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e. g., rad monitors, etc.).

'Compensatory non-alarming indications in this context indudes computer based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits.

Significant Transient includes response to automatic or manually initiated functions such as scrams, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10/o or greater.

(Sii~ociffc) Indications needed to monitor safety functions necessary for protection of the public must include control room indications, computer generated indications and dedicated annunciation capability. The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled and in a eoolable geometty, to remove heat from the core, to maintain the reactor coolant system intact, and to maintain containment intact.

'Planned actions are excluded from this EAL since the hss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

EJIL 3

2. HL2. Bm.3. QQBE QQQLIHG

2. Hh2.Bfu.2.HEhIRHK 6 BKM1,jHIEGBIIY Mf 8 I 5 IS 8 ME Bt

5. HL6.Blat.2.JtHEHIQEY 82

Plant Specific EAL eline (A,H,S)

Indian Point Unit 2 IC¹: SG1 Prolonged loss of all offslte power and prolonged loss of all onslte AC power.

Op. Mode ApptfoabtfftV g1(PwrOps) g2(HSB) g3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SG1.1 Prohnged hss of all offsite and onsite AG power as indicated by:

a. Loss of power to-(sit~pacific):

Rathnkmimlrmfzmftra K2.553.5Kmi&kh tfiiau822hum Rhl3h.$Bmd5h rmftgthfthf.

AND

~

b. Failure of~specific) ~

tglfrttrtie emergency buses.

EDQR21 2? Kld 22 AND g.hilmirtrtfrgithahliglffinaauuKiiammhi;

~

Bmtgratiunaf umr turftauir&amaulinumhmauitbia&~ftftf iMlhurh5QI tilmly.

QB

~ (Sit~fic)-fndicatioaof-continuing-degradatioaof-core-cooling-baseborn-Fission-QBBHGEar BEDmthmhhmHL2.~ QQQL!HG 83

Plant Specific EAL Celine (A,H,S)

Indian Point Unit 2 BaSeS Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prolonged hss of all AC power will lead to hss of fuel clad, RCS, and containment. Thgel~peclflc) g houre to restore AC power caa4o h based on site blackout coping analysis performed in conformance with 10CFR50.63 and Regulatory Guide 1.155, "Station Blackout, as available, with appropriate alhwance for offsite emergency response. Although this IC may be viewed as redundant to the Fission Product Barrier Degradation IC, its inclusion is necessary to better assure timely recognition and emergency response.

The likelihood of restoring iftgYjiftffggrft ~ ~i~

This IC is specified to assure that in the unlikely event of prolonged station blackout, timely recognition of the seriousness of the event occurs and that declaration of a General Emergency occurs as early as is appropriate, based on a reasonable assessment of the event trajectory.

should be based on a realistic appraisal of the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions.

In addition, under these conditions, fission product barrier monitoring capability may be degraded. Although it may be dNicult to predict when power can be restored, it is necessary to give the Emergency Director a reasonable idea of how quickly (s)he may need to declare a General Emergency based on two major considerations:

1. Are there any present indications that core cooling is already degraded to the point that Loss or Potential Loss of fission product barriers is imminent? (

iefocmatI~

2. If there are no present indications of such core cooling degradation, how likely is it that power can be restored in time to assure that a loss of two barriers with a potential loss of the third barrier can be prevented?

Thus, indication of continuing core cooling degradation must be based on fission product barrier monitoring with particular emphasis on Emergency Director judgement as it relates to imminent loss or potential loss of fission product barriers and degraded ability to monitor fission product barriers.

Bftfftrfmr.

1. HL2.~QQQL5G Bm.2

2. LaEar IHU22hEer gf KQR ifrHK h1ail2aihn PllK m2athn QladfgYi BuhEZBK62 2.QllQJI!lk DIRQfKBQf Z2ftjft~l kkir8? YiiQQ 6 Bltfftiftggff;QmianRuhDmmftrii {DfKQfgr~miftm.Bftlf.9.3QL1521.

5 EQBJh9 BELMLQKQEEJ.hGPQYKB ZBM2 84

Plant Specific EAL eline (A,H,S)

Indian Point Vnit 2 IC¹: SG2 Failure of the Reactor Protection System to complete an automatlcmmm there Is Indlcatlon of an extreme challenge to the ability to cool the core.

~ and manual ~m~ was not successful and Op. Mode Appllcablllty ~ 1(PwrOps) Q2(HSB) Q3(HSD) Q4(CSD) Q5(Refuel) Q6(Defuel) QAII SG2.1

1. EKaathinBL1 AND

2. Either of the folhwing:

BED aatbuaiht QKGIHL2.3XHKQQQLIHG" 85

.Plant Specific EAL beeline (A,H,S)

Indian Point Unit 2 Bases Automatic and manual scram are not considered successful if action away from the reactor control console is required to scram the reactor.

Under the conditions of this IC and its associated EALs, the efforts to bring the reactor subcritical have been unsuccessful and, as a result, the reactor is producing more heat than the maximum decay heat load for which the safety systems were designed. Although there are capabilities away from the reactor control console, such as emergency boration in PWRs, or-the continuing temperature rise indicates that these capabilities are not effective. This sequence could be a precursor for a core melt sequence. CSEE Syhzilhalitlr =BKaathhtftrftd hami aa faihtrftrtf fmr magftizfhathntndftf;umahftiulfr Fl hlhminga amhr triL 3hhngrtignaf thft M.xhfmm uay.maaualtrinnrnutrtmnIig Irinmmalhllunft~fblramanualiriuutxhfaihtnahuirhlfmtha rmhzhnamhat that thft rmhzhuzfhginumnrahmtad fgr uhhb thft~mhmmmrfftmanmL Ihh mullion iaffiaaim filmgfhdhihanutgmatigmf muaual urgtftgtigamhmtntrin thftrmhziammmgtignlffithnfuitumnfCftrautfr hzsttignmhmaQrmhmutnghzmuu:~ rfftm.htnt imh.

For PWRs, the extreme challenge to the ability to cool the core is intended to mean that the core exit temperatures are at or approaching 1200'F or that the reactor vessel water level is below the top of active fuel. For plants using CSFSTs, this EAL equates to a Core Cooling RED condition.

~

Another consideration is the inability to initially remove heat during the early stages of this sequence. For PWRs, if emergency feedwater flow is insufficient to remove the amount of heat required by design from at least one steam generator, an extreme challenge should be considered to exist. For plants using CSFSTs, this EAL equates to a Heat Sink RED condition.

In the event either of these challenges exist at a time that the reactor has not been brought behw the power associated with the safety system design (typically 3 to 5% power) a core melt sequence exits. In this situation, core degradation can occur rapidly. For this reason, the General Emergency declaration is intended to be anticipatory of the fission product barrier matrix declaration to permit maximum offsite intervention time.

86

Plant Specific EALideline (FPB)

Indian Point Unit 2 PWR FPB 1C¹: FC1 . Barrfel'uel Claddin Type: Potential Loss

==

Description:==

Critical Safety Function Status FC1.2 FC1.3 HeaNiak- RED ~jn~~gg~/gg~

Bases:

Core Cooling - ORANGE indicates subcooling has been hst and that some clad damage may occur. Heat Sink - RED indicates the ultimate heat sink function is under extreme challenge and thus these two items indicate potential loss of the fuel clad barrier.

i. HL2.Hm.2. QQBEQQQLSG

? EKB.Ebs? OKRA 87

Plant Specific EALuideline (FPB)

Indian Point Unit 2 PWR FPB ICg: FC2 Barrier: Fuel Claddin Type: Loss Descrlptlon: Primary Coolant Activity Level FC2.1 Coolant activity greater than Bases:

This ~~pec~ value corresponds to 300 pCi/cc l-131 equivalent. Assessment by the NUMARC EAL Task Force indicates that this amount of coolant activity h~elLaboue is considered hst. g~ corresponds to about 2/o to 5% fuel dad damage. This amount of clad damage indicates significant dad heating and thus the fuel clad barrier haltaaftanifr attaluatinnrtf nnniant antbdtxaanniatatf mith Pl ahlaaituittanaa mufnrmfttf. Iha nahulatinn naahattd.urtttn EQGatra tfatnagaaaataamant aurna tttrma anrf matfa ihaznattntathta aaaumfttfttnihatiha 821~ttuntaiant anthdthla 2 x LQianuzttittrm f2x KKKQ. Bmtf nn a KLQE gaL BGS zfumtt 5.ERE. iha rttaultina aslant fthaahtftnifftgl&tfhuafttharuhmuuu&tfhtr HUfdhBQ.

tha aaamt~i anff anuina gf tha~~Q itumhiti la uniutttttfn. thtiftla nfl ~ trt ftntntt hatt thftaft hen nutnhftra ~tmrtaia There is no equivalent "Potential Loss" EAL for this item.

LaEer fuunQ.Gamer M EL Ihrna ZtVl222hL&nhnildmflhala~

88

Plant Specific EAuideline (FPB)

Indian Point Unit 2 PWR FPB IC¹: FC3 Barrier: Fuel Cfaddin Type: Loss Desorlptfort: Core Exit Thermocouple Readings FC3.1 Greater tha+sit~peciTQ ~g Bases:

The Loss" EA+si~peci~ reading should correspond to significant superheating of the coolant. This value typically corresponds to the temperature reading that indicates core cooling - RED in fuel clad barrier EAL ¹1 which is usually about 1200 'F.

Ehhmm; EKKQQBE22QL59.~2 89

Plant Specific EALIIIuideline (FPB)

Indian Point Unit 2 PWR FPB II%: FC3 Barrier: Fuel Claddin Type: Potential Loss Descrlptlon: Core Exit 'Ihermocoupfe Readings FC3.2 Greater than~~Nig ZEX Bases:

The Potential Loss EA+si~poc~ reading should correspond to hss of subcooling. This value typically corresponds to the temperature reading that indicates core cooling-ORANGE in fuel dadbarrier EAL ¹1 which is usually about 700 to 900'F. 5giZ331hm4lignum~gf QSEQI~QQfKgd2QL59 90

Plant Specific EAL lIIideline (FPB) indian Point Unit 2 PWR FPB IC¹: FC4 Barrier: Fuel Claddin Type: Potential Loss

==

Description:==

Reactor Vessel Water Level FC4.1 Bases:

There is no "Loss" EAL corresponding to this item because it is better covered by the other fuel clad barrier "Loss" EALs.

The+~peci~ value for the 'Potential Loss EALcorresponds to the top of the active fuel. For sites using CSFSTs, the "Potential Loss" EAL is defined by the Core Cooling-ORANGE path. Th~~pecif+ value in this EAL should be consistent with the CSFST value.

91

Plant Specific EALsideline (FPB)

Indian Point Unit 2 PWR FPB IC¹: FC5 Barrier: Fuel Ciaddin Type: Loss

==

Description:==

Containment Radiation Monitor Reading FC5.1 Containment rad monitor reading greater thagsitaspec+ fZQdZZ jnfimittffKE5grBZ Bases:

The+~pecif~eading is a value which indicates the release of reactor coolant, with elevated activity indicative of fuel damage, into the containment. The reading should be calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration of 300 pCilgm dose equivalent I-131 into the containment atmosphere. Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations higher than that specified for RCS barrier hss EAL ¹4. Thus, this EAL indicates a loss of both the fuel clad barrier and a loss of RCS barrier.

Ih ~allah ~ hf II all hd &~h IERalahlMIHIIIKld 9 rmzmhham/ugftftPh afitm EQGaaumumhrmzdihtt ummrtihnrtfhuviauazihtmtuirmtutturfr jnmafahurtfmiuithhfinm jrtujuffmL jih furihftr~umftff1ba1 rid dmxhmrtf gurrfttfmditmmLemrtf amtuntiuitmaz1aittmftrtiafaumhftrft himiaa1aneummifhnurftmutraL

~~

within technical specifications and are therefore indicative of fuel damage (approximately 2-5% dad failure depending on core inventory and RCS volume). This value is

'llowed Ih, There is no Potential Loss" EAL associated with this item.

Ehfftrftrzft; 92

Plant Specific EAL%ideline (FPB)

Indian Point Unit 2 PWR FPB IC¹: FC6 Barrier: Fuel Claddin Type: Loss

==

Description:==

Other (site specific) indications FC6.1 Bases:

This EAL is to cover other~taepocifQ indications that may indicate loss or potential hss of the fuel ciad barrier, including indications from containment air monitors or any other Q~Q54M instrumentation.

93

Plant Specific EALIILtideline (FPB)

Indian Point Unit 2 PWR FPB ICg: FC6 Barrier: Fuel Claddin Type: Potential Loss

==

Description:==

Other (site-specific) Indications FC6.2 Bases:

This EAL is to cover othergsitacpeci~ indications that may indicate loss or potential loss of the fuel clad barrier, including indications from containment air monitors or any other

+~peel~ instrumentation.

94

Plant Specific EALideline (FPB)

Indian Point Unit 2

=PWR FPB ICg: FC7 Barrier: Fuel Claddin Type: Loss/Pot. Loss

Description:

Emergency Director Judgement FC7.1 Any condition in the opinion of the Emergency Director that indicates hss or potential loss of the fuel clad barrier Bases:

This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the fuel clad barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in Emergency Director judgement that the barrier may be considered lost or potentially lost. (See also IC SG1, Prohnged Loss of All Offsite Power and Prohnged Loss of All Onsite AC Power", for additional information.)

95

Plant Specific EA~sideline (FPB) indian Point Unit 2 PWR FPB IC¹: RCS1 Barrier: RCS Type: Potential Loss

==

Description:==

Critical Safety Function Status RCS1.1 BCaiategrity - Red ~ ga ~~QQIQ'.

RCS1.2 HeebSiak - Red ~ gg ~~ Qg ~ ~ ~ g gggjgf Bases:

~

This EAL is for PWRs using Critical Safety Function Status Tree (CSFST) monitoring and functional recovery procedures.

RED path indicates an extreme challenge to the safety function derived from appropriate instrument readings, and these CSFs indicate a potential loss of RCS barrier.

There is no Loss" EAL associated with this item.

Reference:

1. F-0.3, Rev. 2, HEAT SINK

2. F-0.4, Rev. 3, INTEGRITY 96

Plant Specific EAL&ideline (FPB)

Indian Point Unit 2 PWR FPB IC¹: RCS2 Barrier: RCS Type: Loss

==

Description:==

RCS Leak Rate RCS2.1 Greater than available makeup capacity as indicated by ftttmafiaa{hamhmulimarihriunhr aaimlhn g{RmEZ~

fKREBEGSUBE{P2R; BQGSEGQQL!HGXQKBLQ2HIMD

&299 %Lid 29lK9 x{m 5911K9 XQRB 1001-2500 15 f94)

Bases:

The "Loss EAL addresses conditions where leakage from the RCS is greater than available inventory control capacity such that a loss of subcooling has occurred. The loss of subcooling is the fundamental indication that the inventory control systems are inadequate in maintaining RCS pressure and inventory against the mass loss through the leak.

97

Plant Specific EAL Guideline (FPB)

Indian Point Unit 2 PWR FPB ICN: RCS2 Barrier: RCS Type: Potential Loss

==

Description:==

RCS Leak Rate UaisolabfaRCS leak exceeding the capacity of one charging pump in the normal charging mode (gQgrgz, ~gal+

Bases:

~~

The "Potential Loss" EAL is based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) jttajtagR KXREfR ~ QQQRQIIt Qf QQtt Qbatgjtlg QlllHQ.. In conjunction with the SG Tube Rupture 'Potential Loss" EAL this assures that any event that results in significant RCS inventory shrinkage or loss (e. g., events leading to reactor scram and ECCS actuation) will result in no lower than an Alert emergency classification.

98

Plant Specific EALbideline (FPB) indian Point Unit 2 PWR FPB IC¹: RCS3 Barrier: RCS Type: Loss Descrlptlort: SG Tube Rupture RCS3.1 Unisolated faulted (outside VC) ruptured steam generator Bases:

This EAL is intended to address the full spectrum of Steam Generator (SG) tube rupture events in conjunction with containment barrier "Loss" EAL ¹4 and fuel clad barrier EALs.

The Loss" EAL addresses ruptured SG(s) with an unisolable secondary line break corresponding to the loss of 2 o3 fission product barriers (RCS barrier and containment barrier-thisEALwillalwaysresultincontainmentbarrier'Loss EAL¹4). Thisallowsthedirectreleaseofradioactivefissionandactivationproductstotheenvironment. Resultantoffsite dose rates are a function of many variables. Examples include: coolant activity, actual leak rate, SG carry over, iodine partitioning, and meteorology. Therefore, dose assessment in accordance with IC AG1, 'Site Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 1000 mR Whole Body or 5000 mR Child Thyroid for the Actual or Projected Duration of the Release Using Actual Meteorohgy", is required when there is indication that the fuel matrix/clad is potentially lost.

(Si~ociffc)

BELIAL indication should be consistent with the diagnostic activities of the emergency operating procedures (EOPs)+~aIIable. This should indude indication of reduction in primary coolant inventory, increased secondary radiation levels, and an uncontrolled or complete depressurization of the ruptured SG. Secondary radiation increases should be observed via radiation monitoring of condenser air ejector discharge, SG bhwdown, mains steam, and/or SG sampling system. Determination of the uncontrolled" depressurization of the ruptured SG should be based on indication that the pressure decrease in the ruptured steam generator is not a function of operator action.

This should prevent declaration based on a depressurization that results from an EOP induced cooldown of the RCS that does not involve the prohnged release of contaminated secondary coolant from the affected SG to the environment. This EAL should encompass steam breaks, feed breaks, and stuck open safety or relief valves.

Bfthrftagm; 1 hQI 12 BID 1K ZLhhiQEtKBBIQBILIKLE% 12LiiL92

2. HL BEEQIQB3BZ QB SAHHYJHdEGIIQH. ~/9?

3. M ~Qamatar MmBtta1urfL 99

Plant Specific EAL Guideline (FPB)

Indian Point Unit 2 PWR FPB IC¹: RCS3 Barrier: RCS Type: Potential Loss Desol'lptlotl: SG Tube Rupture RCS3.2 GG ruhr ruttfurn aaithntififtdln M~Ganaratnr Iud Burtturfb PHD BGRiftnlrngftrt~tnftttd~ the aaannitx hLiGZhD ni a ~ charging rtutuL Bases:

The "Potential Loss" EAL is based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Controlsystemwhichisconsideredasoneeeatrffuc}al gbnrgjngpumpdischargingtothechargingheader. Inconjunctionwiththe RCSleakrate PotentialLoss" EALthisassures that any event that results in significant RCS inventory shrinkage or loss (e. g., events leading to reactor scram and ECCS actuation) will result in no lower than an "Afert" emergency classification.

?

2.

~M

3. hQl 12. Bfnt. 19.BIER GElKBh22B IUBE LBK17l1192 BED 19. BEBGIQB IBE QB GhEEIY JHdEGIIQhL M11L9?

~Rumrnhztuhft BunlurfL 100

Plant Specific EAL Guideline (FPB)

Indian Point Unit 2 PWR FPB ICg: RCS4 Barrier: RCS Type: Loss

==

Description:==

Containment Radiation Monitoring RCS4.1 Hauid rhea EHiar ELRmfh mlaat mnuh adiYitx) Kl{EhaQ uQLz aad imemiag Bases:

Th~i~poci~ reading is a value which indicates the release of reactor coolant to the containment. The reading should be calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with normal operating concentrations (i. e., within TIS) into the containment atmosphere. This reading will be less than that specified for fuel clad barrier EAL ¹5. Thus, this EAL would be indicative of a RCS leak only. If the radiation monitor reading increased to that specified by fuel clad barrier EAL ¹3, fuel damage would also be indicated.

However, if the site-specific physical location of the containment radiation monitor is such that radiation from a chud of released RCS gases could not be distinguished from radiation from nearby piping and components containing elevated reactor coolant activity, this EAL should be omitted and other site-specific indications of RCS leakage substituted.

There is no "Potential Loss" EAL associated with this item.

101

Plant Specific EALsideline (FPB) indian Point Unit 2 PWR FPB ICN: RCS5 Barrier: RCS Type: Loss

==

Description:==

Other (Site-specific) indications RCS5.1 Bases:

This EAL is to cover other~azpec~ indications that may indicate loss or potential loss of the RCS barrier, including indications from containment air monitors or any other (ei~eci instrumentation.

102

Plant Specific EALNIjideline (FPB) indian Point Unit 2 PWR FPB ICg: RCS5 Barrier: RCS Type: Potential Loss

==

Description:==

Other (site-specific) Indications RCS5.2 Bases:

This EAL is to cover other (site-specific) indications that may indicate loss or potential loss of the RGS barrier, including indications from containment air monitors or any other (site-specific) instrumentation.

103

Plant Specific EALideline (FPB) indian Point Unit 2 PWR FPB IC¹: RCS6 Barrier: RCS Type: Loss/Pot. Loss

==

Description:==

Emergency Director RCS6.1 Any condition in the judgment of the Emergency Director that indicates loss or potential loss of the RCS barrier.

Bases:

This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the RCS barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in Emergency Director judgement that the barrier may be considered hst or potentially lost. (See also IC SG1, "Prohnged Loss of All Offsite Power and Prohnged Loss of All Onsite AC Power, for additional information.)

104

Plant Specific EALuideline (FPB)

Indian Point Unit 2 PWR FPB ICN: PC1 Barrier: Prima Containment Type. Potential Loss

==

Description:==

Critical Safety Function Status PC1.1 Coatairuttent Red ~fta~

Bases:

~

This EAL is for PWRs using Critical Safety Function Status Tree (CSFST) monitoring and functional recovery procedures.

~

tht fbft fftfi ~ g Lftmfjtgf ~ ~

of containment. Conditions leading to a containment RED path result from RCS barrier and/or fuel dad barrier loss.

ftf

~ ~ ~fjgg ~ Ifgfttg ftf~ftiZ}L" ~~

RED path indicates an extreme challenge to the safety function derived from appropriate instrument readings and/or sampling results, and thus represents a potential loss Thus, this EAL is primarily a discriminator between Site Area Emergency and General Emergency representing a potential loss of the third barrier.

There is no "Loss" EAL associated with this item.

105

Plant Specific EALideline (FPB)

Indian Point Unit 2 PWR FPB ICg: PC2 Barrier: Prima Containment Type: Loss

==

Description:==

Containment Pressure PC2.< Rapid ~exptaineditg~hfi decrease in Containment Pressure following initial increase PC2.2 containment pressure or sump level response not consistent with LOCA conditions. LLtmftzgttg&gJm~

uzur iafhmuamamifta~ihaimaftiftttulainabhfhftEafiftra1ar mfhmarmiftfnaiigmhmadiftm.

Bases:

Rapid unexplained loss of pressure (i. e., not attributable to containment spray ~~ Qgftiittg ~ or condensation effects) following an initial pressure increase indicates a loss of containment integrity. Containment pressure and sump levels should increase as a result of the mass and energy release into containment from a LOCA. Thus, sump level or pressure not increasing indicates containment bypass (V-sequence) and a hss of containment integrity.

106

'L Plant Specific EALRideline (FPB)

Indian Point Unit 2 PWR FPB IC¹: PC2 Barrier: Prima Containment Type: Potential Loss Descrfptfon: Containment Pressure PC2.3 +pacific) + psig and increasing PC2.4 PC2.5 Lm1han ihlmlfiimumQQLtiainalftfttaulifta admuurda ftQttiQtnftrtiumuiina Bases:

The~~pacific) ~ psig for potential loss of containment is based on the containment design pressure. Existence of an explosive mixture ~hfdLQftfta) means a hydrogen and oxygen concentration of at least the hwer deflagration limit curve exists. The indications of potential loss under this EAL corresponds to some of those leading to the RED QUALM path in EAL ¹1 above and may be declared by those sites using CSFSTs. As described above, this EAL is primarily a discriminator between Site Area Emergency and General Emergency representing a potential hss of the third barrier.

The second potential loss EAL represents a potential hss of containment in that the containment heat removaVdepressurization system ~ containment sprays, Eaa Qgghr

, but not including containment venting strategies) are either hst or performing in a degraded manner, as indicated by containment pressure greater than the setpoint at which the equipment was supposed to have actuated.

fhfmuzL' RQihfl QQfKQilQQ BcQQfkdlEfl {GQ2l32%1.2lgdLQgfiQ BQQKlitiflQlR" QRQfl 1, Wmillha mad.

2. 1IQfhiftdEG83.Qhmiftr 5.uam~L1Z.uzi.2.

~ ilhtiKfQ!02'litt' Lieu. HQMfftYQE.fQf flQ!fQQE1YKith QillQt: QlaQh'. EAR

2. QGEDmha LmDmalfmiLEKD.Ebu.9.19QLRi.

5. HZ~

8 Ih ~BBRMHIBI HfhlaiQr Iris'ah1Xlai&iQa.hCZhm&mfJV

'f 07

Plant Specific EALideline (FPB) indian Point Unit 2 PWR FPB ICN: PC3 Barrier: Prima Containment Type: Loss

==

Description:==

Containment Isolation Valve Status After Containment Isolation PC3.1

~

Either; QR Qr mnrn ~~ ~ Qr fp Qr QQ Valve(s) not closed Ifdtfta rfgttirftg lnnhilitxtQimhhmx Qrimanr mhmdhf:hargiltnmltt2rhQQatniamftat AND downstroke radioloaical releaseaathuav to the environment exists as a result Bases:

~

head glERR ~ nttITItyg ~ KE QamKf K@QE ~QhnrginQ ~

This EAL is intended to address incomplete containment isolation that allows direct release to the environment. It represents a loss of the containment barrier.

QQatniam9nL ~ ttitiia KflriftfftQ QQQtMrft IlaiKJQtn@R ~ frnm QE2k QEMx RLkfKQR Ythhil tlmaztaiamftathQIIathochlt ttdtiah ftithtrriQ nnthmmbanatiQizdatina fmztianaQr QrntfifhasHmi rftifmmuathhr rthtQtnr QQQlaat QtthifhthnszataiarnftaL

~

There is no "Potential Loss" EAL associated with this item.

EhfftrftaQII; 108

Plant Specific EAL Guideline (FPB) indian Point Unit 2 PWR FPB IC¹: PC4 Barrier: Prima Containment Type: Loss

==

Description:==

SG Secondary Side Release with Primary to Secondary Leakage PC4.1 gftiatiahitt release of secondary side to atmosphere fzm fhtgfggffttf~gttttfttafttt+ with primaty to secondary leakage greater than tech spec allowable gf RR GEhlinauxataamgftftttmtar Bases:

~~

This EAL addresses SG tube ruptures.

~litttt Llahtthhh aamadan<ai~h atittaau tuatmusaharai tahtth ftttttflinaar grza hglatign haa htttta ~ftgttttfhg thtt 5 graft tata' >

5 rgttttittttf ht ~hraahammllaa~ @utica aafttttt at:aiamahtrig ralittf~tabttta that aaanui htt isttlattttf fz glattt gould'gghf aha ha ggttttitttf under the EhL For smaller breaks, not exceeding the normal charging capacity threshokf in RCS barrier "Potential Loss" EAL ¹2 (RCS leak rate) or EAL ¹3 (SG tube rupture), this EAL results in an Unusual Event. For larger breaks, RCS barrier 'Loss or Potential Loss EAL ¹2 would result in an Alert. For SG tube ruptures which may involve multiple steam generators or unisolable secondary line breaks, this EAL would exist in conjunction with RCS barrier "Loss EAL ¹3 and would result in a Site Area Emergency. Escalation to General Emergency would be based on Potential Loss" of the fuel clad barrier.

109

Plant Specific EALsideline (FPB)

Indian Point Unit 2 PWR FPB ICg: PC5 Barrier: Prima Containment Type: Potential Loss Desoriptlort: Significant Radioactive Inventory in Containment PC5.1 Containment radiation monitor reading greater th KEbrziadiztarIQQELKzELK Bases:

The~~ac) reading is a value which indicates significant fuel damage well in excess of the EALs associated with both loss of fuel clad and hss of RCS barriers. As stated in Section 3.8, a major release of radioactivity requiring offsite protective actions from core damage is not possible unless a major failure of fuel cladding allows radioactive material t be released from the core into the reactor coolant. Regardless of whether containment is challenged, this amount of activity in containment, if released, could have such severe consequences that it is prudent to treat this as a potential loss of containment, such that a General Emergency declaration is warranted. NUREG-1228 "Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents," indicates that such conditions do not exist when the amount of clad damage is less than 2o/o.

2 ~dlalM rft~gnM h ttantff uQQQ

~ hl rjftgaxhu mzurrftdmd.thumbmark amlaat II Qf MY5Q QQQ

'll QEER Qart thk I

~umatjaa tQ tlmmataiamftatatmmhftrft IERiaahlMIEIINEEkl 'l Unless there is a (site-specific) analysis justifying a higher value, it is recommended that a radiation monitor reading corresponding to 20% fuel clad damage be specified here.

~ h&~l CE!!tEUI~ Ih Qt ttaldaQ Q gthK~ mhtuE IQ 52atajataftat Elgl hfl!ER HEju~ it JR iurthftr 2&uQEri that hirutaataaftauQuiih QQrftmatfQL Mn There is no "Potential Loss EAL associated with this item.

3. QuhulaljaadmdhM ia jftttftrframD65mithh, B.Bum9lR92 110

Plant Specific EAL ideline (FPB)

Indian Point Vnit 2 PWR FPB IC¹: PC6 Barrier: Prima Containment Type: Potential Loss

==

Description:==

PC6.1 Core exit thermocouples in excess ot 1200 QE9HIDED QZK92QL59

'F and restoration procedures ~ J. BEQEQHK IQ JJJfgZQMIE QQBE QQQLJHg QK2. BEKQHKIQ5hlUHEXQQZjE QQQL59" not effective within 15 minutes fM4 BEGEQHK IQ PC6.2 Core exit thermocouples in excess of 700 'F with RVLIS Natural Circulation Range less than 39% with no RCPs running, or RVLIS RCP Running range less than 44% with 4 RCPs running, or 30% with 3 RCPs running, or 20% with 2 RCPs running, or13% with 1 RCP running and restoration procedures JE~ BE555K IQ 5gEQUgf=. QQBE QQQL59. EUg BESPOKE DE9BKE QQBE KKHJH9. EELQ2. BEZQHK ZQ MIllBBIEDQQf3E QQQL59) not effective within 15 minutes Bases:

In this EAL, the function restoration procedures are those emergency operating procedures that address the recovery ot the core cooling critical safety functions. The procedure is considered effective if the temperature is decreasing or if the vessel water level is increasing.

The conditions in this potential loss EAL represent imminent melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure.

In conjunction with the core exit thermocouple EALs in the fuel and RCS barrier columns, this EAL would result in the declaration of a General Emergency loss of two barriers and the potential hss of a third. It the function restoration procedures are ineffective, there is not "success" path.

Severe accident analyses (e. g., NUREG-1150) have concluded that function restoration procedures can arrest core degradation within the reactor vessel in a significant fraction of the core damage scenarios, and that the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide a reasonable period to allow function restoration procedures to arrest the core melt sequence. Whether or not procedures will be effective should be apparent within 15 minutes. The Emergency Director should make the declaration as soon as it is determined that the procedures have been, or will be effective. The reactor vessel level chosen should be consistent with the emergency response guides applicable to the facility.

There is no "Loss EAL associated with this item.

111

Plant Specific EALN4ideline (FPB) indian Point Unit 2 PWR FPB IC¹: PC7 Barrier: Prima Containment Type: Loss

==

Description:==

Other (site-specific) indications PC7.1 QB Ml ~ QNQ QQR MQ RKkKR fut: 2 ills laahfTilrM~amiairtfttftuiumxumrftliftfuruurgft mhm mhhhrmdhlflarudiutugimlmhma uuihnm.tulhl~irztUmtftlhr~dM Bases:

This EAL should cover other~speci indications that may unambiguously indicate hss or potential hss of the containment barrier 112

Plant Specific EALuideline (FPB)

Indian Point Unit 2 PWR FPB ICg: PC7 Barrier: Prima Containment Type: Potential Loss Desorlptlon: Other (site-specific) indications PC7.2 Bases:

This EAL should cover other (site-specific) indications that may unambiguously indicate loss or potential hss of the containment barrier, including indications from area or ventilation monitors in containment annulus or other contiguous buildings.

113

Plant Specific EALsideline (FPB)

Indian Point Unit 2 PWR FPB ICg: PC8 Barrier: Prima Containment Type: Loss/Pot. Loss

==

Description:==

Emergency Director Judgement PC8.1 Any condition in the judgment of the Emergency Director that indicates loss or potential loss of the containment barrier Bases:

This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the containment barrier is hst or potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in Emergency Director judgement that the barrier may be considered lost or potentially lost. (See also IG SG1, "Prohnged Loss of All Offsite Power and Prolonged Loss of All Onsite AC Power", for additional information.)

114

Plant Specific EAL%ideline (FPB) indian Point Unit 3 PWR FPB IC¹: FC1 Barrier: Fuel Claddin Type: Loss Descrfptfotl: Critical Safety Function Status FC1.1 CoreCooling - RED ~g~ QQQE QQQIJ59 Bases:

Core Cooling - RED indicates significant superheating and core uncovery and is considered to indicate loss of the Fuel Clad Barrier.

fhhrmmft; 1 QGK ER2. Qura Qzliag. Hftma2 115

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Fission Product Barrier Evaluation Revision 0 Consolidated Edison Co.

Indian Point Station Unit 2 5/17/94 Operations Support Services, Inc.

233 Water Street 2nd Floor Plymouth, MA 02360

xl J

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Evaluation of IP-2 Fission Product Barrier Emer enc Action Levels The Fission Product Barrier (FPB) degradation category for a PWR plant is illustrated in the following table which is designated "Table 4" in NESP-007, Revision 2.

The Initiating Condition (IC) for each of the four emergency classiQcations (Unusual Event, Alert, Site Area Emergency, and General Emergency) are designated FUl, FAl, FSl, and FGl, respectively.

Each IC is defined by one or more EALs or combination of EALs which are indicative of a loss or potential loss of one or more of the three fission product barriers, The three fission product barriers are:

~ Fuel Clad (FC)

~ Reactor Coolant System (RCS)

~ Primary Containment (PC)

NESP-007, Revision 2, prescribes example EALs for each of the three Qssion product barriers. An EAL is defined by one or more plant conditions. For example, there are seven FC barrier wimple EALs, eight RCS barrier example EALs, and eleven PC example EALs. Each EAL may consist of one or more conditions representing a loss of the barrier and a potential loss of the barrier. Some EALs may have only loss conditions, others only potential loss conditions, some have both loss and potential loss conditions. Each EAL is given a sequential number in Table 4. In the following list, NESP-007 EALs with a defined condition (i. e., labeled as needing "site-specific" input in Table 4) are identiQed with a "yes", and those without a deQned condition (i. e. labeled "not applicable" in Table 4) are identiQed with a "no":

sW, OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 NUMARC IP2

~Brrl r EAL ¹ ~I ~P Lg~ PPP LES la Yes Yes Yes(FC1.1) Yes(FC1.2) lb No Yes No Yes(FC1.3) 2 Yes No Yes(FC2.1) No 3 Yes Yes Yes(FC3. 1) Yes(FC3.2)

No Yes No Yes(FC4. 1) 5 Yes No Yes(FC5.1) No 6 Yes Yes No No 7 Yes Yes Yes(FC7.1) Yes(FC7.1)

RCS la No Yes No Yes(RCS1.1) lb No Yes No Yes(RCS1.2) 2 Yes Yes Yes(RCS2.1) Yes(RCS2.2) 3a Yes Yes Yes(RCS3. 1) No 3b Yes No No Yes(RCS3.2) 4 Yes No Yes(RCS4.1) No 5 Yes Yes No No 6 Yes Yes Yes(RCS6 1) Yes(RCS6. 1) 1 r'o Yes No Yes(PCl.l) 2a Yes Yes Yes(PC2. 1) Yes(PC2.3) 2b Yes Yes Yes(PC2.2) Yes(PC2.4) 2c No Yes No Yes(PC2.5) 3 Yes No Yes(PC3.1) No Y'es No Yes(PC4. 1) No 5 No Yes No Yes(PC5.1) 6a No Yes No Yes(PC6.1) 6b No Yes No Yes(PC6.2) 7 Yes Yes Yes(PC7. 1) No 8 Yes Yes Yes(PC8.1) Yes(PCS. 1)

Based on the classification key given at the beginning of Table 4, the number of example EALs, and the number of loss and potential loss conditions, the set of conditions that can yield a given emergency classification can be computed.

The maximum, theoretically possible set of conditions that can yield an Unusual Event classification is given in column 1 of Table A. These consist of the PC loss and PC potential loss conditio'ns.

The maximum, theoretically possible set of conditions that can yield an Alert classification is given in column 1 of Table B. These consist of FC loss and potential loss conditions, and RCS loss and potential loss conditions.

t OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 The maximum, theoretically possible set of conditions that can yield a Site Area Emergency classification is given in column 1 of Table C. These consist of any of the following conditions:

~ Loss of FC and RCS, or

~ Potential loss of FC and RCS, or

~ Potential loss of FC or RCS and Loss of another barrier The third set of conditions listed above can be represented by the following conditions to eliminate reference to "loss of another barrier":

~ Potential loss of FC and loss of RCS, or

~ Potential loss of FC and loss of PC, or

~ Potential loss of RCS and loss of FC, or

~ Potential loss of RCS and loss of PC While not explicitly stated within NUMARC/NESP-007, the following combinations are also appropriate for inclusion as Site Area Emergency classifications:

~ Loss of FC and loss of PC

~ Loss of RCS and loss of PC The maximum, theoretically possible set of conditions that can yield a General Emergency classification is given in column 1 of Table D. These consist of the following conditions:

~ Loss of any two barriers, and

~ Potential loss of a third These conditions can be represented by the following conditions to correlate barrier loss and potential loss to the three speciQc barriers:

~ Loss of FC and loss of RCS and potential loss of PC, or

~ Loss of RCS and loss of PC and potential loss of FC, or

~ Loss of PC and loss of FC and potential loss of RCS

QSp

~4 k

'4 Qt t I t

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Note that the loss of all three barriers justifies a General Emergency classification as well.

Since the EAL conditions are listed numerically in Table 4, Tables A through D utilize a similar numbering system which is modified by letter abbreviations to define each set of conditions. For example, condition "FC2-loss" corresponds to a loss of the Fuel Clad barrier due to primary coolant activity level greater than (site-specific) value. Similarly, "RCSlb-pot. loss" corresponds to a potential loss of the Reactor Coolant System barrier due to a Critical Safety Function Status Heat Sink-RED condition, and so on.

An evaluation of each condition or set of conditions listed in Tables A through D is made to determine if it properly defines the appropriate threshold for the classification. Ifa condition or set of conditions is appropriate, a comment reflecting this conclusion is recorded in the "Remarks" column. Ifa condition or set of conditions is determined to be inappropriate, it is lined out and the reason for this conclusion is similarly recorded in the "Remarks" column. Where additional space is required to complete comments, the comments are recorded by number in Appendix 1 of this document. The numbers of the comments are recorded in the "Remarks" column with the associated condition or set of conditions to which they apply.

A summary of the results of the fission product barrier evaluation is presented in Appendix 2.

RECOGNITION CATEGORY F FISSION PRODUCT BARRIER DEGRADATION INITIATINGCONDITION MATRIXTABLE 4 PWR UNUSUAL EVENT SITE AREA EMERGENCY GENERALEMERGENCY Any loss or any Any loss or any Loss of both fuel clad FGl Loss of any two potenUal loss of potential loss of either and RCS barriers containment fuel clad or RCS. OR AND Potential loss of both PotenUal loss of third Op. Modes: Op. Modes: fuel clad and RCS barrier.

Power operaUon Hot Power operation Hot OR Shutdown Shutdown PotenUal loss of either Op. Modes:

fuel clad or RCS, and Power operation Hot loss of any additional Shutdown barrier.

Op. Modes:

Power operation Hot Shutdown NOTES:

l. Although the logic used for these iniUaUng condiUons appears overly complex, it is necessary to reflect the following consideraUons:

~ The fuel clad barrier and the RCS barrier are weighted morc heavily than the containment barrier (see SecUons 3.4 and 3.8 for more information on this point). Unusual Event ICs associated with RCS and Fuel Clad barriers are addressed under System Malfunction ICs.

~ At the Site Area Emergency level, there must be some ability to dynamically assess how far present conditions are for General Emergency.

For example, ifFuel Clad barrier and RCS barrier "Loss" EALs existed, this would indicate to the Emergency Director that. In additional to offsite dose assessments, continual assessments of radioactive Inventory and containment integrity must be focused on. If, on the other hand, both Fuel Clad barrier and RCS barrier "PotenUal Loss" EALs existed, the Emergency Director would have more assurance that there was no immediate need to escalate to a General Emergency.

~ The ability to escalate to higher emergency classes as an event gets worse must be maintained. For example, RCS leakage steadily increasing would represent an increasing risk to public health and safety.

2. Fission Product Barrier ICs must be capable of addressing event dynamics. Thus, the EAL Reference Tables 3 and 4 state that IMMINENT(i.

e., within I to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) loss or potential loss should result in a classiflcaUon as ifthe affected threshold(s) are already exceeded, particularly for the higher emergency classes.

RECOGNITION CATEGORY F INITIATINGCONDITION MATRIXTABLE 4 PWR Fuel Clad Barrier Example EALs Potential Loss

1. C tfcal Safe Ft tfo at s Core cooling - red Core cooling - orange OR Heat sink - red Coolant Actfvl Coolant activity greater than (site-speciAc) value Not applicable

3. Co Exit The ocou 1 R Greater than (site-specfAc) 'F Greater than (site-speciAc) 'F O

O Not applicable Level less than (site-spcciAc) value t O

5. Co tafnment diat o o 2

Containment rad monitor reading greater than (site-speci Ac) Not applfcable R/hr t

6. Other sft -s tTf (site-speciAc) as applfcablc (site-spcciAc) as applfcable O

en te o ud ment Any condition fn the Judgment of the Emergency Director that indicates loss or potential loss of the fuel clad barrier Determine which combination of the three barriers are lost or have a potential loss and use the following key to classify the event. Also, an event for multiple cvcnts could occur which result fn the conclusion that exceedfng the loss or potential loss thresholds fs imminent (i. c..

wtthtn 1 tn J. hn>>rs'I. ln this tmmtnent lnss stt>>ation>>cr t>>rldmr nt anrl rlasstfv as tf the threshnfrls an exreerf ed.

0 RECOGNITION CATEGORY F INITIATINGCONDITION MATRIXTABLE 4 PWR RCB Barrier Example EALs potential Loss

1. C tfcal Safe etio Status Not applfcable RCB integrity - red OR Heat sink - red Greater than availablc makeup capacity as indfcated by a loss Unisolable leak exceeding the capacity of one chargfng pump in thc of RCB subcooling normal charging mode

3. SGTubeRu t >

(site-speciAc) fndfcatfon that a SG is ruptured AND has an non- (site-spcciAc) indfcation that a SG is ruptured isolable secondary linc break O AND OR thc primary-to-secondly leak rate exceeds the capacity of onc (site-speciAc) indicatfon that a SG is ruptured AND a prolonged charging pump fn the normal charging mode 8 release of contaminated secondary coolant is occurring from the D affected SG to the environment A

4. taf m nt Rad atfo o to B Containment radfation monitor reading greater than (site- Not applfcable speciAc) R/hr t (W

5. Other site-s C (site-speciAc) as applicablc (site-s peciAc) as applicable O

6. me en Directo Any condition In the]udgment of the Emergency Director that indicates loss or potential loss of the RCS barrier

RECOGNITION CATEGORY F INITIATINGCONDITION MATRIXTABLE 4 PWR Containment Barrier Example EALs Potential Loss

1. C cal Saf t etio ta Not applfcable Containment - red Rapid unexplafned decrease following iniUal increase (site-specific) psig and fncrcasing OR OR Containment pressure or sump level response not consistent Explosive mixture exists with LOCA condiUons OR Containment pressure greater than containment dcpressurization 'n system setpoint wfth less than one full train of depressurizatfon equfpment operaUng O d

Valve(s) not closed Not applicable n AND N downstream pathway to the envfronment exists 2

C' Release of secondly side to atmosphere with prfnmy to secondary leakage greater than tech spec allowable -

Not applicable pact v ve t O Not applicable Containment radiaUon monitor reading greater than (site-specific)

R/hr CO

RECOGNITION CATEGORY F INITIATINGCONDITION MATRIXTABLE 4 PWR Containment Barrier Example EALs Potential Loss

6. o t Thermocou le Readin s Not applicable Core exit thermocouplcs in excess of 1200'F AND restoration procedures not effective within 15 minutes OR Core exit thermocouples in excess of 700 'F with reactor vessel level below top of active fuel AND restoration procedures not effective within 15 minutes

7. 0 te-s IAc indication (site-speciilc) as applicable (site-specific) as applicable O

8. Emer e d ment cl Any condition in the]udgment of the Emergency Director that A indicates loss or potential loss of the containment barrier td C

O

(

I QSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rcv. 0 Table A IP-2/3 Fission Product Barrier Unusual Events NESP- 7 ~Remark Loss or pot. loss of PC PC@-1ess Condition not supported in PEG.

QQRa-less 1 PCQb-1ess 2 PC2e-less Condition not supported in PEG.

PCS-less 3 PCSWss Condition not supported in PEG.

PCGa-less Condition not supported in PEG.

Pt Gb-less Condition not supported in PEG.

PCS-less Subsumed in "Judgment" EAL.

4 5

6 7

Condition not supported in PEG.

Condition not supported in PEG.

8 9

10 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

11

l OSSI 92-402A-2-IP2 IP2 Fission Product Bamcr EAL Evaluation, Rcv. 0 Table B IP-2/3 Fission Product Barrier Alerts HE'~p- Z ~Rm~rk Loss or pot. loss of FC

-1ess ll FC4b-less Condition not supported in PEG.

PCS-less 9 F44-less Condition not supported in PEG.

F45-1ess 18 F46-less Condition not supported in PEG.

ess Subsumed in "Judgment" EAL.

12 13 Condition not supported in PEG.

14 15 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Loss or pot. loss of RCS RCS4a-less Condition not supported in PEG.

EQEttr-toss Condition not supported in PEG.

"os'".'::,.;;ll:,':.i;;"iii'i ii'ilia,'":"'lli!i"...'":"";,:i:: 1!'-'-'!""!...::,',,!.;:,:.:;:,t,",,'! i'i'!!i RCSSa-Iess 17 RCSSb-less Condition not supported in PEG.

lgQ84 ]OsSS rg<<"'-".j~'$rl '

RQS5-less Condition not supported in PEG.

RCSG-1ess Subsumed in "Judgment" EAL.

Hnue+"!:::::."::.'WWW:.'::..'.S:.".,:..:.!r. e:,,,.:::re+.::~OSN!%'N:;<<n'rl!:,~:: WP,,% ~:,!SSSPS!:%so!:" . VSS:. ~! S"SWe!

20 Condition not supported in PEG.

Condition not supported in PEG.

12

OSSI 92402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rcv. 0 Table B IP-2/3 Fission Product Barrier Alerts KWi'MZ ~Rm'~rk Subsumed in "Judgment" EAL.

13

K "t'F r

>1 kg I

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies

~Rm~rk Loss of FC and RCS Condition not supported in PEG.

Condition not supported in PEG.

ll ll Condition not supported in PEG.

ll Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

22 Condition not supported in PEG.

22 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

9 9

Condition not supported in PEG.

9 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

14

't OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies

~RAII~rg Condition not supported in PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

17 Condition not supported in PEG.

21 Condftfon not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Pot. loss of FC and RCS 15

PI

%r 1

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies NE'~P- Qj @ark ll Condition not supported in PEG.

ll Conditfon not supported ln PEG.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

13 13 Condition not supported in PEG.

13 Condition not supported in PEG.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

Conditfon not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

14, 25 14 14 Condition not supported in PEG.

14 Condition not supported ln PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

15, 24 15 15 16

f 4'1 Js l,

%F +

~I

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies g~m~rk Condition not supported in PEG.

15 Condition not supported in PEG.

Conditfon not supported fn PEG.

Subsumed in "Judgment" EAL.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condftion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Pot. loss of FC and loss of RCS Condition not supported in PEG.

Conditfon not supported in PEG.

l 17

CIP Jl'

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies HE~i'- QZ Rt~m~rk 12 Condition not supported in PEG.

12 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

12 12 Condition not supported in PEG.

12 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

14 14 Condition not supported in PEG.

14 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

15 15 Condition not supported in PEG.

18

4f;~

'J*

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies

~Rm~rk 15 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Pot. loss of FC tmd loss of PC Condition not supported in PEG.

Condition not supported in PEG.

12 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

12 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

1 19

Q 3 OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies

~R~~rk 2

Condition not supported ln PEG.

3 13 Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

13 Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported fn PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condftion not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

1 2

Condltfon not supported in PEG.

3 14 Condition not supported ln PEG.

Condition not supported ln PEG.

Condltfon not supported ln PEG.

14 Subsumed ln "Judgment" EAL.

Condition not supported fn PEG.

1 20

rr c

t

~>

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies g."~P- Q ~Rm ~rk 2

Condition not supported in PEG.

3 15 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

14 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

21

'4 4p IP l

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies

~Rm ~r Subsumed fn "Judgment" EAL.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Pot. loss of RCS and loss of FC Condition not supported in PEG.

ll 22 9

Condition not supported ln PEG.

21 Condltfon not supported ln PEG.

Subsumed ln "Judgment" EAL.

ll Condition not supported ln PEG.

19 9

Condition not supported ln PEG.

19 Condition not supported fn PEG.

Subsumed ln "Judgment" EAL.

ll Condition not supported ln PEG.

20 9

Condition not supported ln PEG.

20 Condition not supported in PEG.

22

J 4'

t

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies KLi'2)Z ~Rm ~r Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

ll OSS Condition not supported in PEG.

20 9

Condition not supported in PEG.

20 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

23

+

1 '

'grP

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies

~Rm~rk Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Pot. loss of RCS and loss of PC Condition not supported in PEG.

1 2

Condition not supported in PEG.

3 46 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

1 2

Condition not supported in PEG.

3 19 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

19 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

1 2

24

r h

~ J I

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies

~P~Z ~Rm~r Condition not supported in PEG.

3 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

1 2

Condition not supported in PEG.

3 20 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

20 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

vi og

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies MSLMZ Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL Subsumed in "Judgment" EAL.

Condition not supported fn PEG.

Condltfon not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Loss of FC and PC Condition not supported in PEG.

1 26

,fi 4

')I f

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies

+ ~P- ~RI'~rk Condition not supported in PEG.

3 12 Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

12 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

1 2

Condition not supported in PEG.

3 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

ess 40 Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

1 2

Condition not supported ln PEG.

27

~ I OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies

~Rm'~rk 3

9 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

9 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

21 21 Condition not supported in PEG.

21 21 Conditfon not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

21 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

28

1

%II Q 1

"4A H t'

OSSI 92%2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies KSMP- 2 ~LTII~rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Loss of RCS and PC Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

29

OSSI 92~2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies

~Rm ~rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

1 2

Condition not supported in PEG.

3 47 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

4Q Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

17 17 Condition not supported in PEG.

17 17 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

17 Subsumed ln "Judgment" EAL.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condltfon not supported in PEG.

Condition not supported in PEG.

30

gi a

O'.I 4)

"IC

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies

~~P-5Q, ~Rm~r]~

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

I 2

Condition not supported in PEG.

3 47 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

1 2

Condition not supported in PEG.

3 Subsumed in "Judgment" EAL.

31

C4 ~

T

• 1

OSSI 92~2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table C IP-2/3 Fission Product Barrier Site Area Emergencies

~NE P~ ~Rm >~k Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

32

'4

• 1 I' f C

OSSI 92402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies PEP~7 ~Remark Loss of FC + loss of RCS + pot. loss of PC Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

ass Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

~

1 l, 27 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

4, ll 33

C i

),

OSSI 92M2A-2-IP2 IP2 Fission Product Bamer EAL Evaluation, Rcv. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP-007 Remarks 11, 26 11,6 11, 29 Condition not supported in PEG.

Condition not supported in PEG.

ll 11,9 ll, 30 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

11,4 11, 26 11,6 11, 29 Condition not supported in PEG.

Condition not supported in PEG.

11,8 11,9 11, 30 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

CondNon not supported in PEG.

34

IA Tr ~

~ '

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP-0 Remarks Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed.in "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftfon not supported fn PEG.

Condition not supported fn PEG.

Condftfon not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

35

OSSI 92%2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NE P-0 7 ~Remark Condition not supported in PEG.

Conditfon not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condltfon not supported in PEG.

Condition not supported ln PEG.

Conditfon not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftfon not supported in PEG.

Condition not supported in PEG.

Condltfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condltfon not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

36

~ l OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies

~NE')QP- g7 ~Remark Condition not supported fn PEG.

CondfUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

CondfUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondfUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG, 37

CC k3 J

OSSI 92W2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NE P- 07 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

26 6

Condition not supported in PEG.

Condition not supported in PEG.

9 38

1,

• 's I qh

'et

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies N~EP-00 Remarks 9

10 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

4 26 6

My~&(RFN<.~~gggg~),,,PEN~~ F@P~~X~~~RPC~~c~,.., ~>,,

Condition not supported in PEG.

Condition not supported in PEG.

8 9

10 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

ess Condition not supported in PEG.

Subsumed in "Judgment" EAL.

4 26 6

35, Addressed inAet5%+Dep stpt pres, above.

Condition not supported in PEG.

Condition not supported in PEG.

8 39

4~

F>

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE ~P-0 2 ~Remark 9

10 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed fn "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

li OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP- 07 ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

9, ll 9, 11 9, ll 9, 11 Condition not supported in PEG.

Condition not supported in PEG.

9, ll 9, 11 9, 11 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

9, 11 9, ll 9, ll 9, ll Condition not supported in PEG.

Condition not supported in PEG.

9, ll 9, ll 9, 11 41

OSSI 92402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rcv. 0 Table D '- IP-2/3 Fission Product Barrier General Emergencies NES~P- Remarks Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

9, ll 9,11 9, 11 9, ll CondfUon not supported in PEG.

Condftfon not supported in PEG.

9, 11 9, ll 9, ll Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

42

~ n 4k fht ykb

~'

OSSI 92402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP-007 ~Remark Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftion not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

43

,1 Z4 J

OSSI 92-4)2A-2-IP2, IP2 Fission product Barrier EAL Evaluation, Rcv. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies

~NE P-(gg ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

CondNon not supported in PEG.

CondNon not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Jl OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rcv. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP-007 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftfon not supported in PEG.

Condftfon not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condftfon not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

45

L OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies NESP-007 ~Remark Condition not supported fn PEG.

Condftion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

4 26

',all"'-"'"':-.":,::ll,~ 6 Condition not supported in PEG.

Condition not supported fn PEG.

8 9, ll 10 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

26 6

If 4 f

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NEAP-(57 ~Remark CondiUon not supported in PEG.

CondiUon not supported in PEG.

8 9, ll 10 CondiUon not supported in PEG.

Subsumed 1n "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

26 6

34, Addressed in Rad5%+Dep stpt pres, above.

Condition not supported 1n PEG.

Cond1Uon not supported in PEG.

8 9, 11 10 CondiUon not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

CondiUon not supported in PEG.

Cond1tion not supported in PEG.

Condition not supported in PEG.

47

'I ~ I' I

~ \

4 I

S I

OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies RESP-00 ~Rem rk Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

48

l II l

ll p t

Ey

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE ~P- ~Rm ~rk Condition not supported fn PEG.

Condition not supported fn PEG.

CondlUon not supported fn PEG.

Condition not supported fn PEG.

Condltfon not supported fn PEG.

Condition not supported fn PEG.

Condftfon not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

CondlUon not supported fn PEG.

Condition not supported fn PEG.

CondfUon not supported fn PEG.

Condition not supported fn PEG.

CondfUon not supported fn PEG.

Condltfon not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condftfon not supported fn PEG.

49

+ l

'4 I yi

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NE P- 07 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftfon not supported in PEG.

50

T se l

(Q p

4(

\:,o

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NE P- 07 ~Rem rk Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

51

~ .

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies N~EP-0 7 ~Remark Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

52

J JJ'I a

1 a,f tl

OSSI 92402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rcv. 0 Table D IP-2/3 Fission Product Barrier General Emergencies RESP-0 ~Remark Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Loss of RCS + loss of PC + pot. loss of FC Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

53

C l

ta 4

L',

id

'0

OSSI 92402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies NE P- 07 ~Remark Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported ln PEG.

CondlUon not supported in PEG.

Condition not supported ln PEG.

CondlUon not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

CondlUon not supported ln PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

54

'g(w 4~>

gf ef 4-

~sq e

QSSI 92-4)2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE p-tlpIZ ~Rem k Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported ln PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

55

1 QSSI 92402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP-007 ~Remark Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

56

6i c'

OSSI 92-4)2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies NESP-007 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

57

Jl l h

,C <

OSSI 92402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies N~EP- 07 ~Rm ark Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

58

y',h 4g D

a.V I'qg il L

<< ~

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies RESP- 7 ~Rem rk Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

INN'%"'i!i'4,:u"'ll CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

59

Q OSSI 92402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP~ ~Rm'turk Condition not supported in PEG.

CondiUon not supported in PEG.

Subsumed in "Judgment" EAL.

48 48 Condition not supported in PEG.

48 48 Condition not supported in PEG.

CondlUon not supported ln PEG.

Subsumed in "Judgment" EAL.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Vs~

L IW P,.q

QSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0, Table D IP-2/3 Fission Product Barrier General Emergencies

~NE P~7 ~Rm~rk Condition not supported in PEG.

Condition not supported in PEG.

40 40 Condition not supported in PEG.

40 40 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condttton not supported In PEG.

Condition not supported in PEG.

RCS3a-los Condition not supported in PEG.

Subsumed in "Judgment" EAL.

61

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NB l~P- )7 ~Remark 39 39 39 39 Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

39 39 Condition not supported in PEG.

39 39 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

39 39 Condition not supported in PEG.

39 39 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

62

i A

~II I ll t

~I \

OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE P~7 ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

Condftion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 40 Condition not supported in PEG.

40 40 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

4) 4 1

1y*

4

'J~

OSSI 92-42A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rcv. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE P-gQQ ~Rem k Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

1 sa

.1 4

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies PEP~7 ~Rm~rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported 1n PEG.

Condition not supported 1n PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

65

~ i g

OSSI 92-4)2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE P~7 ~Remark Condftion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condftfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

37 39 Condftfon not supported in PEG.

39 66

~

l 4

'J gag

OSSI 92-4)2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE P~7 ~Rem rk 39 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

39 39 Condition not supported in PEG.

39 39 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

39 39 Condition not supported in PEG.

39 39 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

39 39 Condition not supported in PEG.

39 39 Condition not supported in PEG.

67

l~

4J D

l l t

'I I J4h

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NEF~P- ~Rm ~rk Condition not supported in PEG.

Subsumed in "Judgment" EAL.

CondlUon not supported in PEG.

CondlUon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 40 Condition not supported in PEG.

40 40 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

68

4 4 Q'(

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rcv. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE P~7 Remarks Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

69

tQ Xi.

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE P-007 Remarks Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

CondNon not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

CondNon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

70

I h",'I IO t ly gf pC

'1

QSSI 92M2A-2-IP2 IP2 Fission Product Bamer EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP-007 Remarks Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported fn PEG.

Subsumed in "Judgment" EAL.

CondiUon not supported in PEG.

CondlUon not supported in PEG.

CondlUon not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

71

ey.

J jI

OSSI 92-42A-2-IP2 IP2 Fission Product Bamer EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP-007 ~Rem rk Condition not supported ln PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL..

Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

72

ll~

l 4,g 4

4

"'~\ 4

OSSI 92-42A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies

~Remark Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Cond1tion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Cond1tion not supported in PEG.

Condition not supported in PEG.

Cond1tion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported 1n PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgmt:nt" EAL.

73

~'

I

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies N~EP- 07 ~Remark Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

74

QC I

I P(

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE P~ ~Rem rk Loss of PC + loss of FC + pot. loss of RCS Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

CondNon not supported in PEG.

CondNon not supported in PEG.

75

II OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies N~EP- 07 Remarks Condition not supported in PEG.

Condition not supported 1n PEG.

Condition not supported 1n PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported 1n PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Cond1Uon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported 1n PEG.

Condition not supported 1n PEG.

Condition not supported in PEG.

ll ll ll 76

t OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP-(IPIg ~Remark CondNon not supported in PEG.

ll Condition not supported in PEG.

CondNon not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

'.r 0!!!-'-':-'::::ll!'!*'"!!~AD"-"'! "-""

'i! ":-"":iiiiiii'iii 41 41 Condition not supported in PEG.

41 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

9, ll 9, ll 9, ll CondNon not supported in PEG.

9, ll Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

77

t ii l'g~ 1 4 t

OSSI 92-42A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies N~EP-007 ~Remark Condition not supported fn PEG.

CondiUon not supported in PEG.

41 41 Condition not supported fn PEG.

41 Condftion not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

CondiUon not supported fn PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

CondfUon not supported fn PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

ll ll ll CondfUon not supported in PEG.

ll Condition not supported in PEG.

Condition not supported in PEG.

78

) ~~ a OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies RESP-0 ~Remark Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

42 42 Condition not supported ln PEG.

42 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

9, ll 9, ll 9, ll Condition not supported in PEG.

9, 11 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

IPG2b'-Joss'"'::.':::::.:'+ '-K5-Joss""w" ""': Condition not supported in PEG.

Condition not supported in PEG.

@'-:42:"InorJoeaNDr+:Md':: ~r':::44:'%@rN'-":-

79

Nl ail 1

OSSI 92%2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies N~E~P- ~Rem rk 42 42 Condition not supported in PEG.

42 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported ln PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

80

4 wf S

~94

) 11

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rcv. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE')~P- ~Remark Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported ln PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

CondiUon not supported ln PEG.

81

+d hat

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rcv. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NE P-007 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Cond1tion not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Cond1tion not supported in PEG.

Condition not supported in PEG.

ll ll Condition not supported 1n PEG.

ll Condition not supported in PEG.,

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported 1n PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

82

tV e$

<p g 1

Ql Jg C'

41 J e

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies MNE MP- 2 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

ll ll Condition not supported in PEG.

ll Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

48 48 48

P Lg4 II

OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NE P-007 Remarks Condition not supported in PEG.

48 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

9, ll 9, ll 9, ll Condition not supported in PEG.

9, ll Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

48 48 48 Condition not supported in PEG.

48 Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

85

OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE P~7 Remarks Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

oss Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

86

~ I,"

r.,

< 4 ~

IK$

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP- 7 ~Remark Condition not supported in PEG.

CondfUon not supported in PEG.

CondiUon not supported in PEG.

CondfUon not supported in PEG.

Condition not supported in PEG.

CondfUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondfUon not supported in PEG.

Condftfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

87

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE ~P- ~Remark Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

88

tl tQ g I

t,PI Il ~

Yi '

OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE P~ ~Rem k Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

89

I

~

OSSI 92402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP-007 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

v~'

v

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies NESP-007 ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftfon not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported fn PEG.

Conditfon not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftion not supported in PEG.

ll 91

A

~:,

4

~a

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP-007 ~Remark Condition not supported in PEG.

ll Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Cond1tion not supported in PEG.

Condition not supported in PEG.

Condition not supported 1n PEG.

Condition not supported in PEG.

40 40 40 Condition not supported in PEG.

40 Cond1tion not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

9, ll Qss 9, 11 9, ll Condition not supported in PEG.

9, ll Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported 1n PEG.

<7 t I I

E:

J

OSSI 924)2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NES~P- ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 40 40 CondiUon not supported in PEG.

40 CondiUon not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.,

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

CondiUon not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

93

)

J 7

~ ~

)1

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies N~EP- 07 ~Remark Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL, Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

g,l g th

'i4,>>

4

OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE I~P- ()7 ~Remark Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Loss of FC + loss of RCS + loss of PC Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

95

a~'~

E. g 3

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NE P-007 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

ll, 26 ll Condition not supported in PEG.

ll ll Condition not supported in PEG.

Condition not supported in PEG.

ll Subsumed in "Judgment" EAL.

Condition not supported in PEG.

ll, 26 11,6 Condition not supported in PEG.

ll ll Condition not supported in PEG.

Condition not supported in PEG.

96

f 7

OSSI 92-4)2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rcv. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies NE!~P- )~0 ~Remark Condition not supported in PEG.

ll Subsumed fn "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftfon not supported in PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

ll. 26 11,6 Condition not supported in PEG.

ll ll Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

ll Subsumed in "Judgment" EAL.

Conditfon not supported in PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

97

ig~

) I

% 'E i'SJ rE

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NE P- 07 ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG'.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

98

~ I l

k's

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~Rem rk Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

CondlUon not supported in PEG.

Condftion not supported in PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftion not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

a'I t '4

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP-007 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

100

I k

h

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP- 7 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported In PEG.

Condition not supported in PEG.

26 42 Condition not supported in PEG.

43 48 Condition not supported In PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

26 6, 42 101

Ql OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NEAP- )Q7 ~Remark Condition not supported in PEG.

43 48 Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

26 6,42 Condition not supported in PEG.

43 48 Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

Subsumed in "Judgment" EAL.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

102

(3 y>>

h,,"

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP- 07 ~Remark Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Cond%on not supported in PEG.

103

g1 gs

+)0 I~

II

't

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE P~7 ~Rem rk Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

9, 11,26 9, 11,42 CondNon not supported in PEG.

43 48 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

48 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

9, 11,26 9, 11,42 Condition not supported in PEG.

43 48 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

"J 7

1 jI,

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies N~EP-0 7 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

9, 11,26 9, 11,42 Condition not supported in PEG.

43 48 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

105

j 7'

l1

'f 4 C't p

OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP- 07 ~Remark CondNon not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

106

I ic I

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NEAP- )~ Remarks Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondfUon not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Conditfon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

107

~4 C~

C~

E ref l'W P

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies N~E')+P- g7 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

108

<<t1I, OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies NE P-0 7 ~Rem k CondiUon not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

26 6, 42 Condition not supported in PEG.

43 48 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

26 6,42 CondiUon not supported in PEG.

43 48 CondiUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

109

4.

lg14 >

E. I

OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~Rem k Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

26 6,42 Condition not supported in PEG.

43 48 Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

40 Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

110

• 1 A

e~

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies NESP- 7 ~Remark Subsumed in "Judgment" EAL.

Condition not supported in PEG.

'ubsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondfUon not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

CondfUon not supported in PEG.

Condition not supported in PEG.

CondfUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condftion not supported in PEG.

l Ql A,

E'j

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NB P~7 Remarks Condition not supported in PEG.

CondNon not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG. ~

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

112

~ g lg

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table 0 IP-2/3 Fission Product Barrier General Emergencies NESP-007 ~Remark Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported fn PEG.

Condition not supported fn PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported fn PEG.

Condltfon not supported in PEG.

Condition not supported fn PEG.

Condftfon not supported in PEG.

Condition not supported in PEG.

Condition not supported fn PEG.

113

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t> 4

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE P~ ~Remark Condition not supported in PEG.

Condition not supported in PEG.

CondiUon not supported in PEG.

CondiUon not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

CondlUon not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported ln PEG.

Condition not supported ln PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed ln "Judgment" EAL.

Subsumed ln "Judgment" EAL.

Condition not supported in PEG.

CondlUon not supported in PEG.

CondlUon not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed ln "Judgment" EAL.

114

4 XJ 1

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OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies

~NE ~P- ~Rm~rk Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

Subsumed ln "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported ln PEG.

115

lt Ew'

OSSI 92-402A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Table D IP-2/3 Fission Product Barrier General Emergencies RESP- 7 ~Rm~rk Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

Condition not supported in PEG.

Condition not supported in PEG.

Condition not supported in PEG.

Subsumed in "Judgment" EAL.

Subsumed in "Judgment" EAL.

116

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OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rcv. 0 Appendix 1 Fission Product Barrier Remarks The only source of significant containment pressure increase other than a faulted steam generator is an RCS boundary breach. By definition, loss of the RCS boundary and the loss of the primary containment boundary require a Site Area Emergency classification. Therefore, this EAL is unnecessary and can be deleted.

2. If an inconsistent loca response is observed, a loss of the RCS has occurred, By definition, loss of the RCS boundary and the loss of the primary containment boundary require a Site Area Emergency classification. Therefore, this EAL is unnecessary and can be deleted.

3. The initiation signal for containment isolations are result of an RCS breach. By definition, loss of the RCS boundary and the loss of the primary containment boundary require a Site Area Emergency classification. Therefore, this EAL is unnecessary and can be deleted.

4, In order to reach containment-red on the CSFST, containment design pressure has been reached or exceeded. This is indicative of a loss of RCS boundary. It is not possible to reach this condition without also being in a Heat Sink-Red or Core Cooling-Red.CSFST which is a loss of RCS and the fuel clad barrier. The source of energy must be the result of severe degradation of core cooling or loss of heat sink. Since the EAL is a potential loss of containment by definition, this combination of conditions requires the declaration of a General Emergency. Therefore, this EAL is unnecessary and can be deleted.

5, Containment design pressure can only be reached as a result of a severe loca event. This represents a loss of the RCS barrier and a potential loss of the primary containment. By definition, this combination of conditions requires the declaration of at least an Alert classification.

Therefore, this EAL is unnecessary and can be deleted.

6. Generation of this level of hydrogen concentration in the containment indicates that a loss of fuel clad barrier and loss of RCS barrier has occurred with a potential loss of the primary containment barrier. By definition. this combination of conditions requires the declaration of a General Emergency. Therefore, this EAL is unnecessary and can be deleted.

7. The conditions listed in this EAL represent a loss of the RCS barrier with a potential loss of containment. By definition, the loss of the RCS barrier 1-1

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QSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rcv. 0 Appendix 1 Fission Product Barrier Remarks requires the declaration of an Alert. Therefore, this EAL is unnecessary and can be deleted.

8. These containment radiation levels can only be reached as a result of a severe core damage. This represents a loss of the fuel clad barrier and the loss of the RCS barrier with a potential loss of the primary containment. By definition, this combination of conditions requires the declaration of a General Emergency. Therefore, this EAL is unnecessary and can be deleted.

9 Core Exit Thermocouple readings 21200 'F with a failure of restoration procedures represent a potential loss of the primary containment, a loss of fuel clad barrier, and a loss of subcooling which is a fundamental indication of a loss of the RCS barrier. By deQnition, this combination of conditions requires the declaration of a General Emergency. Therefore, this EAL is unnecessary and can be deleted.

10. A Core Exit Thermocouple reading 2700 'F with reactor vessel water level below the top of active fuel requires entry to the Core Cooling-Red CSFST and warrants declaration of a General Emergency. See justification ¹11.

Therefore, this EAL is unnecessary and can be deleted.

Core Cooling-Red on the CSFST is indicative of a Core Exit Thermocouple reading of 21200 'F, or reactor vessel water level below the top of active fuel with a Core Exit Thermocouple reading of >700 'F. EAL¹ FC3.1 and EAL¹ FC3.2 represent a loss and potential loss of the fuel clad based on Core Exit Thermocouple readings of 1200 'F and 700 'F, respectively, EAL¹ RCS2.1 represents a loss of subcooling, therefore, entry into Core Cooling-Red also represents a loss of the RCS barrier. EAL¹ PC6.5 is indicative of a Core Exit Thermocouple reading 2700 'F and represents a potential loss of primary containment barrier. Thus, entry into Core Cooling-Red requires declaration of a General Emergency. Therefore, this EAL is unnecessary and can be deleted.

12, Core Cooling-Orange on the CSFST represents a potential loss of the fuel clad barrier and a loss of subcooling which is indicative of a loss of the RCS barrier. By definition, this combination of conditions requires the declaration of a Site Area Emergency, Therefore, this EAL is unnecessary and can be deleted.

1-2

II Ql I

% Tech. Spec.

provides a pathway from the RCS to outside containment, WhOe it is feasible for both of these conditions to exist simultaneously, they are not related such that the failure associated with red path integrity (reactor vessel structural failure) interfaces with the containment loss mechanism (steam generator tube leakage). Therefore this combination is not appropriate.

47. While RCS 2.1 and RCS4.1 are losses of RCS, the concern for RCS loss is reactor vessel integrity. PC4.1 is a loss of containment in that a secondary side release with primary to secondary leakage > Tech. Spec.

provides a pathway from the RCS to outside containment. WhQe it is feasible for both of these conditions to exist simultaneously, they are not related such that the failure associated with a loss of coolant (reactor vessel structural failure) interfaces with the containment loss mechanism (steam generator tube leakage). Ifprimary to secondary leakage was of the magnitude to have caused the loss of inventory, then declaration would be made per RCS 3.1. Therefore this combination is not appropriate.

While RCS 1.1, RCS1.2, RCS 2.1 and RCS4.1 are losses of RCS, the concern for RCS loss is reactor vessel integrity. PC4.1 is a loss of containment in that a secondary side release with primary to secondary leakage > Tech. Spec. provides a pathway from the RCS to outside

, containment. WMe it is feasible for both of these conditions to exist simultaneously in conjunction with one or more of the fuel clad loss indicators (FC1.2, FC1.3, FC2.1, FC3.2, FC4.1, FC5.1), they are not related such that the failure associated with a loss of coolant (reactor vessel structural failure) interfaces with the containment loss mechanism (steam generator tube leakage). If SG leakage was of the magnitude to have caused the loss of inventory, then declaration would be made per RCS 3.1 + one of the fuel clad loss indicators. Therefore this combination is not appropriate.

1-7

OSSI 92<2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Appendix 2 Summary of Fission Product Barrier Evaluation The following summarizes the EALs which resulted from the analysis performed of the fission product barrier methodology of NUMARC-007 for Indian Point 2:

Unusual Event

~ PC4. 1-loss

~ PC7. 1-loss

~ Emergency Director Judgement Alert:

~ FC2.1-loss

~ RCS1.1-pot loss

~ RCS2.1-loss

~ RCS4.1-loss

~ RCS2.2-pot loss

~ Emergency Director Judgement Site Area Emer enc:

~ FC1.2-pot loss

~ FC1.3-pot loss/RCS1.2-pot loss

~ RCS3.1-loss

~ FC5. 1-loss

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Appendix 2 Summary of Fission Product Barrier Evaluation Site Area Emer enc cont:

~ PC2.1-loss

~ PC2.2-loss

~ PC3. 1-loss

~ RCS2.2-pot loss + PC4. 1-loss

~ FC2.1-loss + PC4.1-loss

~ Emergency Director Judgement General Emer enc:

~ PC1.1-pot. loss

~ FC1.1-loss

~ PC2.4-pot. loss

~ PC5.1-pot. loss

~ PC2.5-pot loss + ANY:

-FC2. 1-loss

-FC5. 1-loss

~ RCS3. 1-loss + ANY:

-FC1.2-pot loss

-FC1.3-pot loss

-FC2. 1-loss

-FC3.2-pot loss

-FC4. 1-pot loss

-FC5. 1-loss

OSSI 92M2A-2-IP2 IP2 Fission Product Barrier EAL Evaluation, Rev. 0 Appendix 2 Summary of Fission Product Barrier Evaluation General Emer enc cont:

~ PC2.1-loss + ANY:

-FC1.2-pot loss

-FC1,3-pot loss

-FC2.1-loss

-FC3.2-pot loss

-FC4. 1-pot loss

-FC5. 1-loss

~ PC2.2-loss + ANY:

-FC1.2-pot loss

-FC1.3-pot loss

-FC2.1-loss

-FC3.2-pot loss

-FC4. 1-pot loss

-FC5.1-loss

~ PC3.1-loss + ANY:,

-FC1.2-pot loss

-FC1.3-pot loss

-FC2.1-loss

-FC3.2-pot loss

-FC4. 1-pot loss

-FC5. 1-loss

~ PC6,1-pot. loss

~ PC6.2-pot loss

~ Emergency Director Judgement 10

'1 OSSI 92-402A-3-PWR PWR EAL Binning Document, Rev. 0 1.0 CSFST Status Subcriticality CSFST Status SA2.1 SS2.1 SG2.1 (Heat Sink) gP2(IP3) redundant to 1.3 Core Cooling CSFST Status FC1.1 (General)

FC1.2 (SAE)

PC6.1(General)

PC6.2(General)

SG2.1 (Core Cooling)

Heat Sink CSFST Status FC1.3/RCS1.2 (SAE)

SS4.1 SG2.1 (Heat Sink) 1.4 Integrity CSFST Status RCS1.1 (Alert)

Containment CSFST Status PC1.1 (General) 2.0 Reactor Fuel 2.1 Coolant Activity SU4.2 FC2,1 (Alert) 2.2 Failed Fuel Detectors (Ginna only)

SU4.1 FC6.1 (Alert)

FC6.1 + RCS1.1 (SAE)

+ RCS2.2 (SAE)

+ RCS2.1 (SAE) 2.8 Containment Radiation RCS4.1 (Alert)

FC5.1 (SAE)

PC5.1 (General) 2.4 Refueling Accidents or Other Radiation Monitors AU2.1 AA2.1 AA2.2

OSSI 92-402A-3-PWR PWR EAL Bfnnlng Document, Rev. 0 8.0 Reactor Coolant System 8.1 RCS Leakage SU5.1 RCS2.2 (Alert)

SS5.1 Primary to Secondary Leakage PC4.1 (NUE)

PC4.1 + RCS2.2 (SAE)

PC4.1 + FC2.1 (SAE) 8.8 RCS Subcooling RCS2.1 (Alert) 4.0 Containment 4.1 Contai nment Integrity Status PC7.1 (NUE)

PC2.1 (S AE)

PC2.2 (S AE)

PC3.1 (S AE)

PC2.5 + FC2.1 (General)

+ FC5.1

+ FC6.1(Ginna only)

PC2.1 + FC1.2(General)

+ FC1.3

+ FC2.1

+ FC3.2

+ FC4.1

+ FC5.1

+ FC6.1(Ginna only)

PC2.2 + FC1.2(General)

+ FC1.3

+ FC2,1

+ FC3.2

+ FC4.1

+ FC5.1

+ FC6.1(Ginna only)

PC3.1 + FC1.2(General)

+ FC1.3

+ FC2.1

+ FC3.2

+ FC4.1

+ FC5.1

+ FC6.1(Ginna only)

OSSI 92-402A-3-PWR PWR EAL Banning Document, Rev. 0 4.2 SG Tube Rupture with Secondary Release RCS3.1(SAE)

RCS3.1 + FC1.2(General)

+ FC1.3

+ FC2.1

+ FC3.2

+ FC4.1

~

+ FC5.1

+ FC6.1(Ginna only) 4.8 Combusible Gas Concentrations PC2.4(General) 5.0 Radioactivity Release /Area Radiation 5.1 EQluent Monitors AU1.1 AA1.1 AS1.1 AG1.1 5.2 Dose Projections/ Environmental Measurements AU1.2 AA1.2 AS1.3 AS1.4 AG1.3 AG1.4 5.8 Area Radiation Levels AU2.4 AA3.1 AA3.2

OSSI 92-402A-3-PWR PWR EAL BInntng Document, Rev. 0 6.0 Electrical Failures 6.1 Loss of AC Power Sources SU1.1 SA1.1 SA5.1 SS1.1 SG1.1 6.2 Loss of DC Power Sources SU7.1 SS3.1 V.O Equipment Failures 7.1 Technical SpeciQcation Requirements SU2.1 7.2 System Failures or Control Room Evacuation HU1.6 HA1.6 HA5.1 HS2.1 SA3.1 7.3 Loss of Indications/Alarm/Communication Capability SU3.1 SU6.1 SA4.1 SS6.1

OSSI 92-402A-3-PWR PWR EAL Bfnnlng Document. Rev. 0 8.0 Hazards 8.1 Security Threats HU4.1 HU4.2 HA4.1 HA4.2 HS1.1 HS1.2 HG1.1 HG1.2 8.2 Fire or Explosion HU2.1 HU1.5 HA2.1 8.3 Man-Made Events HU1.4 HU3.1 HU3.2 HA1.5 HA3.1 HA3.2 8.4 Natural Events HU1.1 HU1.2 HU1.3 HU1.7 HA1.1 HA1.2 HA1.3 HA1.7 9.0 Other FC7.1 RCS6.1 PC8.1 HU5.1 HA6.1 HS3.1 HG2.1

OSSl-92-n02~-4-lp2 IP2 EAL Tccl>nlcal Bases Docuhnchht, Rcv 0 New York EAI~ Upgrade project InChan Pohnt 2 Emergency Action Levels J

Technical Bases Revision 0 6/20/94 8 Bi~a=.~'m m

'~a=a e~x-Operations Support Services, Inc.

233 Water Street 2nd Floor Plyrnoutl>, Mh 02360

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OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document. Rev 0 PURPOSE The purpose of this document is to provide an explanation and rationale for each of the emergency action levels (EALs) included in the EAL Upgrade Program for Indian Point Station No. 2 (IP-2). It is also intended to facilitate the review process of the IP-2 EALs and provide historical documentation for future reference. This document is also intended to be utilized by those individuals responsible for implementation of IP-1024 "Emergency Classification" as a technical reference and aid in EAL interpretation.

DISCUSSION EALs are the plant-specific indications, conditions or instrument readings which are utilized to classify emergency conditions defined in the IP-2 Emergency Plan.

Subsequent to the acceptance by the NRC of MB~C/NESP-007 "Methodology for Development of Emergency Action Levels" as an acceptable alternative to the NUREG 0654 EAL guidance, the four nuclear utilities in the State of New York decided to perform a joint implementation of the new methodology. This upgrade project involved the following plants:

~ Nine Mile Point Unit 1 (NMPC)

~ Nine Mile Point Unit 2 (NMPC)

~ James A. FitzPatrick Nuclear Power Plant (NYPA)

~ Indian Point Station 2 (ConEd)

~ Indian Point 3 Nuclear Power Station (NYPA)

~ R.E. Ginna Nuclear Power Station (RG&E)

While the upgraded EALs are site specific, an objective of the upgrade project was to ensure conformity and consistency between the sites to the extent possible.

The revised EALs were derived from the Initiating Conditions and example EALs given in the IP-2 Plant-Specific EAL Guideline (PEG). The PEG is the IP-2 interpretation of the NUMARC methodology for developing EALs, The PEG identifies deletions from the NUMIARC methodology by striking out words and phrases that are not applicable to IP-2; additions are identified by underlining new words and phrases. The source of documents for PEG changes from NUMARC methodology are listed in the references section of the PEG.

Many of the EALs derived from the NUMARC methodology are fission product barrier based. That is, the conditions which define the EALs are based upon loss or potential loss of one or more of the three fission product barriers.

, r

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OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 The primary fission product barriers are:

A. r F 1 I in The fuel cladding is comprised of the zirconium tubes which house the ceramic uranium oxide pellets along with the end plugs which are welded into each end of the fuel rods.

B. r 1 n m The RCS is comprised of the reactor vessel shell, vessel head, vessel nozzles and penetrations and all primary systems directly connected to the reactor vessel up to the first containment isolation valve.

C.~i'Th t' p'ftl containment structure and all isolation valves required to p

maintain containment integrity under accident conditions.

The following criteria serves as the bases for event classification related to fission product barrier loss:

1E Any loss or potential loss of containment

~Al ~

Any loss or any potential loss of either fuel clad or RCS i Ar Em r n Any loss of both fuel clad and RCS or Any potential loss of both fuel clad and RCS or Any potential loss of either fuel clad or RCS with a loss of any additional barrier nrlEmr Loss of any two barriers with loss or potential loss of a third Those EALs which reference one or more of the fission product barrier IC designators (FC, RCS and PC) in the PEG Reference section of the technical bases are derived from the Fission Product Barrier Analysis. The analysis entailed an evaluation of every combination of the plant specific barrier loss/potential loss indicators applied to the above criteria.

K

'I

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 Where possible, the EALs have been made consistent with and utilize the conditions defined in the IP-2 Critical Safety Function Status Trees (CSFSTs). While the symptoms that drive operator actions specified in the CSFSTs are not indicative of gll possible conditions which warrant emergency classification, they do define the symptoms, independent of initiating events, for which reactor plant safety and/or fission product barrier integrity are threatened. Where these symptoms are clearly representative of one of the PEG Initiating Conditions, they have been utilized as an EAL. This allows for rapid classification of emergency situations based on plant conditions without the need for additional evaluation or event diagnosis. Although some of the EALs presented here are based on conditions defined in the CSFSTs, classification of emergencies using these EALs is not dependent upon Emergency Operating Procedures (EOPs) entry or execution. The EALs can be utilized independently or in conjunction with the EOPs.

To the extent possible, the EALs are symptom based. That is, the action level is defined by values of key plant operating parameters which identify emergency or potential emergency conditions. This approach is appropriate because it allows the full scope of variations in the types of events to be classified as emergencies. But, a purely symptom based approach is not suf6cient to address all events for which emergency classification is appropriate. Particular events to which no predetermined symptoms can be ascribed have also been utilized as EALs since they may be indicative of potentially more serious conditions not yet fully realized.

The EALs are grouped into nine categories to simplify their presentation and to promote a rapid understanding by their users. These categories are:

1. CSFST Status

2. Reactor Fuel

3. Reactor Coolant System

4. Containment

5. Radioactivity Release / Area Radiation

6. Electrical Failures

7. Equipment Failures

8. Hazards

9. Other Categories 1 through 5 are primarily symptom based. The symptoms are indicative of actual or potential degradation of either fission product barriers or personnel safety.

Categories 6, 7 and 8 are event based. Electrical Failures are those events associated with losses of either AC or vital DC electrical power. Equipment Failures are abnormal and emergency events associated with vital plant system failures, while Hazards are those non-plant system related events which have affected or may acct plant safety.

,3

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OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document. Rev 0 Category 9 provides the Emergency Director (Senior Watch Supervisor) the latitude to classify and declare emergencies based on plant symptoms or events which in his judgment warrant classification. This judgment includes evaluation of loss or potential loss of one or more fission product barriers warranting emergency classification consistent with the NUMARC barrier loss criteria.

Categories are further divided into one or more subcategories depending on the types and number of plant conditions that dictate emergency classifications. For example, the Electrical Failures category has two subcategories whose values can be indicative of losses of electrical power sources: loss of AC power sources and loss of DC power sources. An EAL may or may not exist for each sub category at all four classification levels.

Similarly, more than one EAL may exist for a sub category in a given emergency classification when appropriate (i.e. no EAL at the General Emergency level but three EALs at the Unusual Event level).

For each EAL, the following information is provided:

~ Classification: Unusual Event, Alert, Site Area Emergency, or General Emergency

~ Operating Mode Applicability: One or more of the following plant operating conditions are listed: Power Operation, Hot Shutdown, Cold Shutdown, Refuel and Defueled

~ EAL: Description of the condition or set of conditions which comprise the EAL

~ Basis: Description of the rationale for the EAL

~ PEG

Reference:

PEG IC(s) and example EAL(s) from which the EAL is derived

~ Basis Reference(s): Source documentation from which the EAL is derived

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document. Rev 0 P~

The identified operating modes are defined as follows Reactor shutdown margin is less than Technical Specification minimum required with coolant temperature (Tavg) at or above normal operating temperature.

Reactor shutdown margin greater than or equal to Technical Specification minimum required with coolant temperature (Tavg) less than normal operating temperature.

~h Reactor shutdown margin greater than or equal to Technical Specification minimum required with coolant temperature (Tavg) less than or equal to 200 'F.

gg~l Reactor shutdown margin greater than or equal to Technical Specification minimum required for refueling operations and coolant temperature (Tavg) less than or equal to 140 'F.

Dafizdld Reactor vessel contains no irradiated fuel.

These operating modes correlate to the NUMARC-007 and PEG identified operating modes as follows:

hni 1B Power Operations Power Operations Startup/Hot standby Power Operation Hot Shutdown Hot Shutdown Cold Shutdown Cold Shutdown Refuel Refuel Defueled Defueled All All

$ I 'I OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document. Rev 0 Plant Emergency Operating Procedures (EOPs) are designed to maintain and/or restore a set of critical safety functions which are prioritized for restoration efforts during accident conditions. By monitoring the critical safety functions status, the impact of multiple events can be inherently addressed.

The critical safety functions are monitored through the use of Critical Safety Function Status Trees (CSFSTs). When certain plant parameters exceed threshold values specified by the CSFST, the plant operator is directed to one or more functional restoration and/or EOPs in an attempt to restore those parameters to within acceptable limits. The following CSFSTs are utilized to be indicative of failures or potential failures of one or more fission product barriers:

Cggdptd'tl'CSIIST'S reactivity control which may pose a threat to fuel clad and RCS tl f integrity.

G g Rdptd 'l'SIIST'l t I I core subcooling and thus pose a direct threat to the integrity of the reactor fuel clad.

~ Em~ink The Red path of this CSFST is indicative of a loss of ability to remove decay heat from the core and thus poses a direct threat to fuel clad integrity.

~ ~In gri~ The Red path of this CSFST is indicative of a direct threat to RCS barrier integrity.

H dp tg ftl 'SIISTI 'l t' I barrier and direct threat to the containment barrier integrity.

fRCS

f P q', A

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 1.0 CSFST Status 1.1 Subcriticality 1.1.1 -

Alert Either:

ORANGE path F-0.1 SUBCRITICALITY AND Emergency boration is required OR RED path F-0.1 SUBCRITICALITY AND Emergency boration is required Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Subcriticality - ORANGE path is entered based on failure of the intermediate range startup rate monitors to indicate negative or zero following reactor trip. This EAL addresses any manual trip or automatic trip signal followed by a manual which fails to shut down the reactor to an extent requiring emergency boration. A manual trip is any set of actions by the reactor operator(s) at the reactor control console which causes control rods to be rapidly inserted into the core and brings the reactor subcritical (e. g.,

reactor trip button).

This condition indicates failure of the automatic and manual protection systems to trip the reactor to the extent which precludes the reactor being made sub-critical. Although a front line automatic protection system did not function in response to a plant transient, it is the continued criticality under conditions requiring a reactor trip which poses the potential threat to fuel clad integrity and thus warranting declaration of an Alert.

PEG

Reference:

SA2.1 Basis Reference(s):

1. CSFST F-0.1, Subcriticality

2. FR-S.1, Response to Nuclear Generation/ATWS.

1-2

~y OSSI-92-402A-4-IP2 IP2 EAI. Technical Bases Document, Rev 0 1.0 CSFST Status 1.1 Subcriticality 1.1.2 Site Area Emergency RED path in F-0.1 SUBCRITICALITY AND either:

Emergency boration is inoperable OR Power range not ( 5% within 15 min. of initiation of emergency boration Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Subcriticality - RED path is entered based on failure of power range indication to decrease below 5% following a reactor trip. This portion of the EAL addresses any manual trip or automatic trip signal followed by a manual trip which fails to shut down the reactor to an extent that the reactor is producing more heat load for which the safety systems were designed. A manual trip is any set of actions by the reactor operator(s) at the reactor control console which causes control rods to be rapidly inserted into the core and brings the reactor subcritical (e. g,, reactor trip button).

This condition indicates failure of both the automatic and manual protection systems to trip the reactor in conjunction with a failure of alternate boration systems to reduce reactor power below decay heat levels. The combination of failure of both front line and backup protection systems to function in response to a plant transient, along with the continued production of heat poses a direct threat to fuel clad and RCS integrity and thus warrants declaration of a Site Area Emergency.

15 minutes is specified to allow time for emergency boration to be effective and provides a discriminator between SA2.1 and SS2.1. The classification should be made as soon as it is apparent that emergency boration is not or willnot be effective in reducing reactor power below 5%.

PEG

Reference:

SS2.1 1-3

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 Basis Reference(s):

1. CSFST F-0.1, Subcriticality

2. FR-S.1, Response to Nuclear Generation/ATWS 1-4

• p OSSI-92-402A-4-IP2 IP2 EAL TechnIcal Bases Document, Rev 0 1.0 CSFST Status 1.1 Subcriticality 1.1.3 General Emergency RE<D path in F-0.1, SUBCRITICALITY AND Emergency boration is required AND RED path in F<-0.3, HEAT SINK AND Heat sink is required Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Heat Sink - RE<D path is entered based on both:

~ all S/G's narrow range level < 8% (36% adv. cnmt,)

AND

~ Total feedwater flow to S/Gs < 400 gpm CSF<ST Subcriticality - RED path is entered based on 2 5% reactor power following a reactor trip.

The combination of these two conditions (Heat Sink-RED and reactor power 2 5%) indicates the ultimate heat sink function is under extreme challenge.

Additionally, the efforts to bring the reactor subcritical have been unsuccessful and, as a result, the reactor is producing more heat load for which the safety systems were designed. This situation could be the precursor for a core melt sequence.

A major consideration is the inability to initiallyremove heat during the early stages of this sequence. Ifemergency feedwater flow is insuf5cient to remove the amount of heat required by design from at least one steam generator, an extreme challenge should be considered to exist. This equates to a HEAT Sink RED condition.

In the event, this challenge exists at a time when the reactor has not been brought below the power associated with safety system design power (5%) a core melt sequence is considered to exist. In this situation, core degradation can occur rapidly. For this reason, the General Emergency declaration is intended to be anticipatory of the fission product barrier matrix declaration to permit maximum offsite intervention time.

1-5

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 PEG

Reference:

SG2.1 (Heat Sink) This EAL is redundant to 1.3.2 Basis Reference(s):

1. CSFST F-0.3, Heat Sink

2. CSFST F-0.1, Subcriticality

3. FR-S.1, Response to Reactor Restart/ATWS

4. FR-S.2, Response to Loss of Core Shutdown 1-6

OSSI-92-402A-4-IP2 IP2 EAI Technical Bases Document, Rev 0 1.0 CSFST Status 1.2 Core Cooling 1.2.1 Site Area Emergency ORANGE or RED path in F-0.2, CORE COOLING Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Core Cooling - ORANGE path is entered based on either:

~ Core exit thermocouples > 700 'F OR

~ RVLIS level < 39% w/ no RCPs (TAF)

< 44% w/4 RCPs

< 38% w/3 RCPs

< 20% w/2 RCPs

< 13%%uo w/1 RCPs Either condition indicates subcooling has been lost and that some clad damage may occur. It must also be assumed that the loss of RCS inventory is a result of a loss of RCS barrier. Therefore a Site Area Emergency is warranted based upon the potential loss of fuel clad with loss of RCS barriers.

PEG

Reference:

FC1.2 FC3.2 FC4.1 Basis Reference(s):

1. CSFST F-0.2, Core Cooling 1-7

r.

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 1.0 CSFST Status 1.2 Core Cooling 1.2.2 General Emergency RED path in F-0.2, CORE COOLING AND Functional restoration actions taken and procedures not effective within 15 min.

Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Core Cooling - RED path is entered based on either:

~ Core exit thermocouples ) 1200 'F OR

~ Core exit thermocouples ) 700 'F AND

~ RVLIS level < 39% w/ no RCPs (TAF)

< 44% w/4 RCPs

< 38% w/ 3 RCPs

< 20% w/2 RCPs

< 13% w/ 1 RCPs Either condition indicates significant core exit superheating and core uncovery and is considered a loss of the Fuel Clad Barrier. It must also be assumed that the loss of RCS inventory is a result of a loss of RCS barrier.

These conditions, ifnot mitigated, willlikely lead to core melt which willin turn result in a potential loss of containment, Therefore, declaration of a General Emergency is warranted.

Severe accident analyses (e. g., NUREG-1150) have concluded that function restoration procedures can arrest core degradation within the reactor vessel in a significant fraction of the core damage scenarios, and that the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide a reasonable period to allow function restoration procedures to arrest the core melt sequence. Whether or not procedures will be effective should be apparent within 15 minutes. The Emergency Director should make the declaration as soon as it is determined that the procedures have not been, or will not be effective.

For the purpose of this EAL the term 'effective'ith regards to functional restoration procedures means that the CSFST Core Cooling - RED path entry criterion no longer exists.

1-8

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 PEG

Reference:

FC1.1 SG2.1 (Core Cooling)

PC6.1 PC6.2 Basis Reference(s):

1. CSFST F-0.2, Core Cooling 1-9

l gag OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 1.0 CSFST Status 1.3 Heat Sink 1.3.1 Site Area Emergency RE<D path in F-0.3, HEAT SINK AND Heat sink is required Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Heat Sink - RED path is entered based on both:

~ all S/G's narrow range level < 8% (36% adv. cnmt.)

AND

~ Total feedwater flow to S/Gs < 400 gpm The combination of these two conditions indicates the ultimate heat sink function is under extreme challenge. This EAL addresses loss of functions required for hot shutdown with the reactor at pressure and temperature.

Under these conditions, there is an actual major failure of a system intended for protection of the public with potential for multiple 6ssion product barrier loss. Therefore, declaration of a Site Area Emergency is warranted, PEG

Reference:

FC1.3 RCS1.2 SS4.1 Basis Reference(s):

1. CSFST F-0.3, Heat Sink 1-10

I OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 1.0 CSFST Status 1.3 Heat Sink 1.3.2 General Emergency RE<D path in F-0.3, HEAT SINK AND Heat sink is required AND RE<D path in F-0.1, SUBCRITICALITY AND Emergency boration is required Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Heat Sink - RED path is entered based on both:

~ all S/G's narrow range level < 8% (36% adv. cnmt.)

AND

~ Total feedwater flow to S/Gs < 400 gpm CSFST Subcriticality - RED path is entered based on 2 5% reactor power following a reactor trip.

The combination of these two conditions (Heat Sink-RED and reactor power 2 5%) indicates the ultimate heat sink function is under extreme challenge.

Additionally, the efforts to bring the reactor subcritical have been unsuccessful and, as a result, the reactor is producing more heat load for which the safety systems were designed. This situation could be the precursor for a core melt sequence.

A major consideration is the inability to initiallyremove heat during the early stages of this sequence. Ifemergency feedwater flow is insufFicient to remove the amount of heat required by design from at least one steam generator, an extreme challenge should be considered to exist. This equates to a HEAT Sink RED condition.

In the event this challenge exists at a time when the reactor has not been brought below the power associated with safety system design power (5%) a core melt sequence is considered to exist. In this situation, core degradation can occur rapidly. For this reason, the General Emergency declaration is intended to be anticipatory of the fission product barrier matrix declaration to permit maximum offsite intervention time.

IA OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document, Rev 0 PEG

Reference:

SG2.1 (Heat Sink)

Basis Reference(s):

1. CSFST F-0.3, Heat Sink

2. CSFST F-0.1, Subcriticality

3. FR-S.1, Response to Reactor Restart/ATWS 4 FR-S.2, Response to Loss of Core Shutdown 1-12

phd g OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 1.0 CSFST Status 1.4 Integrity 1.4.1 Alert RED path on F-0.4, INTEGRITY Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Integrity - RED path is entered based on both:

~ exceeding RCS cooldown rate of 100 'F/hr AND

~ all RCS cold leg temperatures to the leR of the RCS Pressure/RCS Cold Leg Temperature Curve The combination of these two conditions indicates the RCS barrier is under significant challenge and should be considered a potential loss of RCS barrier.

Any loss or potential loss of RCS barrier warrants declaration of an Alert.

PEG

Reference:

RCS1.1 Basis Reference(s):

1, CSFST F-0.4, Integrity 1-13

4g OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 1.0 CSFST Status 1.5 Containment 1.5.1 General Emergency RED path F-0.5, CONTAINMENTresulting from loss of coolant Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Containment - RED path is entered based on exceeding containment design pressure of 47 psig. This pressure is well in excess of that expected from the design basis loss of coolant accident. This is indicative of a loss of both RCS and fuel clad boundaries in that it is not possible to reach this condition without also being in a Heat Sink-RED or Core Cooling-RED CSFST. The source of energy must be the result of severe degradation of core cooling or loss of heat sink. Since containment pressures at or approaching design levels is also a potential loss of containment, this combination of conditions requires the declaration of a General Emergency.

PEG

Reference:

PC1.1 Basis Reference(s):

l. CSFST F-0.5, Containment 1-14

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 1.0 CSFST Status 1.5 Containment 1.5.1 'eneral Emergency RED path F-0.5, CONTAINMENT Mode Applicability:

Power Operations, Hot Shutdown Basis:

CSFST Containment - RED path is entered based on exceeding containment design pressure of 47 psig. This pressure is well in excess of that expected from the design basis loss of coolant accident. This is indicative of a loss of both RCS and fuel clad boundaries in that it is not possible to reach this condition without also being in a Heat Sink-RED or Core Cooling-RED CSFST. The source of energy must be the result of severe degradation of core cooling or loss of heat sink. Since containment pressures at or approaching design levels is also a potential loss of containment, this combination of conditions requires the declaration of a General Emergency.

PEG

Reference:

PC1.1 Basis Reference(s):

1. CSFST F-0.5, Containment 1-14

II l4 I I

II I Il 41 fH Qp 4I%~)

OSSI-92-402A-4-IP2 IP2 EAL TechnIcal Bases Document, Rev 0 The reactor fuel cladding serves as the primary fission product barrier. Over the useful life of a fuel bundle, the integrity of this barrier should remain intact as long as fuel cladding integrity limits are not exceeded.

Should fuel damage occur (breach of the fuel cladding integrity) radioactive fission products are released to the reactor coolant. The magnitude of such a release is dependent upon the extent of the damage as well as the mechanism by which the damage occurred. Once released into the reactor coolant, the highly radioactive fission products can pose significant radiological hazards inplant from reactor coolant process streams. Ifother fission product barriers were to fail, these radioactive fission products can pose significant offsite radiological consequences.

The following parameters/indicators are indicative of possible fuel failures:

QEIIIA.i'D 'g dp ti, t I tfi product activity is very low. Small concentrations of fission products in the coolant are primarily from the fission of tramp uranium in the fuel cladding or minor perforations in the cladding itself. Any significant increase from these base-line levels is indicative of fuel failures.

~ n i i i Although not a direct indication or measurement of fuel damage, exceeding predetermined limits on containment high range radiation monitors under LOCA conditions is indicative possible fuel failures.

lin A '

i ' r Both area and process radiation monitoring systems designed to detect fission products during refueling conditions as well as visual observation can be utilized to indicate loss or potential loss of spent fuel cladding integrity.

2-1

OSSI-92-402A-4-IP2 IP2 EAL TechnIcal Bases Document, Rev 0 2.0 Reactor Fuel 2.1 Coolant Activity 2.1.1 Unusual Event Coolant sample activity 2 60/(E bar) pCi/cc Mode Applicability:

Basis:

Elevated reactor coolant activity represents a potential degradation in the level of safety of the plant and a potential precursor of more serious problems.

This EAL addresses reactor coolant samples exceeding coolant technical specifications, PEG

Reference:

SU4.2 Basis Reference(s):

1. Technical Specifications para. 3.1.D.1 2-2

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.1 Coolant Activity 2.1.2 Alert Coolant activity > 300 pCi/cc I-131 equivalent Mode Applicability:

Power operation, hot shutdown Basis:

Elevated reactor coolant activity represents a potential degradation in the level of safety of the plant and a potential precursor of more serious problems.

This amount of coolant activity corresponds to about 2% to 5% fuel clad damage. When reactor coolant activity reaches this level, significant clad heating has occurred and thus the fuel clad barrier is considered lost.

Therefore, declaration of an Alert is warranted.

A site specific evaluation of coolant activity associated with 5% clad failures was performed. The calculation was based upon WOG core damage assessment source terms and made the conservative assumption that the I-131 equivalent activity is 2 x I-131 source term (2 x 2.4E5 Ci). Based on a 90,000 gal. RCS volume 579 'F, the resulting coolant concentration was calculated as 102.3 pCi/cc. Since the assumptions and source of the NUMARC number is unknown, there is no way to know how these two numbers compare. It has been decided to use the value provided by MB~C.

PEG

Reference:

FC2.1 Basis Reference(s):

Letter from D. Gaynor to R. Burns 7/27/93 "EAL Technical Basis 2.1.2" 2-3

/It OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.2 Containment Radiation 2.2.1 Alert Rapid rise on R-41 or R-42 with coolant sample activity > 60/(E bar) pCi/cc and increasing RCS leakage Mode Applicability:

Power operation, hot shutdown Basis:

A rapid rise on R-41/42 with confirmation by coolant sample of concentrations in excess of Technical Specifications indicates the release of reactor coolant to the containment. The indication was derived assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with normal operating concentrations (i. e., within T/S) into the containment atmosphere. This EAL is indicative of a RCS leak only. IfR-25 readings increase to that specified by Reactor Fuel EAL 2.2.2, significant fuel damage would also be indicated.

PEG

Reference:

RCS4.1 Basis Reference(s):

1. None 2-4

Ilp' j Qf

OSSI-92-402A-4-IP2 IP2 EAI Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.2 Containment Radiation 2.2.2 Site Area Emergency Containment radiation monitor R-25 or R-26 ) 17 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

The 17 R/hr reading is a value which indicates the release of reactor coolant, with elevated activity indicative of fuel damage, into the containment. The reading is calculated assuming the instantaneous release and dispersal'of the reactor coolant noble gas and iodine inventory associated with a concentration of 300 p,Ci/gm dose equivalent I-131 into the containment atmosphere. Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations allowed within technical specifications and are therefore indicative of fuel damage (approximately 5 %

clad failure depending on core inventory and RCS volume). This value is higher than that specified in EAL 2.2.1 which would be indicative of only the RCS barrier. Thus, this EAL indicates a loss of both the fuel clad barrier and a loss of RCS barrier warranting declaration of a Site Area Emergency.

PEG

Reference:

FC5.1 Basis Reference(s):

1. Letter from DA Smith 2-5

4

'Qt (

C

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.2 Containment Radiation 2.2.3 General Emergency Containment radiation monitor R-25 or R-26 > 68 Ehr Mode Applicability:

Power operation, hot shutdown Basis:

The 68 R/hr reading is a value which indicates signi6cant fuel damage (20 %

clad failure) well in excess of the EALs associated with both loss of fuel clad and loss of RCS barriers. A major release of radioactivity requiring offsite protective actions &om core damage is not possible unless a major failure of fuel cladding allows radioactive material to be released from the core into the reactor coolant. Regardless of whether containment is challenged, this amount of activity in containment, ifreleased, could have such severe consequences that it is prudent to treat this as a potential loss of containment, such that a General Emergency declaration is warranted.

NUREG-1228 "Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents," indicates that such conditions do not exist when the amount of clad damage is less than 20%.

PEG

Reference:

PC5.1 Basis Reference(s):

1. Letter from DA Smith 2-6

~ *r OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 2.0 Reactor Fuel 2.3 Refueling Accidents or Other Radiation Monitors 2.3.1 Unusual Event Spent fuel pool (reactor cavity during refueling) water level cannot be restored and maintained above the Technical Specification minimum water level Mode Applicability:

Basis:

In light of Reactor Cavity Seal failure, incidents at two difFerent PWRs and loss of water in the Spent Fuel Pit/Fuel Transfer Canal at a BWR all occurring since 1984, explicit coverage of these types of events via EALs 2.3.1 and 2.3.32 is appropriate given their potential for increased doses to plant staff. Classification as an Unusual Event is warranted as a precursor to a more serious event.

The spent fuel pool Technical Specification minimum water level is 93'".

The spent fuel pool low water level alarm setpoint is 93'". The definition of

"... cannot be restored and maintained above ..." allows the operator to visually observe the low water level condition, ifpossible, and to attempt water level restoration instructions as long as water level remains above the top of irradiated fuel. Water level restoration instructions for loss of refueling cavity water level during refueling are performed in accordance with AOI-17-0.3.

When the fuel transfer canal is directly connected to the spent fuel pool and reactor cavity, there could exist the possibility of uncovering irradiated fuel in the fuel transfer canal. Therefore, this EAL is applicable for conditions in which irradiated fuel is being transferred to and from the RPV and spent fuel pool.

PEG

Reference:

AU2.1 Basis Reference(s):

1. AOI-17-0.3

2. ARP-SGF 2-7

t V',f

OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document, Rev 0 2.0 Reactor Fuel 2.3 Refueling Accidents or Other Radiation Monitors 2.3.2 Alert Confirmed sustained alarm on any of the following radiation monitors resulting from fuel damage caused by an uncontrolled fuel handling process:

~ R-2/R-7 Vapor Containment Area Monitors

~ R-5 Fuel Storage Building Area Monitor

~ R-25/26 Vapor Containment High Radiation Area Monitors Mode Applicability:

Basis:

NUREG-0818, "Emergency Action Levels for Light Water Reactors," forms the basis for this EAL. This EAL is defined by the specific area where irradiated fuel is located such as reactor cavity, reactor vessel, or spent fuel pool.

NUIKG/CR-4982, "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82," July 1987, indicates that even ifcorrective actions are not taken, no prompt fatalities are predicted, and that risk of injury is low. In addition, NRC Information Notice No. 90-08, "KR-85 Hazards from Decayed Fuel" presents the following in its discussion:

"In the event of a serious accident involving decayed spent fuel, protective actions would be needed for personnel on site, while o6'site doses (assuming an exclusion area radius of one mile from the plant site) would be well below the Environmental Protection Agency's Protective Action Guides. Accordingly, it is important to be able to properly survey and monitor for Kr-85 in the event of an accident with decayed spent fuel."

An "uncontrolled fuel handling process" is defined as any event or activity related to the movement of irradiated fuel which results in unexpected or uncontrolled conditions. This terminology has been specifically added to exclude anticipated increases in area radiation levels as a result of actions performed in accordance with approved procedures during refueling operations.

Thus, an Alert Classification for this event is appropriate. Escalation, if appropriate, would occur via Emergency Director judgment in EAL Category 9.0.

2-8

Jg~

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 PEG

Reference:

AA2.1 Basis Reference(s):

1. System Description No. 12, Radiation Monitoring And Protection System

2. System Description No. 17, Fuel and Core Component Handling System 2-9

j OSSI-92-402A-4-IP2 IP2 EAI Technical Bases Document, Rev 0 2.0 .

Reactor Fuel 2.3 Refueling Accidents or Other Radiation Monitors 2.3.3 Alert Report of visual observation of irradiated fuel uncovered Mode Applicability:

Basis:

This EAL is defined by the specific areas where irradiated fuel is located such as reactor cavity, reactor vessel, or spent fuel pool.

There is no indication that water level in the spent fuel pool or refueling cavity has dropped to the level of the fuel other than by visual observation.

Since there is no level indicating system in the fuel transfer canal, visual observation of loss of water level would also be required.

SuKcient time exists to take corrective actions for these conditions and there is little potential for substantial fuel damage. NUIKG/CR-4982 "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82" indicates that even ifcorrective actions are not taken, no prompt fatalities are predicted and the risk of injury is low. In addition, NRC Information Notice No. 90-08, "KR-85 Hazards &om Decayed Fuel" presents the following it its discussion:

"In the event of a serious accident involving decayed spent fuel, protective actions would be needed for personnel on site, while offsite doses (assuming an exclusion area radius of one mile from the plant site) would be well below the Environmental Protection Agency's Protective Action Guides. Accordingly, it is important to be able to properly survey and monitor for Kr-85 in the event of an accident with decayed spent fuel.

Thus, an Alert Classification for this event is appropriate. Escalation, if appropriate, would occur via radioactivity release category 5.0 or Emergency Director judgment in EAL Category 9.0.

This EAL applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage.

2-10

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document. Rev 0 PEG

Reference:

AA2.2 Basis Reference(s):

1. System Description No. 12, Radiation Monitoring And Protection System

2. System Description No. 17, Fuel and Core Component Handling System

3. NUREG/CR-4982 "Severe Accident in Spent Fuel Pools in Support of Generic Safety Issue 82" 4 NRC Information Notice No. 90-08, "KR-85 Hazards from Decayed Fuel" 2-11

gA Qh

<<V4

%+t

OSSI-92-402A-4-IP2 IP2 EAL TechnIcal Bases Document, Rev 0 The reactor vessel provides a volume for the coolant which covers the reactor core. The reactor vessel and associated pressure piping (reactor coolant system) together provide a barrier to limitthe release of radioactive material should the reactor fuel cladding integrity fail.

There are three RCS parameters which are indicative of conditions which may pose a threat to RCS or fuel cladding integrity:

E I I>>T AC CAR 'I! I'RCSIS g indications are utilized to indicate potential pipe cracks which may propagate to an extent threatening fuel clad, RCS and containment integrity. RCS leakage of a degree requiring ECCS to maintain RCS inventory poses a direct threat to fuel clad integrity. Reactor vessel water level is also directly related to the status of adequate core cooling, and therefore fuel cladding integrity.

~ Prim n L k A subset of RCS leakage, excessive primary to secondary leakage in conjunction with unisolable secondary releases to environment may result in losses of containment integrity as well as threaten fuel clad integrity for more severe SG tube

~g ruptures.

Al IRCS A I'l that the inventory control systems are inadequate A

pressure and inventory against mass loss through a leak.

d ICI d'l in maintaining RCS 3-1

ki

.p%

Q,s

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 3.0 Reactor Coolant System 3.1 RCS Leakage 3.1.1 Unusual Event Unidentified or pressure boundary leakage ) 10 gpm OR Identified leakage > 25 gpm Mode Applicability:

Power operation, hot shutdown Basis:

The conditions of this EAL may be a precursor of more serious conditions and, as a result, is considered to be a potential degradation of the level of safety of the plant. The 10 gpm value for the unidentified leakage and pressure boundary leakage was selected because it is observable with normal Control Room indications. Smaller values must be determined through time-consuming sur veillance tests (e. g., mass balances). The 25 gpm value for identified leakage is set at a higher value because of the significance of identified leakage in comparison to unidentified or pressure boundary leakage.

Only operating modes in which there is fuel in the reactor coolant system and the system is pressurized are specified.

PEG

Reference:

SU5.1 Basis Reference(s):

None 3-2

gl, I

if'

OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document, Rev 0 3.0 Reactor Coolant System 3.1 RCS Leakage 3.1.2 Alert Primary system leakage exceeding capacity () 75 gpm) of a single charging pump Mode Applicability:

Power operation, hot shutdown Basis:

This EAL is based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) when RCS leakage exceeds the capacity of one charging pump. 75 gpm is the minimum operability Qow rate for each charging pump.

PEG

Reference:

RCS2.2 Basis Reference(s):

1. Drawing no. 1980M 1085

2. PT-Q33 3-3

44' r,r rrr'

OSSI-92-402A-4-IP2 IP2 EAI. Technical Bases Document. Rev 0 8.0 Reactor Coolant System 8.1 RCS Leakage 3.1.8 Site Area Emergency RVLIS cannot be maintained > 39% with no RCPs running OR With the reactor vessel head removed, it is reported that water level in the Reactor Vessel is dropping in an uncontrolled manner and core uncovery is likely Mode Applicability:

Power operation, hot shutdown, cold shutdown, refuel Basis:

The reactor vessel water level used in this EAL is the top of active fuel (TAF).

This value corresponds to the level which is used in CSFSTs to indicate challenge to core cooling and loss of the fuel clad barrier. This is the minimum water level to assure core cooling without further degradation of the clad. Severe core damage can occur and reactor coolant system pressure boundary integrity may not be assured ifreactor vessel water level is not maintained above that corresponding to RVLIS at 39% w/ no RCPs running (Dynamic range: < 44% w/4 RCPs, < 38% w/ 3 RCPs, < 20% w/ 2 RCPs, < 13%

w/ 1 RCPs). RVLIS dynamic range indications are not utilized in this EAL since the RCPs would not be running under conditions where vessel level is approaching TAF.

Thus, declaration of a Site Area Emergency is warranted under the conditions speci6ed by this EAL. Escalation to a General Emergency would be via radioactivity release category 5.0.

PEG

Reference:

SS5.1 FC4.1 Basis Reference(s):

1. FR-C.1 "Response to Inadequate Core Cooling

2. Abnormal Operating Instruction 4.2.1, Loss Of Residual Heat Removal System 3-4

4 4'C

OSSI-92-402A-4-IP2 IP2 EAI. Techntcal Bases Document, Rev 0 3.0 Reactor Coolant System 3.2 Primary to Secondary Leakage 3.2.1 Unusual Event Unisolable release of secondary side to atmosphere from the affected steam generator(s) with primary to secondary leakage > 0.3 gpm in any steam generator Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses SG tube leaks indicative of a loss of containment, Unisolable secondary side releases to atmosphere include feed line or steam line breaks as well as stuck open safety or atmospheric relief valves that cannot be isolated once isolation has been directed by the EOPs. A steam generator which is required to be used for plant cooldown would also be covered under this EAL. For small leaks, not exceeding the normal charging capacity threshold in RCS leakage EAL 3.1.2, this EAL results in an Unusual Event. For larger leaks, RCS leakage EAL 3.2.2 would result in a Site Area Emergency. For SG tube ruptures which may involve multiple steam generators or unisolable secondary line breaks, SG tube rupture EAL 4.2.1 would also result in a Site Area Emergency.

PEG

Reference:

PC4.1 Basis Reference(s):

1. Technical Speci6cations, Amendment No. 152, paragraph 3.1.F, page 3.1.F-3 3-5

4 I la F;r

.Jr

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 3.0 Reactor Coolant System 3.2 Primary to Secondary Leakage 3.2.2 Site Area Emergency Unisolable release of secondary side to atmosphere from the a6'ected steam generator(s) with primary to secondary leakage exceeding capacity (> V5 gpm) of a single charging pump Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses SG tube leaks indicative of a loss of both RCS and containment barriers. Unisolable secondary side releases to atmosphere include feed line or steam line breaks as well as stuck open safety or atmospheric relief valves that cannot be isolated once isolation has been directed by the EOPs. A steam generator which is required to be used for plant cooldown would also be covered under this EAL. Primary to secondary leakage in excess of the capacity of one charging pump (>75 gpm) is based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS). 75 gpm is the minimum operability Qow rate for each charging pump. For primary to secondary leakage in excess of the capacity of a single charging pump in the absence of secondary to atmosphere release, an Alert would be declared based on EAL 3.1.2.

This EAL represents the loss of both RCS and containment barriers and therefore warrants declaration of a Site Area Emergency.

PEG

Reference:

PC4.1 + RCS2.2 Basis Reference(s):

1. E-3 "Steam Generator Tube Rupture"

2. Technical Specifications, Amendment No. 152, paragraph 3.1.F, page 3.1.F-3

3. Drawing no. 1980M 1085 4 PT-Q33 3-6

C'p

~ V

~j

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 3.0 Reactor Coolant System 3.2 Primary to Secondary Leakage 3.2.3 Site Area Emergency Unisolable release of secondary side to atmosphere from the affected steam generator(s) with primary to secondary leakage > 0.3 gpm in any steam generator AND

)

Coolant activity 300 pCi/cc of I-131 Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses SG tube leaks indicative of a loss of containment in conjunction with a loss of fuel cladding. Unisolable secondary side releases to atmosphere include feed line or steam line breaks as well as stuck open safety or atmospheric relief valves that cannot be isolated once isolation has been directed by the EOPs. A steam generator which is required to be used for plant cooldown would also be covered under this EAL.

A coolant activity > 300 p.Ci/cc of I-131 indicates a loss of fuel cladding. Refer to EAL N2.1.2 basis This condition represents a loss of both primary containment with the loss of fuel cladding and thus warrants declaration of a Site Area Emergency.

PEG

Reference:

PC4.1+ FC2.1 Basis Reference(s):

1. Technical Specifications Section 3.1.F 3-7

OSSI-92-402A-4-IP2 IP2 EAI. Technical Bases Document. Rev 0 3.0 Reactor Coolant System 3.3 RCS Subcooling 3.3.1 Alert RCS subcooling < SI initiation setpoint due to RCS leakage Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses conditions where leakage from the RCS is greater than available inventory control capacity such that a loss of subcooling has occurred. The loss of subcooling is the fundamental indication that the inventory control systems are inadequate in maintaining RCS pressure and inventory against the mass loss through the leak.

Loss of the RCS barrier warrants declaration of an Alert, PEG

Reference:

RCS2.1 Basis Reference(s):

l. E-O, Reactor Trip Or Safety Injection 3-8

fI If I~ I~r f%

t~

f~

OSSI-92-402A-4-IP2 IP2 EAI TechnIcal Bases Document, Rev 0 The containment structure is an atmospheric vapor containment system, It forms a fission product barrier designed to contain the radioactive fission products generated from any postulated accident so as to preclude exceeding ofFsite exposure limits.

The containment structure is a low leakage system housing the reactor vessel, the reactor coolant piping, steam generators and other branch connections of the reactor primary system. The containment is equipped with isolation valves for systems which penetrate the containment boundary.

These valves automatically actuate to isolate systems under emergency conditions.

There are three containment parameters which are indicative of conditions which may pose a threat to containment integrity or indicate degradation of RCS or reactor fuel clad integrity.

~ i I Abnormally high containment pressure or failure of containment cooling systems following a LOCA are indicative of potential losses of the containment barrier integrity.

The existence of an unisolable CI or CVI line break outside containment constitutes a loss of containment integrity as well as a loss of RCS boundary. Inconsistent containment response to a known LOCA is also indicative of containment loss in conjunction with RCS barrier breach. Should a loss of fuel cladding integrity occur under either of these conditions, the potential for release of large amounts of radioactive materials to the environment exists.

n r r 'h n 'Gtube ruptures in conjunction with a secondary system line break resulting in release to the environment constitutes losses of both RCS and containment integrity.

Primary to secondary leakage in excess of Technical Specifications in conjunction with fuel clad damage and secondary system leakage to the environment constitutes losses of fuel clad, RCS and containment integrity. This condition provides the potential for release of large amounts of radioactive materials to the environment.

4-1

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0

~ m i l n n r i n 'heexistenceofcombustiblegas

'concentrations in containment pose a severe threat to containment integrity and are indicative of severely degraded reactor core and RCS conditions.

4-2

4 P

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 4.0 Containment 4.1 Containment Integrity Status 4.1.1 Unusual Event Both doors open on a VC airlock for > 4 hrs.

OR Inability to close containment pressure relief or purge valves which results in a radiological release pathway to the environment for > 4 hrs.

Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses an indication that unambiguously indicates loss of the containment barrier under conditions when containment integrity is required.

It is important to note however, that loss of containment due to both airlock doors being open is event dependent. Upon recognition, shift personnel would rapidly respond in an attempt to reestablish containment integrity. Ifthe doors cannot be reclosed, any loss of the RCS barrier that occurs with the doors open would appear as an inconsistent LOCA response. Therefore, this event is not used as a definitive indicator of loss of the primary containment barrier for purposes of defining higher classification EALs. Rather it is left to the Emergency Director's judgment whether such a loss has occurred.

PEG

Reference:

PC7.1 Basis Reference(s):

Tech Spec. 3.6.A.1.D and 3.6.A,3" 4-3

~E t

gl 4

OSSI-92-402A-4-IP2 IP2 EAI. Technical Bases Document, Rev 0 4.0 'ontauunent 4.1 Containment Integrity Status 4.12 Site Area Emergency Rapid uncontrolled decrease in containment pressure following initial increase due to RCS failure OR Loss of primary coolant inside containment with contaiznnent pressure or sump level response not consistent with LOCA conditions Mode Applicability:

Power operation, hot shutdown Basis:

Rapid unexplained loss of pressure (i. e., not attributable to contaixunent spray or Fan Cooling Units or condensation efFects) following an initial pressure increase indicates a loss of both RCS and containment integrity.

Containment pressure and sump levels should increase as a result of the mass and energy release into containment from a LOCA. Thus, sump level or pressure not increasing indicates containment bypass (V-sequence) and a loss of containment integrity.

This EAL indicates loss of both RCS and containment and therefore warrants declaration of a Site Area Emergency.

PEG

Reference:

PC2.1 PC2.2 Basis Reference(s):

None 4-4

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 4.0 Containment 4.1 Containment Integrity Status 4.1.3 Site Area Emergency Either:

Any Phase "A" or Phase "B" or containment ventilation isolation valve(s) not closed when required following confirmed LOCA OR Inability to isolate any primary system discharging outside containment AND Radiological release to the environment exists as a result Mode Applicability:

Power operation, hot shutdown Basis:

This EAL is intended to address incomplete containment isolation that allows direct release to the environment, It represents a loss of both the RCS and containment barrier and therefore warrants declaration of a Site Area Emergency.

Failure of Phase "A" or Phase "B" or containment ventilation isolation valves to isolate is intended to address incomplete containment isolation that allows direct release to the environment. It represents a loss of both the RCS and containment barrier.

"Inability to isolate any primary system discharging outside containment" is intended to address other primary systems, either direct or indirect, which the inability to isolate indicate loss of both RCS and containment.

PEG

Reference:

PC3.1 Basis Reference(s):

1. Technical Specifications 3.6.A.1.1 and 3.6.A.1.A 4-5

ff

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OSSI-92-402A-4-IP2 IP2 EAI. Technical Bases Document, Rev 0 4.0 Containment 4.1 Containment Integrity Status 4.1.4 General Emergency Con6rmed phase "B" isolation signal with less than minimum containment cooling safeguards equipment operating, Table 4.3 AND Any indicators of fuel clad loss, Table 4.1 Table 4.3 Minimum Containment Coolin Safe ards E ui ment Fan Cooler Units 0 eratin S ra Pum sRe uired

<3 3

5 Table 4.1 Fuel Clad Loss Indicators

1. Coolant activity > 300 pCi/cc of I-131

2. Containment radiation monitor R-25/R-26 reading >17 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

This EAL represents a potential loss of containment in conjunction with losses of both RCS and fuel clad.

A potential loss of containment is considered to exist in that a containment heat removal/depressurization system (e. g,, containment sprays, Fan Cooler Units, but not including containment venting strategies) is either lost or performing in a degraded manner, as indicated by containment pressure greater than the setpoint at which the equipment was supposed to have actuated.

RCS is also assumed to be lost in this condition due to the high containment pressure.

4-6

gl OSSI-92-402A-4-IP2 IP2 EAL TechnIcal Bases Document. Rev 0 Table 4.1 presents fuel clad loss indicators which represent 2 - 5% clad failures. Refer to EAL ¹'s 2.1.2 and 2.2.2 for bases of these indicators, PEG

Reference:

PC2.5+ FC2.1, FC5.1 Basis Reference(s):

1. Updated FSAR, Chapter 5, page 5.1-16/17, para. 3.

2. CCF Design Basis Document (DBD)

3. Design Basis Document, "Containment Spray System" 4 EOP E-O, Reactor Trip Or Safety Injection, for Phase "A" and "B" containment pressure signals

5. Technical Speci6cations 3.6.B-2 4-7

4

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7, $

I

OSSI-92-402A-4-IP2 IP2 EAL TechnIcal Bases Document, Rev 0 4.0 Containment 4.1 Containment Integrity Status 4.1.5 General Emergency Either:

Rapid uncontrolled decrease in containment pressure following initial increase OR Loss of primary coolant inside containment with containment pressure or sump level response not consistent with LOCA conditions AND Any indicators of fuel clad damage, Table 4.2 Table 4.2 Fuel Clad Dama e Indicators

1. ORANGE or RED path in F-0.2, CORE COOLING

2. RED path in F-0.3, HEAT SINK AND Heat sink is required

3. Coolant activity > 300 pCi/cc of I-131

4. Containment radiation monitor R-25/R-26 reading >17 Ehr Mode Applicability:

Power operation, hot shutdown Basis:

This EAL indicates loss of both RCS and containment with loss or potential loss of the fuel cladding and therefore warrants declaration of a General Emergency.

Rapid unexplained loss of pressure (i. e., not attributable to containment spray or Fan Cooling Units o'r condensation effects) following an initial pressure increase indicates a loss of both RCS and containment integrity.

Containment pressure and sump levels should increase as a result of the mass and energy release into containment from a LOCA. Thus, sump level or pressure not increasing indicates containment bypass (V-sequence) and a loss of containment integrity.

Table 4.2 presents fuel clad loss and potential loss indicators:

~ ORANGE path in F-0.2, Core Cooling: Refer to EAL ¹1.1.1 basis

~ RED path in F-0.3, Heat Sink: Refer to EAL ¹1.2.1 basis Coolant activity > 300 pCi/cc of I-131: Refer to EAL ¹2.1.2 basis 4-8

OSSI-92-402A-4-IP2 IP2 EAI- Technical Bases Document. Rev 0

~ Containment rad monitor reading > 17 R/hr: Refer to EAL N2.2.2 basis PEG

Reference:

PC2.1/PC2.2+ FC1.2, FC1.3, FC2.1, FC3.2, FC4.1, and FC5.1 Basis Reference(s):

1. F-0.2, Rev. 2, CORE COOLING

2. F-0.3, Rev.2, HEAT SINK 4-9

OSSI-92-402A-4-IP2 IP2 EAI. Technfcal Bases Document, Rev 0 4.0 Contauunent 4.1 Containment Integrity Status 4.1.6 General Emergency Either:,

Any Phase "A" or Phase "B" or containment ventilation isolation valve(s) not closed when required following conQrmed LOCA OR Inability to isolate any primary system discharging outside containment AND Radiological release to the environment exists as a result AND Any indicators of fuel clad damage, Table 4.2 Table 4.2 Fuel Clad Dama e Indicators

1. ORANGE or RED path in F-0.2, CORE COOLING

2. RED path in F-0.3, HEAT SINK AND Heat sink is required

3. Coolant activity > 300 pCi/cc of I-131

4. Containment radiation monitor R-25/R-26 reading >17 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

This EAL indicates loss of both RCS and containment with loss or potential loss of the fuel cladding and therefore warrants declaration of a General E< merge ncy.

F<ailure of Phase "A" or Phase "B" or CVI valves to isolate is intended to address incomplete containment isolation that allows direct release to the environment. It represents a loss of both the RCS and containment barrier.

"Inability to isolate any primary system discharging outside containment" is intended to address other primary systems, either direct or indirect, which the inability to isolate indicate loss of both RCS and containment.

Table 4.2 presents fuel clad loss and potential loss indicators:

~ ORANGE path in F-0.2, Core Cooling: Refer to EAL ¹1.1.1 basis

~ RED path in F-0.3, Heat Sink: Refer to EAL ¹1.2.1 basis 4-10

t

/

OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document, Rev 0 4.0 Containment 4.1 Containment Integrity Status 4.1.6 General Emergency Either:

Any Phase "A" or Phase "B" or containment ventilation isolation valve(s) not closed when required following confirmed LOCA OR Inability to isolate any primary system discharging outside containment AND Direct radiological release pathway to the environment exists as a result AND Any indicators of fuel clad damage, Table 4.2 Table 4.2 Fuel Clad Dama e Indicators

1. ORANGE or RED path in F-0.2, CORE COOLING

2. RED path in F-0.3, HEAT SINK AND Heat sink is required (RCS pressure > intact SG)

3. Coolant activity > 300 p.Ci/cc of I-131

4. Containment radiation monitor R-25/R-26 reading >17 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

This EAL indicates loss of both RCS and containment with loss or potential loss of the fuel cladding and therefore warrants declaration of a General Emergency.

Failure of Phase "A" or Phase "B" or CVI valves to isolate is intended to address incomplete containment isolation that allows direct release to the environment. It represents a loss of both the RCS and containment barrier.

"Inabilityto isolate any primary system discharging outside containment" is intended to address other primary systems, either direct or indirect, which the inability to isolate indicate loss of both RCS and containment.

Table 4.2 presents fuel clad loss and potential loss indicators:

~ ORANGE path in F-0.2, Core Cooling: Refer to EAL ¹1.1.1 basis

~ RED path in F-0.3, Heat Sink: Refer to EAL ¹1.2.1 basis 4-10

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0

~ Coolant activity > 300 pCi/cc of I-131: Refer to EAL 42.1.2 basis

~ Containment rad monitor reading > 17 R/hr: Refer to EAL P2.2.2 basis PEG

Reference:

PC3.1+ FC1.2, FC1.3, FC2.1, FC3.2, FC4.1, and FC5.1 Basis Reference(s):

Tour of Simulator Control Room, Discussion with Training Instructor R. Burns

2. Technical Specification 3.6.A.1.A and 3.6.A.1.B

3. F-0.2, Rev. 2, CORE COOLING 4 F-0.3, Rev.2, HEAT SINK 4-11

P 7

4g

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 4.0 Containment 4.2 SG Tube Rupture w/ Secondary Release 4.2.1 Site Area Emergency Unisolated faulted (outside VC) ruptured steam generator Mode Applicability:

Power operation, hot shutdown Basis:

This EAL is intended to address the full spectrum of Steam Generator (SG) tube rupture events in conjunction with a loss of containment due to a significant secondary line break. This EAL addresses ruptured SG(s) with an unisolable secondary line break corresponding to the loss of 2 of 3 fission product barriers (RCS barrier and containment barrier). This allows the direct release of radioactive fission and activation products to the environment. Resultant offsite dose rates are a function of many variables.

Examples include: coolant activity, actual leak rate, SG carry over, iodine partitioning, and meteorology.

The indications utilized should be consistent with the diagnostic activities of the emergency operating procedures (EOPs), ifavailable. This should include indication of reduction in primary coolant inventory, increased secondary radiation levels, and an uncontrolled or complete depressurization of the ruptured SG. Secondary radiation increases should be observed via radiation monitoring of condenser air ejector discharge, SG blowdown, main steam, and/or SG sampling system. Determination of the "uncontrolled" depressurization of the ruptured SG should be based on indication that the pressure decrease in the ruptured steam generator is not a function of operator action. This should prevent declaration based on a depressurization that results from an EOP induced cooldown of the RCS that does not involve the prolonged release of contaminated secondary coolant from the affected SG to the environment. This EAL encompasses steam breaks, feed breaks, and stuck open safety or relief valves.

PEG

Reference:

RCS3.1 4-12

OSSI-92-402A-4-IP2 IP2 EAL Technfcal Bases Document, Rev 0 Basis Reference(s):

1. E-3 "Steam Generator Tube Rupture"

2. AOI 1.2, Steam Generator Tube Leak

3. E-O, Reactor Trip Or Safety Injection 4-13

'Xy "I

lp, ~

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 4.0 Containment 4.2 SG Tube Rupture w/ Secondary Release 4.2.2 General Emergency Unisolated faulted (outside VC) ruptured steam generator AND Any indicators of fuel clad damage, Table 4.2 Table 4.2 Fuel Clad Dama e Indicators

1. ORANGE or RED path in F-0.2, CORE COOLING

2. RED path in F-0.3, HEAT SINK AND Heat sink is required

3. Coolant activity > 300 p,Ci/cc of I-131

4. Containment radiation monitor R-25/R-26 reading >17 R/hr Mode Applicability:

Power operation, hot shutdown Basis:

This EAL is intended to address the full spectrum of Steam Generator (SG) tube rupture events in conjunction with a loss of containment due to a significant secondary line break with actual or potential loss of the fuel clad integrity. This EAL addresses ruptured SG(s) with an unisolable secondary line break corresponding to the loss of 2 of 3 fission product barriers (RCS barrier and containment barrier) with the actual or potential loss of the third (fuel cladding). This allows the direct release of radioactive fission and activation products to the environment, Resultant offsite dose rates are a function of many variables. Examples include: coolant activity, actual leak rate, SG carry over, iodine partitioning, and meteorology.

The indications utilized should be consistent with the diagnostic activities of the emergency operating procedures (EOPs), ifavailable. This should include indication of reduction in primary coolant inventory, increased secondary radiation levels, and an uncontrolled or complete depressurization of the ruptured SG. Secondary radiation increases should be observed via radiation monitoring of condenser air ejector discharge, SG blowdown, main steam, and/or SG sampling system. Determination of the "uncontrolled" depressurization of the ruptured SG should be based on indication that the pressure decrease in the ruptured steam generator is not a function of operator action. This should prevent declaration based on a depressurization that results from an EOP induced cooldown of the RCS that does not involve 4-14

I l

OSSI-92-402A-4-IP2 IP2 EAL Technfcal Bases Document. Rev 0 the prolonged release of contaminated secondary coolant from the affected SG to the environment. This EAL encompasses steam breaks, feed breaks, and stuck open safety or relief valves.

Table 4.2 presents fuel clad loss and potential loss indicators:

~ ORANGE path in F-0.2, Core Cooling: Refer to EAL ¹1.1.1 basis

~ RED path in F-0.3, Heat Sink: Refer to EAL ¹1.2.1 basis

~ Coolant activity > 300 pCi/cc of I-131: Refer to EAL ¹2.1.2 basis

~ Containment rad monitor reading > 17 R/hr: Refer to EAL ¹2.2.2 basis This condition represents a loss of both RCS and primary containment with the loss or potential loss of fuel cladding and thus warrants declaration of a General Emergency.

PEG

Reference:

RCS 3.1+ FC1.2, FC1.3, FC2.1, FC3.2, FC4.1, and FC5.1 Basis Reference(s):

1. Technical Speci6cations Section 3.1.F

2. F-0.2, Rev. 2, CORE COOLING

3. F-0.3, Rev.2, HEAT SINK 4-15

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 4.0 Containment 4.3 Combustible Gas Concentrations 4.3.1 General Emergency 2 4% hydrogen concentration in containment Mode Applicability:

Power operation, hot shutdown Basis:

Existence of an explosive mixture (4 % hydrogen) means a hydrogen and oxygen concentration of at least the lower deflagration limit curve exists.

When hydrogen and oxygen concentrations reach or exceed the deflagration limits, imminent loss of the containment barrier exists. To generate such levels of combustible gas, loss of the fuel clad and RCS barriers must have occurred.

This EAL represents loss of both fuel clad and RCS with the potential loss. of containment and therefore warrants declaration of a General Emergency.

PEG

Reference:

PC2.4 Basis Reference(s):

1. SOP 10.9.1, "Hydrogen Recombiners" 4-16

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 E

Many EALs are based on actual or potential degradation of fission product barriers because of the increased potential for offsite radioactivity release.

Degradation of fission product barriers though, is not always apparent via non-radiological symptoms. Therefore, direct indication of increased radiological efQuents or area radiation levels are appropriate symptoms for emergency classification.

At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions may result which require offsite protective actions. Increased area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.

There are two basic indications of radioactivity release rates and one for area radiation levels which warrant emergency classifications.

Di tiki ti fK t Chai systems provides a rapid assessment mechanism to determine releases

't 'g in excess of classifiable limits.

~ D r n n r nm 1M r 'rojected offsite doses (based on efQuent monitor readings) or actual offsite field measurements indicating doses or dose rates above classifiable limits.

~ r excess i

L: Sustained general area radiation levels in of those indicating loss of control of radioactive materials or those levels which may preclude access to vital plant areas also warrant emergency classification.

5-1

(1 Il

OSSI-92-402A-4-IP2 IP2 EAI- Technical Bases Document, Rev 0 5.0 Radioactivity Release / Area Radiation 5.1 EfQuent Monitors 5.1.1 Unusual Event A valid reading on any monitors Table 5.1 column "NUE" for > 60 min.

Table 5.1 EfHuent Monitor Classification Thresholds Monitor GE SAE Alert R-27 53 pCi/cc 5.3 pCi/cc 5.3E-1 pCi/cc 2,3E-3 pCi/cc R-44 53 pCi/cc 5.3 pCi/cc 5.3E-l pCi/cc 2.3E-3 pCi/cc R-54 N/A N/A 2.5E-1 pCi/cc 2.5E-3 pCi/cc R-49 N/A N/A 2.7E-2 pCi/cc 2.7E4 pCi/cc Mode Applicability:

Basis:

The "value shown" for each monitor is two times the calculated Technical Specification release rates as specified in the IP-1007.

Valid means that a radiation monitor reading has been confirmed by operators to be correct, Unplanned releases in excess of two times the site technical specifications that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the Unusual Event emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes. Therefore, it is not intended that the release be averaged over 60 minutes. For example, a release of 4 times T/S for 30 minutes does not exceed this initiating condition. Further, the Emergency Director should not wait until 60 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or willlikely exceed 60 minutes.

Monitor indications are calculated on the basis of the methodology of IP-1007.

Annual average meteorology is used.

Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

5-2

I" OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 PEG

Reference:

AU1.1 Basis Reference(s):

System Description No. 12, Radiation Monitoring And Protections System

2. IP-1007 "Determination of the Magnitude of Release and Exposure Rate"

3. Technical Specifications Section 3.9 4 Letter from D. Smith to R. Burns 5-3

t c

OSSI-92-402A-4-IF2 IP2 EAL Technical Bases Document, Rev 0 5.0 Radioactivity Release /Area Radiation 5.1 Eff1uent Monitors 5.1.2 Alert A valid reading on any monitors Table 5.1 column "Alert" for > 15 min.

Table 5.1 Effluent Monitor Classification Thresholds Monitor GE R-27 53 pCi/cc 5.3 pCi/cc 5.3E-1 pCi/cc 2.3E-3 pCi/cc RA4 53 pCi/cc 5.3 pCi/cc 5.3E-1 pCi/cc 2.3E-3 pCi/cc R-54 N/A N/A 2.5E-1 pCi/cc 2.5E-3 pCi/cc R-49 N/A N/A 2.7E-2 pCi/cc 2.7E-4 pCi/cc Mode Applicability:

Basis:

This event escalates from the Unusual Event by escalating the magnitude of the release by a factor of 100. Prorating the 500 mR/yr criterion for both time (8766 hr/yr) and the 200 multiplier, the associated site boundary dose rate would be 10 mR/hr. The required release duration was reduced to 15 minutes in recognition of the increased severity.

Monitor indications are calculated on the basis of the methodology of IP-1007, "Determination of the Magnitude of Release and Exposure Rate". Annual average meteorology is used.

As previously stated, the 10 mR/hr value is based on a proration of 200 times the 500 mR/yr basis of the 10CFR20 non-occupational MPC limits, rounded down to 10 mR/hr. The values for the gaseous effluent radiation monitors are based upon not exceeding 10 mR/hr at the site boundary as a result of the release.

Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

5-4

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 PEG

Reference:

AA1.1 Basis Reference(s):

System Description No. 12, Radiation Monitoring And Protections System

2. IP-1007, "Determination of the Magnitude of Release and Exposure Rate"

3. Technical Specifications Section 3.9 4 Letter from D. Smith to R. Burns 5-5

'L 6

Ol

OSSI-92-402A-4-IP2 IP2 EAI. Technical Bases Document. Rev 0 5.0 Radioactivity Release / Area Radiation 5.1 Effluent Monitors 5.1.3 Site Area Emergency A valid reading on any monitors Table 5.1 column "SAE" for > 15 min.

Table 5.1 EfQuent Monitor Classification Thresholds Monitor GE R-27 53 p,Ci/cc 5.3 p,Ci/cc 5.3E-1 pCi/cc 2.3E-3 p,Ci/cc RM 53 p.Ci/cc 5.3 p,Ci/cc 5.3E-1 pCi/cc 2.3E-3 p.Ci/cc R-54. N/A N/A 2.5E-1 pCi/cc 2.5E-3 p,Ci/cc R-49 N/A N/A 2.7E-2 pCi/cc 2.7E-4 p,Ci/cc Mode Applicability:

Basis:

The values shown were determined utilizing IP-1007, "Determination of the Magnitude of Release and Exposure Rate" based upon a 100 mR whole body exposure. These values where determined using annual average, meteorology.

The 100 mR integrated dose is based on the proposed 10CFR20 annual average population exposure. This value also provides a desirable gradient (one order of magnitude) between the Alert, Site Area Emergency, and General Emergency classes. It is deemed that exposures less than this limit are not consistent with the Site Area Emergency class description. The 500 mR integrated child thyroid dose was established in consideration of the 1:5 ratio of the EPA Protective Action Guidelines for whole body thyroid.

Integrated doses are generally not monitored in real-time. In establishing the emergency action levels, a duration of one hour is assumed, based on a site boundary dose of 100 mH/hour whole body or 500 mH/hour child thyroid, whichever is more limiting (depends on source term assumptions).

Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

5-6

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 PEG

Reference:

AS1.1 Basis Reference(s):

System Description No. 12, Radiation Monitoring And Protections System

2. IP-1007, "Determination of the Magnitude of Release and Exposure Rate"

3. Technical Specifications Section 3.9

4. Letter from D. Smith to R. Burns 5-7

I J}

'4.7

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 5.0 Radioactivity Release / Area Radiation 5.1 Effluent Monitors 5.1.4 General Emergency A valid reading on any monitors Table 5.1 column "GE" for ) 15 min.

Table 5.1 EfHuent Monitor Classification Thresholds Monitor GE R-27 53 p,Ci/cc 5.3 p.Ci/cc 5.3E-l pCi/cc 2.3E-S p,Ci/cc R-44 53 p,Ci/cc 5.3 p,Ci/cc 5.3E-1 pCi/cc 2.3E-S p,Ci/cc R-54 N/A N/A 2.5E-1 pCi/cc 2.5E-3 p,Ci/cc R-49 N/A N/A 2.7E-2 pCi/cc 2.7E-4 p,Ci/cc Mode Applicability:

Basis:

The values shown were determined utilizing IP-1007, "Determination of the Magnitude of Release and Exposure Rate" based upon a 100 mR whole body exposure. These values where determined using annual average meteorology.

The 1000 mR whole body and the 5000 mR child thyroid integrated dose are based on the EPA protective action guidance which indicates that public protective actions are indicated ifthe dose exceeds 1 rem whole body or 5 rem child thyroid. This is consistent with the emergency class description for a General Emergency. This level constitutes the upper level of the desirable gradient for the Site Area Emergency.

Integrated doses are generally not monitored in real-time. In establishing the emergency action levels, a duration of one hour is assumed, based on a site boundary dose of 1000 mR/hour whole body or 5000 mR/hour child thyroid, whichever is more limiting (depends on source term assumptions).

Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

5-8

4~ ~

P;

OSSI-92-402A-4-IP2 IP2 EAL TechnIcal Bases Document. Rev 0 PEG

Reference:

1 AG1.1 Basis Reference(s):

System Description No. 12, Radiation Monitoring And Protections System

2. IP-1007, "Determination of the Magnitude of Release and Exposure Rate"

3. Technical Specifications Section 3.9 4 Letter from D. Smith to R. Burns 5-9

+l J

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 5.0 Radioactivity Release / Area Radiation 5.2 Dose Projections/ Environmental Measurements/ Release Rates 5.2.1 Unusual Event Confirmed sample analyses for gaseous or liquid release rates in excess of 2 technical specifications limits for > 60 min.

I Mode Applicability:

Basis:

Unplanned releases in excess of two times the site technical specifications that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the Unusual Event emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes. Therefore, it is not intended that the release be averaged over 60 minutes. For example, a release of 4 times T/S for 30 minutes does not exceed this initiating condition.

Further, the Emergency Director should not wait until 60 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or willlikely exceed 60 minutes PEG

Reference:

AU1.2 Basis Reference(s):

1. Technical Specifications Section 3.9 5-10

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OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document, Rev 0 5.0 Radioactivity Release /Area Radiation 5.2 Dose Projections/ Environmental Measurements/ Release Rates 5.2.2 Alert Confirmed sample analyses for gaseous or liquid release rates in excess of 200 x technical specifications limits for > 15 min.

Mode Applicability:

Basis:

Confirmed sample analyses in excess of two hundred times the site technical specifications that continue for 15 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. This event escalates from the Unusual Event by increasing the magnitude of the release by a factor of 100 over the Unusual Event level (i. e.,

200 times Technical Specifications). Prorating the 500 mR/yr basis of the 10CFR20 non-occupational MPC limits for both time (8766 hr/yr) and the 200 multiplier, the associated site boundary dose rate would be 10 mR/hr. The required release duration was reduced to 15 minutes in recognition of the increased severity.

PEG

Reference:

AA1.2 Basis Reference(s):

1. Technical Specifications Section 3.9 5-11

1 Qg 4

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document. Rev 0 5.0 Radioactivity Release / Area Radiation 5.2 Dose Projections/ Environmental Measurements/ Release Rates 5.2.3 Alert Dose projections or field surveys which indicate doses / dose rates in excess of Table 5.2 column "Alert" at the site boundary or beyond.

Table 5,2 Dose Pro ection/ Env. Measurement Classification Thresholds GE TEDE 1000 mR 100 mR 10 mR CDE Thyroid 5000 mR 500 mR N/A TEDE rate 1000 mH/hr 100 mH/hr 10 ma/hr CDE Thyroid rate 5000 mIMn 500 mR/hr N/A Mode Applicability:

Basis:

Ofrsite integrated doses in excess of 10 mR TEDE or dose rates in excess of 10 mR/hr TEDE represent an uncontrolled situation and hence, a potential degradation in the level of safety. This event escalates from the Unusual Event by increasing the magnitude of the release by a factor of 100 over the Unusual Event level (i. e., 200 times Technical Specifications). Prorating the, 500 mR/yr basis of 10CFR20 for both time (8766 hr/yr) and the 200 multiplier, the associated site boundary dose rate would be 10 mR/hr.

As previously stated, the 10 mR/hr value is based on a proration of 200 times the 500 mR/yr basis of 10CFR20, rounded down to 10 mR/hr.

I 5-12

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document. Rev 0 PEG

Reference:

AA1.2 Basis Reference(s):

1. IP-1007, "Determination of the Magnitude of Release and Exposure Rate"

2. Technical Specifications Section 3.9 5-13

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OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 5.0 Radioactivity Release / Area Radiation 5.2 Dose Projections/ Environmental Measurements/ Release Rates 5.2.4 Site Area Emergency Dose projections or field surveys which indicate doses / dose rates in excess of Table 5.2 column "SAE" at the site boundary or beyond.

Table 5.2 Dose Pro ection / Env. Measurement Classification Thresholds GE TEDE 1000 mR 100 mR 10 mR CDE Thyroid 5000 mR 500 mR N/A TEDE rate 1000 mR/hr 100 mR/hr 10 mR/hr CDE Thyroid rate 5000 mH/hr 500 mR/hr N/A Mode Applicability:

Ba'sis:

The 100 mR integrated TEDE dose in this EAL is based on the proposed 10CFR20 annual average population exposure. This value also provides a desirable gradient (one order of magnitude) between the Alert, Site Area Emergency, and General Emergency classes. It is deemed that exposures less than this limit are not consistent with the Site Area Emergency class description. The 500 mR integrated CDE thyroid dose was established in consideration of the 1:5 ratio of the EPA Protective Action Guidelines for whole body thyroid. In establishing the dose rate emergency action levels, a duration of one hour is assumed, Therefore, the dose rate EALs are based on a site boundary dose rate of 100 mH/hr TEDE or 500 mR/hr CDE thyroid, whichever is more limiting.

PEG

Reference:

AS1.3 AS1.4 5-14

OSSI-92-402A-4-IP2 IP2 EAI- Technfcal Bases Document, Rev 0 Basis Reference(s):

l. IP-1007, "Determination of the Magnitude of Release and Exposure Rate"

2. Technical Specifications Section 3.9 5-15

gf q OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 5.0 Radioactivity Release / Area Radiation 5.2 Dose Projections/ Environmental Measurements/ Release Rates 5.2.5 General Emergency Dose projections or field surveys which indicate doses / dose rates in excess of Table 5.2 column "GE" at the site boundary or beyond.

Table 5.2 Dose Pro ection / Env. Measurement Classification Thresholds GE Alert TEDE 1000 mR 100 mR 10 mR CDE Thyroid 5000 mR 500 mR N/A TEDE rate 1000 mH/hr 100 mH/hr 10 mH/hr CDE Thyroid rate 5000 mR/hr 500 mB/hr N/A Mode Applicability:

Basis:

The General Emergency values of Table 5.2 are based on the boundary dose resulting from an actual or imminent release of gaseous radioactivity that exceeds 1000 mR TEDE or 5000 mR CDE thyroid for the actual or projected duration of the release. The 1000 mR TEDE and the 5000 mR CDE thyroid integrated dose are based on the EPA protective action guidance which indicates that public protective actions are indicated ifthe dose exceeds 1 rem TEDE or 5 rem CDE thyroid. This is consistent with the emergency class description for a General Emergency. This level constitutes the upper level of the desirable gradient for the Site Area Emergency. Actual meteorology is specifically identified since it gives the most accurate dose assessment.

Actual meteorology (including forecasts) should be used whenever possible.

In establishing the dose rate emergency action levels, a duration of one hour is assumed. Therefore, the dose rate EALs are based on a site boundary dose rate of 1000 mR/hr TEDE or 5000 mH/hr CDE thyroid, whichever is more limiting.

5-16

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 PEG

Reference:

AG1.3 AG1.4 Basis Reference(s):

1. IP-1007, "Determination of the Magnitude of Release and Exposure Rate"

2. Technical Specifications Section 3.9 5-17

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OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 5.0 Radioactivity Release / Area Radiation 5.3 Area Radiation Levels 5.3.1 Unusual Event.

Any sustained direct ARM readings ) 100 x alarm or offscale hi resulting from an uncontrolled process Mode Applicability:

Basis:

Valid elevated area radiation levels usually have long lead times relative to the potential for radiological release beyond the site boundary, thus impact to public health and safety is very low.

This EAL addresses unplanned increases in radiation levels inside the plant.

These radiation levels represent a degradation in the control of radioactive material and a potential degradation in the level of safety of the plant. Area radiation levels above 100 times the alarm setpoint have been selected because they are readily identifiable on ARM instrumentation. Since ARM setpoints are nominally set one decade over normal levels, 100 times the alarm setpoint provides an appropriate threshold for emergency classification. For those ARMs whose upper range limit are less than 100 times the alarm setpoint, a value of offscale high is used. This EAL escalates to an Alert, ifthe increases impair the level of safe plant operation, PEG

Reference:

AU2.4 Basis Reference(s):

None 5-18

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OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 5.0 Radioactivity Release / Area Radiation 5.3 Area Radiation Levels 5.3.2 Alert Sustained area radiation levels > 15 mR/hr in either:

Control Room OR Central Alarm Station and Secondary Alarm Station Mode Applicability:

Basis:

This EAL addresses increased radiation levels that impede necessary access to operating stations requiring continuous occupancy to maintain safe plant operation or perform a safe plant shutdown. Areas requiring continuous occupancy include the Control Room, the central alarm station (CAS) and the secondary security alarm station (SAS). The security alarm stations are included in this EAL because of their importance to permitting access to areas required to assure safe plant operations.

The value of 15 mar is derived from the GDC 19 value of 5 rem in 30 days with adjustment for expected occupancy times. Although Section III.D.3 of NUREG-0737, "Clari6cation of TMIAction Plan Requirements", provides that the 15 mR/hr value can be averaged over the 30 days, the value is used here without averaging. A 30 day duration implies an event potentially more significant than an Alert.

It is the impaired ability to operate the plant that results in the actual or potential degradation of the level of safety of the plant. The cause or magnitude of the increase in radiation levels is not a concern of this EAL.

The Emergency Director must consider the source or cause of the increased radiation levels and determine ifany other EALs may be involved. For example, a dose rate of 15 mR/hr. in the Control Room may be a problem in itself, However, the increase may also be indicative of high dose rates in the containment due to a LOCA. In this latter case, a Site Area Emergency or a General Emergency may be indicated by other EAL categories.

5-19

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 This EAL is not intended to apply to anticipated temporary radiation increases due to planned events (e. g., radwaste container movement, depleted resin transfers, etc.).

PEG

Reference:

AA3.1 Basis Reference(s):

1. GDC 19

2. NUIKG-0737, "Clarification of TMI Action Plan Requirements", Section III.D.3 5-20

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4,

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 5.0 Radioactivity Release /Area Radiation 5.3 -Area Radiation Levels 5.3.3 Alert Sustained abnormal area radiation levels > 8 R/hr within any areas, Table 5.3 AND Access is required for safe operation or shutdown Table 5.3 Plant Areas

~ Condensate Storage Tank

~ RWST

~ Service Water Intake Structure

~ Service Water Valve Pit East

~ Fuel Storage Building

~ Primary AuxiliaryBuilding/Fan House

~ 480 Volt Switchgear Room (Control Building)

~ Cable Spreading Room/Electrical Tunnel

~ Diesel Generator Building/Fuel Tank Area

~ AuxiliaryFeedwater Pump Building

~ Battery Room (Control Building 33'" ele,)

Mode Applicability:

Basis:

This EAL addresses increased radiation levels in areas requiring infrequent access in order to maintain safe plant operation or perform a safe plant shutdown. Area radiation levels at or above 8 R/hr are indicative of radiation fields which may limit personnel access or adversely a6'ect equipment whose operation may be needed to assure adequate core cooling or shutdown the reactor. The basis of the value is described in NMPC memo File Code NMP31027 "Exposure Guidelines For Unusual/Accident Conditions". The areas selected are consistent with those listed in other EALs and represent those structures which house systems and equipment necessary for the safe operation and shutdown of the plant.

It is the impaired ability to operate the plant that results in the actual or potential degradation of the level of safety of the plant. The cause or magnitude of the increase in radiation levels is not a concern of this EAL.

The Emergency Director must consider the source or cause of the increased 5-21

gS OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 radiation levels and determine ifany other EAL may be involved. For example, a dose rate of 8 H/hr may be a problem in itself. However, the increase may also be indicative of high dose rates in the containment due to a LOCA. In this latter case, a Site Area Emergency or a General Emergency may be indicated by other EAL categories.

This EAL is not meant to apply to increases in the containment radiation monitors as these are events which are addressed in other EALs. Nor is it intended to apply to anticipated temporary radiation increases due to planned events (e. g., radwaste container movement, deplete resin transfers, etc.).

PEG

Reference:

AA3.2 Basis Reference(s):

1. Niagara Mohawk Power Corporation memo File Code NMP31027 "Exposure Guidelines For Unusual/Accident Conditions", Revision 1, 3/18/93 5-22

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 Loss of vital plant electrical power. can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity.

The events of this category have been grouped into the following two loss of electrical power types:

A P r 'his category includes losses of onsite and/or oFsite AC power sources including station blackout events.

f P r This category involves total losses of vital plant 125 vdc power sources.

6-1

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OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document, Rev 0 6.0 Electrical Failures 6.1 Loss of AC Power Sources 6.1.1 Unusual Event None of the following sources of offsite power available for > 15 min.:

~ Unit Auxiliarytransformer

~ Station Auxiliary transformer

~ 13.8 KV gas turbine transformer Mode Applicability:

Basis:

Prolonged loss of all ofFsite AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete loss of AC power (station blackout). Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

PEG

Reference:

SU1.1 Basis Reference(s):

1. Design Basis Document (DBD) for 480 V system

2. Oneline Diagram of IP-2 electrical distribution 6-2

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OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document. Rev 0 6.0 Electrical Failures 6.1 Loss of AC Power Sources 6.1.2 Alert Loss of AC power to all 480 volt busses (5A, 2A/3A, 6A) for > 15 min.

AND Inability to power required core cooling systems with alternate power sources for > 15 min.

Mode Applicability:

Cold Shutdown, Refueling Basis:

Loss of all AC power compromises all plant safety systems requiring electric power. This EAL is indicated by: loss of all offsite AND onsite AC power to buses 2A, 3A, 5A AND 6A for greater than 15 minutes as well as loss of alternate power sources such as Alternate Safe Shutdown or other temporary sources of power. When in cold shutdown or refueling mode the event can be classified as an Alert, because of the significantly reduced decay heat, lower temperature and pressure, increasing the time to restore one of the emergency busses, relative to that specified for the Site Area Emergency if EAL. Escalating to the Site Area Emergency, appropriate, is by Abnormal Rad Levels/Radiological Effluent, or Emergency Director Judgment ICs.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

PEG

Reference:

SA1.1 Basis Reference(s):

1. Design Basis Document (DBD) for 480 V system

2. Oneline Diagram of IP-2 electrical distribution

3. ECA-0.0, Loss Of All AC Power 6-3

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OSSI-92-402A-4-IP2 IP2 EAI Technfcal Bases Document, Rev 0 6.0 Electrical Failures 6.1 Loss of AC Power Sources 6.1.3 Alert Available emergency bus AC power sources reduced to only one of the following for > 15 min.:

~ 480V EDG 21

~ 480V EDG 22

~ 480V EDG 23

~ Unit Auxiliarytransformer

~ Station Auxiliarytransformer

~ 13.8 KV gas turbine transformer Mode Applicability:

Power operation, hot shutdown Basis:

The condition indicated by this EAL is the degradation of the offsite power with a concurrent failure of all but one emergency generator to supply power to its emergency bus. Another related condition could be the loss of all offsite power and loss of onsite emergency diesels with only one train of emergency busses being fed from the unit main generator, or the loss of onsite emergency diesels with only one train of emergency busses being fed &om offsite power. The subsequent loss of this single power source would escalate the event to a Site Area Emergency.

PEG

Reference:

SA5.1 Basis Reference(s):

1. Design Basis Document (DBD) for 480 V system

2. Oneline Diagram of IP-2 electrical distribution

3. ECA-0.0, Loss Of AllAC Power 6-4

4 OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 6.0 Electrical Failures 6.1 Loss of AC Power Sources 6.1.4 Site Area Emergency Loss of AC power to all 480 volt busses (5A, 2A/3A, 6A) for > 15 min.

AND Inability to power required core cooling systems with alternate power sources for > 15 min.

Mode Applicability:

Power operation, hot shutdown Basis:

Loss of all AC power compromises all plant safety systems requiring electric power. This EAL is indicated by: loss of all offsite AND onsite AC power to buses 2A/3A, 5A AND 6A for greater than 15 minutes as well as loss of alternate power sources such as Alternate Safe Shutdown or other temporary sources of power. Prolonged loss of all AC power will cause core uncovery and loss of containment integrity, thus this event can escalate to a General Emergency. The time duration should be selected to exclude transient or momentary power losses, but should not exceed 15 minutes.

PEG

Reference:

SS1.1 Basis Reference(s):

1. Design Basis Document (DBD) for 480 V system

2. Oneline Diagram of IP-2 electrical distribution

3. ECA-0.0, Loss Of AllAC Power 6-5

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OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document, Rev 0 6.0 Electrical Failures 6.1 Loss of AC Power Sources 6.1.5 General Emergency Loss of all emergency'bus AC power AND either:

Power cannot be restored to required core cooling systems in ~ 1 hr OR ORANGE or RED path on F-0.2, "CORE COOLING" Mode Applicability:

K Power operation, hot shutdown Basis:

Loss of all AC power compromises all plant safety systems requiring electric power. Prolonged loss of all AC power will lead to loss of fuel clad, RCS, and containment. Although this EAL may be viewed as redundant to the RPV Water Level EALs, its inclusion is necessary to better assure timely recognition and emergency response.

This EAL is specified to assure that in the unlikely event of prolonged station blackout, timely recognition of the seriousness of the event occurs and that declaration of a General Emergency occurs as early as is appropriate, based on a reasonable assessment of the event trajectory.

The likelihood of restoring at least one emergency bus should be based on a realistic appraisal of the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions.

In addition, under these conditions, fission product barrier monitoring capability may be degraded. Although it may be difficultto predict when power can be restored, the Emergency Director should declare a General Emergency based on two major considerations:

1. Are there any present indications that core cooling is already degraded to the point that Loss or Potential Loss of fission product barriers is imminent?

6-6

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~ 41

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document. Rev 0

2. Ifthere are no present indications of such core cooling degradation,

~

how likely is it that power can be restored in time to assure that a loss of two barriers with a potential loss of the third barrier can be prevented?

Thus, indication of continuing core cooling degradation must be based on fission product barrier monitoring with particular emphasis on Emergency Director judgment as it relates to imminent loss or potential loss of fission product barriers and degraded ability to monitor fission product barriers.

The time to restore AC power is based on site blackout coping analysis performed in conformance with 10CFR50.63 and Regulatory Guide 1.155, "Station Blackout", with appropriate allowance for offsite emergency response.

PEG

Reference:

SG1.1 Basis Reference(s):

1. F-0.2, "CORE COOLING,"

2. Design Basis Document (DBD) for 480 V system

3. Oneline Diagram of IP-2 electrical distribution

4. ECA-0.0, Loss Of AllAC Power

5. Letter IPN-92-0 Letter of 4/14/89 to NRC Mail Station PI-137, re Station Blackout Rule 10 CFR 50.63 6-7

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OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 6.0 Electrical Failures 6.2 Loss of DC Power Sources 6.2.1 Unusual Event

( 105 vdc bus voltage indications for > 15 min. on the switchable voltmeter for all of the following panels:

21

~ 22 23

~ 24 Mode Applicability:

Cold Shutdown, Refueling Basis:

The purpose of this EAL is to recognize a loss of DC power compromising the ability to monitor and control the removal of decay heat during cold shutdown or refueling operations. This EAL is intended to be anticipatory in as much as the operating crew may not have necessary indication and control of equipment needed to respond to the loss.

The bus voltage is based on the minimum bus voltage necessary for the operation of safety related equipment. This voltage value incorporates a margin of at least 15 minutes of operation before the onset of inability to operate loads.

PEG

Reference:

SU7.1 Basis Reference(s):

1. Design Basis Document (DBD) for 125 VDC System 6-8

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OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 6.0 Electrical Failures 6.2 Loss of DC Power Sources 6.2.2 Site Area Emergency

( 105 vdc bus voltage indications for ) 15 min. on the switchable voltmeter for all of the following panels:

~ 21 22 23

~ 24 Mode Applicability:

Power operation, hot shutdown Basis:

Loss of all DC power compromises ability to monitor and control plant safety functions. Prolonged loss of all DC power will cause core uncovering and loss of containment integrity when there is significant decay heat and sensible heat in the reactor system. Escalation to a General Emergency would occur by other EAL categories. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

The bus voltage is based on the minimum bus voltage necessary for the operation of safety related equipment. This voltage value incorporates a margin of at least 15 minutes of operation before the onset of inability to operate loads.

PEG

Reference:

SS3.1 Basis Reference(s):

1. Design Basis Document (DBD) for 125 VDC System

2. AOI 27.1.11, Rev. 2, LOSS OF 125VDC POWER 6-9

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OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 Numerous plant system related equipment failure events which warrant emergency classi6cation, based upon their potential to pose actual or potential threats to plant safety, have been identified in this category.

The events of this category have been grouped into the following event types:

'fi '

~ T hni l Only one EAL falls under this event type related to the failure of the plant to be brought to the required plant operating condition required by technical specifications.

1 'his category includes events which are indicative of losses of operability of safety systems such as ECCS, isolation functions, Control Room habitability or cold and hot shutdown capabilities.

Al rm m

' 'ertain events which degrade the plant operators ability to effectively assess plant conditions or communicate with essential personnel within or external to the plant warrant emergency classificatio. Under this event type are losses of annunciators and/or communication equipment.

7-1

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OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 7.0 Equipment Failures 7.1 Technical Specification Requirements 7.1.1 Unusual Event Plant is not brought to required operating mode within Technical Specifications LCO Action Statement Time.

Mode Applicability:

Power operation, hot shutdown Basis:

Limiting Conditions of Operation (LCOs) require the plant to be brought to a required shutdown mode when the Technical Specification required configuration cannot be restored. Depending on the circumstances, this may or may not be an emergency or precursor to a more severe condition. In any case, the initiation of plant shutdown required by the site Technical Specification requires a one hour report under 10CFR50.72 (b) non-emergency events. The plant is within its safety envelope when being shut down within the allowable action statement time in the Technical Specifications. An immediate Notification of an Unusual Event is required when the plant is not brought to the required operating mode within the allowable action statement time in the Technical Specifications. Declaration of an Unusual Event is based on the time at which the LCO-specified action statement time period elapses under the site Technical Specifications and is not related to how long a condition may have existed. Other required Technical Specification shutdowns that involve precursors to more serious events are addressed by other EALs.

PEG

Reference:

SU2.1 Basis Reference(s):

1. Technical Specifications, paragraph 3.0.1, page 3.1.A-1 7-2

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OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 7.0 Equipment Failures 7.2 System Failures or Control Room Evacuation 7.2.1 Unusual Event Report of main turbine failure requiring turbine trip resulting in:

Damage to turbine-generator seals causing a release of lubricating oil or hydrogen OR Casing penetration.

Mode Applicability:

Power Operations Basis:

This EAL is intended to address main turbine rotating component failures of suf6cient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Of major concern is the potential for significant leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs. It is not the intent of this EAL to classify minor operational leakage. Actual fires and flammable gas build up are appropriately classified through other EALs. This EAL is consistent with "the definition of an Unusual Event while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment.

PEG

Reference:

HU1.6 Basis Reference(s):

None 7-3

1 1

f4 I

OSSI-92-402A-4-IP2 IP2 EAI. Technical Bases Document, Rev 0 7.0 Equipment Failures 7.2 System Failures or Control Room Evacuation 7.2.2 Alert Turbine failure generated missiles which causes or potentially causes any required safety related system or structure to become inoperable Mode Applicability:

Power Operations, Hot Shutdown Basis:

This EAL addresses the threat to safety related equipment imposed by missiles generated by main turbine rotating component failures. The involved equipment includes; Service Water System, Condensate Storage Tank and piping, Refueling Water Storage Tank and piping, Shield wall area, P. A. B., Electrical penetration area, Diesel Generators, and Central Control Room. This EAL is consistent with the de6nition of an ALERT in that, if missiles have damaged or penetrated areas containing safety-related equipment, the potential exists for substantial degradation of the level of safety of the plant PEG

Reference:

HA1.6 Basis Reference(s):

1. AOI 26.4.2, Rev. 2, TURBINE MISSILE GENERATION, 12/18/90 7-4

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 7.0 Equipment Failures 7.2 System Failures or Control Room Evacuation 7.2.3 Alert Control Room evacuation Mode Applicability:

Basis:

With the Control Room evacuated, additional support, monitoring and direction through the Technical Support Center and/or other emergency operations center is necessary. Inability to establish plant control from outside the Control Room will escalate this event to a Site Area Emergency.

PEG

Reference:

HA5.1 Basis Reference(s):

l. AOI 27.1.9, Control Room Inaccessibility/Safe Shutdown Control 7-5

I, E(

OSSI-92-402A-4-IP2 IP2 EAI. Technical Bases Document, Rev 0 7.0 Equipment Failures 7.2 System Failures or Control Room Evacuation 7.2.4 Alert Reactor coolant temperature cannot be maintained ( 200 'F Mode Applicability:

Cold Shutdown, Refueling Basis:

This EAL addresses complete loss of functions required for core cooling during refueling and cold shutdown modes. Escalation to Site Area Emergency or General Emergency would be through other EALs.

A reactor coolant temperature increase that approaches or exceeds the cold shutdown technical specification limitwarrants declaration of an Alert irrespective of the availability of technical specification required functions to maintain cold shutdown. The concern of this EAL is the loss of ability to maintain the plant in cold shutdown which is defined by reactor coolant temperature and not the operability of equipment which supports removal of heat from the reactor.

PEG

Reference:

SA3.1 Basis Reference(s):

1. Technical Specifications Amendment 152, Table 3.1.A.1, pg. 3 of 4

2. Technical Specifications Figure 3.10-1 7-6

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OSSI-92-402A-4-IP2 IP2 EAI. Technical Bases Document. Rev 0 7.0 Equipment Failures 7.2 System Failures or Control Room Evacuation 7.2.5 Site Area Emergency Control Room evacuation AND Core cooling cannot be established per AOI 27.1.9, "Control Room Inaccessibility/Safe Shutdown" in 5 15 min.

Mode Applicability:

Basis:

This EAL indicates that expeditious transfer of safety systems has not occurred but fission product barrier damage may not yet be indicated. The time interval for transfer is based on analysis or assessments as to how quickly control must be reestablished without core uncovering and/or core damage.

In cold shutdown and refueling modes, operator concern is directed toward maintaining core cooling such as is discussed in Generic Letter 88-17, "Loss of Decay Heat Removal." In power operation, and hot shutdown modes, operator concern is primarily directed toward maintaining critical safety functions and thereby assuring fission product barrier integrity.

PEG

Reference:

HS2.1 Basis Reference(s):

1. AOI 27.1.9, "Control Room Inaccessibility/Safe Shutdown"

2. Generic Letter 88-17, "Loss of Decay Heat Removal."

7-7

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OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 7.0 Equipment Failures 7.3 Loss of Indications /Alarms /

Communication Capability 7.3.1 Unusual Event Unplanned loss of most (approx. 75%) annunciators or indications on Control

)

Room Panels for 15 min.

AND Increased surveillance is required for safe plant operation Mode Applicability:

Power operation, hot shutdown Basis:

This EAL recognizes the difficultyassociated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. Recognition of the availability of computer based indication equipment is considered.

"Unplanned" loss of annunciators or indicators excludes scheduled maintenance and testing activities.

It is not intended that plant personnel perform a detailed count of the instrumentation lost but the use ofjudgment by the Senior Watch Supervisor as the threshold for determining the severity of the plant conditions. This judgment is supported by the specific opinion of the Senior Watch Supervisor that additional operating personnel willbe required to provide increased monitoring of system operation to safely operate the plant.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies.

While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difEiculty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This willbe addressed by their specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss willbe reported via 10CFR50.72. Ifthe shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on EAL 7.1.1, Inability to Reach Required Shutdown Within Technical Specification Limits.

7-8

OSSI-92-402A-4-IP2 IP2 EAL TechnIcal Bases Document, Rev 0 Annunciators or indicators for this EAL must include those identified in the Abnormal Operating procedures, in the Emergency Operating Procedures, and in other EALs (e. g., area, process, and/or effluent rad monitors, etc.).

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Due to the limited number of safety systems in operation during cold shutdown, refueling, and defueled modes, this EAL is not applicable during these modes of operation.

This Unusual Event will be escalated to an Alert ifa transient is in progress during the loss of annunciation or indication.

PEG

Reference:

SU3.1 Basis Reference(s):

Simulator Walkdown 7-9

Zp

• t Cga

QSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 7.0 Equipment Failures 7.3 Loss of Indications /Alarms /

Communication Capability 7.3.2 Unusual Event Loss of all communications capability affecting the ability to either:

Perform routine operations OR Notify offsite agencies or personnel Mode Applicability:

Basis:

The purpose of this EAL is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate problems with offsite authorities. The loss of offsite communications ability is expected to be significantly more comprehensive than the condition addressed by 10CFR50.72.

The onsite communications loss must encompass the loss of all means of routine communications (i. e., phones, sound powered phone systems, page party system, and radios/walkie talkies).

The offsite communications loss must encompass the loss of all means of communications with offsite authorities. This should include ENS, Bell lines, FAX transmissions, and dedicated phone systems. This EAL is intended to be used only when extraordinary means are being utilized to make communications possible (relaying of information from radio transmissions, individuals being sent to offsite locations, etc.).

PEG

Reference:

SU6.1 Basis Reference(s):

None 7-10

c *

~ P Qj,l P>>

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 7.0 Equipment Failures 7.3 Loss of Indications /Alarms /

Communication Capability 7.3.3 Alert Unplanned loss of most (approx, 75%) annunciators or indications on Control Room Panels for > 15 min.

AND Increased surveillance is required for safe plant operation AND either:

A plant transient in progress OR PROTEUS and SAS are unavailable Mode Applicability:

Power operation, hot shutdown Basis:

This EAL recognizes the difBculty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a transient. Recognition of the availability of computer based indication equipment is considered (PROTEUS, SAS, etc.).

"Unplanned" loss of annunciators or indicators does not include scheduled maintenance and testing activities.

It is not intended that plant personnel perform a detailed count of the instrumentation lost but the use ofjudgment by the Senior Watch Supervisor as the threshold for determining the severity of the plant conditions. This judgment is supported by the specific opinion of the Senior Watch Supervisor that additional operating personnel willbe required to provide increased monitoring of system operation to safely operate the plant.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies.

While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficultyassociated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This willbe addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss willbe reported via 10CFR50.72.

7-11

I Q

'44

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 Annunciators or indicators for this EAL includes those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e. g., area, process, and/or efHuent rad monitors, etc.).

"Significant transient" includes response to automatic or manually initiated functions such as trips, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10% or greater.

Ifboth a major portion of the annunciation system and all computer monitoring are unavailable to the extent that the additional operating personnel are required to monitor indications, the Alert is required.

Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes, no EAL is indicated during these modes of operation.

This Alert will be escalated to a Site Area Emergency ifthe operating crew cannot monitor the transient in progress.

PEG

Reference:

SA4.1 Basis Reference(s):

Simulator walkdown 7-12

I kj

'4j 4

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 7.0 Equipment Failures 7.3 Loss of Indications /Alarms /

Communication Capability 7.3.4 Site Area Emergency Loss of most (approx. 75%) annunciators or indications on Control Room Panels AND Complete loss of ability to monitor all critical safety function status AND A plant transient in progress Mode Applicability:

Power operation, hot shutdown Basis:

This EAL recognizes the inability of the Control Room staff to monitor the plant response to a transient. A Site Area Emergency is considered to exist if the Control Room staff cannot monitor safety functions needed for protection of the public.

Annunciators for this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the CSFST's and Emergency Operating Procedures, and in other EALs (e. g., rad monitors, etc.).

"Significant transient" includes response to automatic or manually initiated functions such as scrams, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10% or greater.

Indications needed to monitor critical safety functions necessary for protection of the public must include Control Room indications, computer generated indications and dedicated annunciation capability. The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled and in a eoolable geometry, to remove heat from the core, to maintain the reactor coolant system intact, and to maintain containment intact.

"Planned" actions are excluded from the EAL since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

7-13

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 PEG

Reference:

SS6.z Basis Reference(s):

None 7-14

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 Hazards are those non-plant system related events which can directly or indirectly impact plant operation or reactor plant and personnel safety, The events of this category have been grouped into the following types:

Etl tlt y' d tt '* d ty tt yt into the Protected Area as well as bomb threats and sabotage attempts.

Also addressed are actual security compromises threatening loss of physical control of the plant.

EM~1 'ires can pose significant hazards to personnel and reactor safety. Appropriate for classification are fires within the site Protected Area or which may aQect operability of vital equipment.

~M- E M - d t tt - t Ely occurring events which can cause damage to plant facilities such as aircraR crashes, missile impacts, toxic or flammable gas leaks or explosions from whatever source.

E t q t ',~tqd l which have potential to cause damage to plarit structures or equipment d

significant enough to threaten personnel or plant safety.

8-1

Q, kd

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 8.0 Hazards 8.1 Security Threats 8.1.1 Unusual Event Bomb device or other indication of attempted sabotage discovered within plant Protected Area.

Mode Applicability:

Basis:

This EAL is based on the IP-2 Safeguards Contingency Plan. Security events which do not represent at least a potential degradation in the level of safety of the plant, are reported under 10CFR73.71 or in some cases under 10CFR50.72.

The plant Protected Area boundary is within the security isolation zone and is defined in the security plan. Bomb devices discovered within the plant vital area would result in EAL escalation.

PEG

Reference:

HU4.1 HU4.2 Basis Reference(s):

1. IP-2 Safeguards Contingency Plan

2. Table 3.1, "VitalAreas By Type And Category."

8-2

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 8.0 Hazards 8.1 Security Threats 8.1.2 Alert Intrusion into plant Protected Area by an adversary.

Mode Applicability:

Basis:

This class of security events represents an escalated threat to plant safety above that contained in the Unusual Event. For the purposes of this EAL, the intrusion by armed or suspected to be armed unauthorized personnel inside the Protected Area boundary can be considered a significant security threat. Intrusion into a vital area by similar personnel will escalate this event to a Site Area Emergency.

PEG

Reference:

HA4.1 HA4.2 Basis Reference(s):

1. IP-2 Safeguards Contingency Plan

2. Table 3.1, "Vital Areas By Type And Category."

8-3

tq i OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 8.0 Hazards 8.1 Security Threats 8.1.3 Site Area Emergency Intrusion into a plant security vital area by an adversary.

Mode Applicability:

Basis:

This class of security events represents an escalated threat to plant safety above that contained in the Alert in that armed or suspected to be armed unauthorized personnel have progressed from the Protected Area to the vital area.

PEG

Reference:

HS1.1 HS1.2 Basis Reference(s):

1. IP-2 Safeguards Contingency Plan

2. Table 3.1, "Vital Areas By Type And Category."

8-4

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 8.0 Hazards 8.1 Security Threats 8.1.4 General Emergency Security event which results in:

Loss of plant control from the Control Room AND Loss of remote shutdown capability Mode Applicability:

Basis:

This EAL encompasses conditions under which unauthorized personnel have taken physical control of vital areas required to reach and maintain safe shutdown.

PEG

Reference:

HG1.1 HG1.2 Basis Reference(s):

1. IP-2 Safeguards Contingency Plan

2. Table 3.1, "Vital Areas By Type And Category."

8-5

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 8.0 Hazards 8.2 Fire or Explosion 8.2.1 Unusual Event Confirmed fire in any plant area, Table 8.2 not extinguished in 5 15 min. of Control Room notification.

Table 8.2 Plant Vital Areas

~ Condensate Storage Tank

~ RWST

~ Service Water Pump Structure

~ Service Water Valve Pit East

~ Fuel Storage Building

~ Primary AuxiliaryBuilding/Fan House

~ Vapor Containment Building

~ 480 Volt Switchgear Room (Control Bldg.)

~ Cable Spreading Room/Electrical Tunnel

~ Central Control Room

~ Diesel Generator Building/Fuel Tank Area

~ AuxiliaryFeedwater Pump Building

~ Battery Room (Control Bldg. 33'0" ele.)

~ Central Alarm Station Mode Applicability:

Basis:

The purpose of this EAL is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. This excludes such items as fires within administration buildings, waste-basket fires, and other small fires of no safety consequence.

PEG

Reference:

HU2.1 8-6

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 Basis Reference(s):

1. Table 3.1, "Vital Areas By Type And Category."

8-7

I

'lr

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 8.0 Hazards 8.2 Fire or Explosion 8.2.2 Unusual Event Report by plant personnel of an explosion within Protected Area boundary which impacts plant safety related systems or structures.

Mode Applicability:

Basis:

The Protected Area boundary is within the security isolation zone and is defined in the site security plan.

For this EAL, only those explosions of sufficient force to damage permanent structures or equipment within the Protected Area should be considered. As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to near by structures and materials. No attempt is made in this EAL to assess the actual magnitude of the damage. The occurrence of the explosion with reports of evidence of damage (e. g., deformation, scorching) is sufBcient for declaration. The Emergency Director also needs to consider any security aspects of the explosion.

PEG

Reference:

HU1.5 Basis Reference(s):

1. Site Plot Plan 8-8

.4 4

'U

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 8.0 Hazards 8.2 Fire or Explosion 8.2.3 Alert Fire or explosion in any plant area, Table 8.2 which causes or potentially causes any required safety related system or structure to become inoperable Table 8.2 Plant Vital Areas

~ Condensate Storage Tank

~ RWST

~ Service Water Pump Structure

~ Service Water Valve Pit East

~ Fuel Storage Building

~ Primary AuxiliaryBuilding/Fan House

~ Vapor Containment Building

~ 480 Volt Switchgear Room (Control Bldg.)

~ Cable Spreading Room/Electrical Tunnel

~ Central Control Room

~ Diesel Generator Building/Fuel Tank Area

~ AuxiliaryFeedwater Pump Building

~ Battery Room (Control Bldg. 33'0" ele.)

~ Central Alarm Station Mode Applicability:

Basis:

The listed areas contain functions and systems required for the safe shutdown of the plant. The IP-2 safe shutdown analysis was consulted for equipment and plant areas required for the applicable mode.

With regard to explosions, only those explosions of sufficient force to damage permanent structures or equipinent required for safe operation within the identified plant areas should be considered. As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to nearby structures and materials. No attempt is made in this EAL to assess the actual magnitude of the damage. The declaration of an Alert and the activation of the TSC will provide the Emergency Director with the resources needed to perform damage assessments. The Emergency Director also needs to consider any security aspects of the explosions.

8-9

OSSI-92-402A-4-IP2 IP2 EAL Technfcal Bases Document, Rev 0 PEG

Reference:

HA2.1 Basis Reference(s):

1. Table 3.1, "Vital Areas By Type And Category."

8-10

$1~

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document. Rev 0 8.0 Hazards 8.3 Man-Made Events 8.3.1 Unusual Event Vehicle crash into or projectile which impacts plant safety related structures or systems within Protected Area boundary Mode Applicability:

Basis:

The Protected Area boundary is within the security isolation zone and is defined in the site security plan.

This EAL addresses such items as plane, helicopter, train, barge, car or truck crash, or impact of other projectiles that may potentially damage plant structures containing functions and systems required for safe shutdown of the plant. Ifthe crash is confirmed to affect a plant vital area, the event may be escalated to Alert.

PEG

Reference:

HU1.4 Basis Reference(s):

1. Site Plot Plan 8-11

i+

l,pl

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 8.0 Hazards 8.3 Man-Made Events 8.3.2 Unusual Event Report or detection of toxic or flammable gases that could enter or have entered within the Protected Area boundary in amounts that could affect the health of plant personnel or safe plant operation OR Report by local, county or state ofBcials, or Unit 3, for potential evacuation of site personnel based on offsite event Mode Applicability:

Basis.

This EAL is based on releases in concentrations within the site boundary that will affect the health of plant personnel or affecting the safe operation of the plant with the plant being within the evacuation area of an offsite event (i. e.,

tanker truck accident releasing toxic gases, etc.). The evacuation area is as determined from the DOT Evacuation Tables for Selected Hazardous Materials, in the DOT Emergency Response Guide for Hazardous Materials.

Should an explosion occur within a specified plant area, an Alert would be declared based on EAL 8.2.2.

PEG

Reference:

HU3.1 HU3.2 Basis Reference(s):

None 8-12

JCt 4

k%

OSSI-92-402A-4-IP2 IP2 EAL TechnIcal Bases Document, Rev 0 8.0 Hazards 8.3 Man-Made Events 8.3.3 Alert Vehicle crash or projectile impact which causes or potentially causes any required safety related system or structure to become inoperable, Table 8.2 Table 8.2 Plant Vital Areas

~ Condensate Storage Tank

~ RWST

~ Service Water Pump Structure

~ Service Water Valve Pit East

~ Fuel Storage Building

~ Primary Auxiliary Building/Fan House

~ Vapor Containment Building

~ 480 Volt Switchgear Room (Control Bldg.)

~ Cable Spreading Room/Electrical Tunnel

~ Central Control Room

~ Diesel Generator Building/Fuel Tank Area

~ AuxiliaryFeedwater Pump Building

~ Battery Room (Control Bldg. 33'0" ele.)

~ Central Alarm Station Mode Applicability:

Basis:

This EAL addresses events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage.

This EAL addresses such items as plane, helicopter, train, barge, car or truck crash, or impact of projectiles into a plant vital area.

PEG

Reference:

8-13

OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document, Rev 0 Basis Reference(s):

1. Table 3.1, "Vital Areas By Type And Category."

8-14

all I

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document. Rev 0 8.0 Hazards 8.3 Man-Made Events 8.3.4 Alert Report or detection of toxic or flammable gases within a plant area, Table 8.2, in concentrations that will be life threatening to plant personnel or preclude access to equipment (even when using personal protective equipment) necessary for safe plant operation Table 8.2 Plant Vital Areas

~ Condensate Storage Tank

~ RWST

~ Service Water Pump Structure

~ Service Water Valve Pit East

~ Fuel Storage Building

~ Primary Auxiliary Building/Fan House

~ Vapor Containment Building

~ 480 Volt Switchgear Room (Control Bldg.)

~ Cable Spreading Room/Electrical Tunnel

~ Central Control Room

~ Diesel Generator Building/Fuel Tank Area

~ AuxiliaryFeedwater Pump Building

~ Battery Room (Control Bldg. 33'0" ele.)

~ Central Alarm Station Mode Applicability:

Basis:

This EAL is based on gases that have entered a plant structure precluding access to equipment necessary for the safe operation of the plant. This EAL applies to buildings and areas contiguous to plant vital areas or other signiflcant buildings or areas. The intent of this EAL is not to include buildings (i. e., warehouses) or other areas that are not contiguous or immediately adjacent to plant vital areas. It is appropriate that increased monitoring be done to ascertain whether consequential damage has occurred.

8-15

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 PEG

Reference:

HA3.1 HA3.2 Basis Reference(s):

None 8-16

t Q) pD II 6

OSSI-92-402A-4-IP2 IP2 EAI Technfcal Bases Document, Rev 0 8.0 Hazards 8.4 Natural Events 8.4.1 Unusual Event Earthquake felt in plant by any plant operator AND Notification received from Unit 3 that an earthquake has been detected on their instrumentation Mode Applicability:

Basis:

Unit 3 seismic instrumentation actuates at 0.01 g.

Damage to some portions of the site may occur but it should not acct ability of safety functions to operate. Methods of detection can be based on instrumentation validated by a reliable source, operator assessment, or indication received from outside agencies. As defined in the EPRI-sponsored "Guidelines for Nuclear Plant Response to an Earthquake", dated October 1989, a "felt earthquake" is:

"An earthquake of sufBcient intensity such that: (a) the inventory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of Control Room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated. For most plants with seismic instrumentation, the seismic switches are set at an acceleration of about 0.01 g."

PEG

Reference:

HU1.1 Basis Reference(s):

1. EPRI document, "Guidelines for Nuclear Plant Response to an Earthquake", dated October 1989

2. Abnormal Operating Instruction 28.0.8 8-17

OSSI-92-402A-4-IP2 IP2 EAI TechnIcal Bases Document. Rev 0 8.0 Hazards 8.4 Natural Events 8.4.2 Unusual Event Report by plant personnel of tornado within plant Protected Area boundary Mode Applicability:

Basis:

This EAL is based on the assumption that a tornado striking (touching down) within the Protected Area boundary may have potentially damaged plant structures containing functions or systems required for safe shutdown of the plant. Ifsuch damage is confirmed visually or by other in-plant indications, the event may be escalated to Alert.

PEG

Reference:

HU1.2 Basis Reference(s):

1. NRC Safety Evaluation Report, 11/26/70 8-18

I" I g I 'a x'Q

OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document, Rev 0 8.0 Hazards 8.4 Natural Events 8.4.3 Unusual Event Assessment by Control Room personnel that a natural event has occurred which impacts plant safety related structures or systems, Table 8.2 Table 8.2 Plant Vital Areas

~ Condensate Storage Tank

~ RWST

~ Service Water Pump Structure

~ Service Water Valve Pit East

~ Fuel Storage Building

~ Primary AuxiliaryBuilding/Fan House

~ Vapor Containment Building

~ 480 Volt Switchgear Room (Control Bldg.)

~ Cable Spreading Room/Electrical Tunnel

~ Central Control Room

~ Diesel Generator Building/Fuel Tank Area

~ AuxiliaryFeedwater Pump Building

~ Battery Room (Control Bldg. 33'0" ele.)

~ Central Alarm Station Mode Applicability:

Basis:

This EAL allows for the Control Room to determine that an event has occurred and take appropriate action based on personal assessment as opposed to verification (i. e., an earthquake is felt but does not register on any plant-specific instrumentation, etc.).

PEG

Reference:

HU1.3 Basis Reference(s):

None 8-19

OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document, Rev 0 8.0 Hazards 8.4 Natural Events 8.4.4 Unusual Event River level > 14.5'OMSL)

OR Service water bay level ( -4.5'OMSL)

Mode Applicability:

Basis:

This covers high and low river water level conditions that could be precursors

)

of more serious events. River water level 14.5 ft. corresponds to the maximum anticipated river runup level. Service water Bay level < -4.5 ft, corresponds to the minimum level to support design service water flow rate.

PEG

Reference:

HU1.7 Basis Reference(s):

1. FSAR Section 2.5

2. Service Water Design Basis Document Section 1.4.1.1.2 8-20

P~~

4

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document. Rev 0 8.0 Hazards 8.4 Natural Events 8.4.5 Alert Earthquake felt in plant by any plant operator AND Notification from Unit 3 that an earthquake of a magnitude ) 0.15 g horizontal or 2 0.10 g vertical has occurred.

Mode Applicability:

Basxso This EAL addresses events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage.

This EAL is based on the FSAR design basis operating earthquake of 0.15 g horizontal or 0.10 g vertical. Seismic events of this magnitude can cause damage to plant safety functions.

PEG

Reference:

HA1.1 Basis Reference(s):

l. Abnormal Operating Instruction 28.0.8 8-21

II

'I I

1

OSSI-92-402A-4-IP2 IP2 EAL TechnIcal Bases Document, Rev 0 8.0 Hazards 8.4 Natural Events 8.4.6 Alert Sustained winds ) 100 mph onsite OR Tornado strikes a plant vital area, Table 8.2 Table 8.2 Plant Vital Areas

~ Condensate Storage Tank

~ RWST

~ Service Water Pump Structure

~ Service Water Valve Pit East

~ Fuel Storage Building Primary Auxiliary Building/Fan House

~ Vapor Containment Building

~ 480 Volt Switchgear Room (Control Bldg.)

Cable Spreading Room/Electrical Tunnel

~ Central Control Room

~ Diesel Generator Building/Fuel Tank Area

~ AuxiliaryFeedwater Pump Building

~ Battery Room (Control Bldg. 33'0" ele.)

~ Central Alarm Station Mode Applicability:

Basis:

This EAL addresses events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage.

This EAL is based on the FSAR design basis of 100 mph. Wind loads of this magnitude can cause damage to safety functions.

PEG

Reference:

HA1.2 8-22

OSSI-92-402A-4-IP2 IP2 EAL TechnIcal Bases Document, Rev 0 Basis Reference(s):

1. NRC Safety Evaluation Report, 11/26/70 8-23

h 4

OSSI-92-402A-4-IP2 IP2 EAL Technfcal Bases Document. Rev 0 8.0 Hazards 8.4 Natural Events 8.4.7 Alert Assessment by the Control Room personnel that a natural event has occurred which causes or potentially causes any required safety related system or structure to become inoperable, Table 8.2 Table 8.2 Plant Vital Areas

~ Condensate Storage Tank

~ RWST

~ Service Water Pump Structure

~ Service Water Valve Pit East

~ Fuel Storage Building

~ Primary AuxiliaryBuilding/Fan House

~ Vapor Containment Building

~ 480 Volt Switchgear Room (Control Bldg.)

~ Cable Spreading Room/Electrical Tunnel

~ Central Control Room

~ Diesel Generator Building/Fuel Tank Area

~ AuxiliaryFeedwater Pump Building

~ Battery Room (Control Bldg. 33'0" ele.)

~ Central Alarm Station Mode Applicability:

Basis:

This EAL addresses events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage.

This EAL specifies areas in which structures containing systems and functions required for safe shutdown of the plant are located.

8-24

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 PEG

Reference:

HA1.3 Basis Reference(s):

1. Table 3.1, "Vital Areas By Type And Category 8-25

44' OSSI-92-402A-4-IP2 IP2 EAI. Techntcal Bases Document, Rev 0 8.0 Hazards 8.4 Natural Events 8.4.8 Alert River level 2 15'OMSL)

OR Low service water bay level resulting in a loss of service water flow Mode Applicability:

Basis:

This EAL addresses events that may have resulted in a plant vital area being subjected to levels beyond design limits, and thus damage may be assumed to have occurred to plant safety systems.

This EAL covers high and low lake water level conditions that exceed levels

)

which threaten vital equipment. A river level 15 ft. corresponds to FSAR de6ned critical flood level which would threaten vital equipment. Service Water Bay level below that which results in a loss of service water flow would result in a loss of cooling water to numerous vital components.

PEG

Reference:

HA1.7 Basis Reference(s):

1. FSAR Section 2.5

2. Service Water Design Basis Document Section 1.4.1.1.2 8-26

'gc, OSSI-92-402A-4-IP2 IP2 EAI- Techntcal Bases Document, Rev 0 The EALs defined in categories 1.0 through 8.0 specify the predetermined symptoms or events which are indicative of emergency or potential emergency conditions, and which warrant classification. While these EALs have been developed to address the full spectrum of possible emergency conditions which may warrant classification and subsequent implementation of the Emergency Plan, a provision for classification of emergencies based on operator/management experience and judgment is still necessary. The EALs of this category provide the Senior Watch Supervisor, POM or Emergency Director the latitude to classify emergency conditions consistent with the established classification criteria, based upon their judgment.

9-1

(4

'1 4

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 9.0 Other 9.1.1 Unusual Event Any event, as determined by the Senior Watch Supervisor, POM or Emergency Director, that could lead to or has led to a potential degradation of the level of safety of the plant.

Mode Applicability:

Basis:

This EAL 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 Unusual Event emergency class.

From a broad perspective, one area that may warrant Emergency Director judgment is related to likely or actual breakdown of site specific event mitigating actions. Examples to consider include inadequate emergency response procedures, transient response either unexpected or not understood, failure or unavailability of emergency systems during an accident in excess of that assumed in accident analysis, or insufBcient availability of equipment and/or support personnel.

PEG

Reference:

HU5.1 Basis Reference(s):

None 9-2

C

+)

Ql j

.t

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 9.0 Other 9.1.2 Unusual Event Any event, as determined by the Senior Watch Supervisor, POM or Emergency Director, that could lead to or has led to a loss or potential loss of containment.

Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the containment barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in Emergency Director judgment that the barrier may be considered lost or potentially lost.

PEG

Reference:

PC8.1 Basis Reference(s):

None 9-3

Cl' OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 9.0 Other 9.1.3 Alert Any event, as determined by the Senior Watch Supervisor, POM or Emergency Director, that could cause or has caused actual substantial degradation of the level of safety of the plant.

Mode Applicability:

Basis:

This EAL 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 Alert emergency class.

PEG

Reference:

HA6.1 Basis Reference(s):

None 9-4

4!

Qt

OSSI-92-402A-4-IP2 IP2 EAI. Technical Bases Document, Rev 0 9.0 Other 9.1.4 Alert Any event, as determined by the Senior Watch Supervisor, POM or Emergency Director, that could lead or has led to a loss or potential loss of either fuel clad or RCS barrier.

Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses any other factors that are to be used by the Emergency Director in determining whether the fuel clad or RCS barriers are lost or potentially lost. In addition, the inability to monitor the barriers should also be considered in this EAL as a factor in Emergency Director judgment that the barriers may be considered lost or potentially lost, PEG

Reference:

FC7.1 RCS6.1 Basis Reference(s):

None 9-5

OSSI-92-402A-4-IP2 IP2 EAI- Techrdcal Bases Document, Rev 0 9.0 Other 9.1.5 Site Area Emergency As determined by the'Senior Watch Supervisor, POM or Emergency Directo'r, events are in progress which indicate actual or likely failures of plant systems needed to protect the public. Any releases are not expected to result in exposures which exceed EPA PAGs.

Mode Applicability:

Basis:

This EAL 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 class description for Site Area Emergency.

PEG

Reference:

HS8.1 Basis Reference(s):

None 9-6

~ it>

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 9.0 Other 9.1.6 Site Area Emergency Any event, as determined by the Senior Watch Supervisor, POM or Emergency Director, that could lead or has led to either:

Loss or potential loss of both fuel clad and RCS barrier OR Loss or potential loss of either fuel clad or RCS barrier in conjunction with a loss of containment Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses unanticipated conditions aFecting Qssion product barriers which are not addressed explicitly elsewhere. Declaration of an emergency is warranted because conditions exist which are believed by the Emergency Director to fall under the emergency class description for Site Area Emergency.

PEG

Reference:

FC7.1 RCS6.1 PC8.1 Basis Reference(s):

None 9-7

":A h

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 9.0 Other 9.1.7 General Emergency As determined by the Senior Watch Supervisor, POM or Emergency Director, events are in progress which indicate actual or imminent core damage and the potential for a large release of radioactive material in excess of EPA PAGs outside the site boundary.

Mode Applicability:

Basis:

This EAL 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 General Emergency class.

Releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the site boundary.

PEG

Reference:

HG2.1 Basis Reference(s):

None 9-8

>t Xt >, 'hy

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 9.0 Other 9.1.8 General Emergency Any event, as determined by the Senior Watch Supervisor, POM or Emergency Director, that could lead or has led to a loss of any two fission product barriers and loss or potential loss of the third.

Mode Applicability:

Power operation, hot shutdown Basis:

This EAL addresses unanticipated conditions affecting Gssion product barriers which are not addressed explicitly elsewhere. Declaration of an emergency is warranted because conditions exist which are believed by the Emergency Director to fall under the emergency class description for the General Emergency class, PEG

Reference:

FC7.1 RCS6.1 PC8.1 Basis Reference(s):

None 9-9

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 ATTA WEE A WORD LIST/DEFINITIONS

OSSI-S2-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 Actuate To put into operation; to move to action; commonly used to refer to automated, multi-faceted operations. "Actuate ECCS".

Adversary As applied to security EALs, an armed or suspected to be armed intruder whose intent is to commit sabotage, disrupt Station operations or otherwise commit a crime on station property.

Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Available The state or condition ofbeing ready and able to be used (placed into operation) to accomplish the stated (or implied) action or function. As applied to a system, this requires the operability of necessary support systems (electrical power supplies, cooling water, lubrication, etc.).

Can/Cannot be determined (c/>)

The current value or status of an identified parameter relative to that specified can/cannot be ascertained using all available indications (direct and indirect, singly or in combination).

Can/Cannot be maintained above/below (c/>)

The value of the identified parameter(s) is/is not able to be kept above /below specified limits. This determination includes making an evaluation that considers both current and future system performance in relation to the current value and trend of the parameter(s). Neither implies that the parameter must actually exceed the limitbefore the action is taken nor that the action must be taken before the limitis reached.

OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document, Rev 0 Can/Cannot be restored above/below (c/>)

The value of the identified parameter(s) is/is not able to be returned to above/below specified limits after having passed those limits. This determination includes making an evaluation that considers both current and future systems performances in relation to the current value and trend of the parameter(s). Does not imply any specific time interval but does not permit prolonged operation beyond a limit without taking the specified action.

As applied to loss of electrical power sources (ex.: Power cannot be restored to any vital bus in 5 4 hrs) the specified power source cannot be returned to service within the specified time. This determination includes making an evaluation that considers both current and future restoration capabilities.

Implies that the declaration should be made as soon as the determination is made that the power source cannot be restored within the specified time.

Close To position a valve or damper so as to prevent flow of the process fluid.

To make an electrical connection to supply power.

Con6rm / Con6rmation To validate, through visual observation or physical inspection, that an assumed condition is as expected or required, without taking action to alter the "as found" configuration.

Control Take action, as necessary, to maintain the value of a specified parameter within applicable limits; to fiix or adjust the time, amount, or rate of; to regulate or restrict.

Decrease To become progressively less in size, amount, number, or intensity.

Discharge Removal of a fluid/gas from a volume or system.

A-3

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 Enter To go into.

Establish To perform actions necessary to meet a stated condition. "Establish communication with the Control Room."

Evacuate To remove the contents of; to remove personnel from an area.

Exceeds To go or be beyond a stated or implied limit, measure, or degree.

Exist To have being with respect to understood limitations or conditions.

Failure A state of inability to perform a normal function.

General Emergency Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels oFsite for more than the immediate site area.

Logic term which indicates that taking the action prescribed is contingent upon the current existence of the stated condition(s). Ifthe identified conditions do not exist, the prescribed action is not to be taken and execution of operator actions must proceed promptly in accordance with subsequent instructions.

A-4

OSSI-92-402A-4-IP2 IP2 EAL TechnIcal Bases Document, Rev 0 Increase To become progressively greater in size, amount, number or intensity.

Indicate To point out or point to; to display the value of a process variable; to be a sign or symbol.

Initiate The act of placing equipment or a system into service, either manually or automatically. Activation of a function or protective feature (i.e. initiate a manual trip).

Injection The act of forcing a fluid into a volume or vessel.

Inoperable Not able to perform it's intended function Intrusion The act of entering without authorization Failure of operability or lack of access to.

Maintain Take action, as necessary, to keep the value of the specified parameter within the applicable limits.

Monitor Observe and evaluate at a frequency suf6cient to remain apprised of the value, trend, and rate of change of the speci6ed parameter.

A-5

OSSI-92-402A-4-IP2 IP2 EAI- Technical Bases Document, Rev 0 Notify To give notice of or report the occurrence of; to make known to; to inform specified personnel; to advise; to communicate; to contact; to relay.

Open To position a valve or damper so as to allow flow of the process fluid.

To break an electrical connection which removes a power supply from an electrical device.

To make available for entry or passage by turning back, removing, or clearing away.

Operable Able to perform it's intended function Perform To carry out an action; to accomplish; to affect; to reach an objective.

Primary System The pipes, valves, and other equipment which connect directly to the reactor vessel or reactor coolant system such that a reduction in reactor coolant system pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.

Remove To change the location or position of.

Report To describe as being in a specific state.

A-6

OSSI-92-402A-4-IP2 IP2 EAL Techntcal Bases Document, Rev 0 Require To demand as necessary or essential.

Take the appropriate action requires to return the value of an identified parameter to within applicable limits.

Rise Describes an increase in a parameter as the result of an operator or automatic action.

Sample To perform an analysis on a specified media to determine its properties.

Shut down To perform operations necessary to cause equipment to cease or suspend operation; to stop. "Shut down unnecessary equipment."

Site Area Emergency Events are in process or have occurred which involve actual or likel m 'i ures of plant functions needed for protection of the public. Any releases failure are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels except near the site boundary.

Sustained Prolonged. Not intermittent or of transitory nature

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document. Rev 0 Trip To de-energize a pump or fan motor; to position a breaker so as to interrupt or prevent the flow of current in the associated circuit; to manually activate a semi-automatic feature.

To take action to cause shutdown of the reactor by rapidly inserting a control rod or control rods (PWR).

Uncontrolled An evolution lacking control but is not the result of operator action.

Unplanned Not as an expected result of deliberate action.

Until Indicates that the associated prescribed action is to proceed only so long as the identified condition does not exist.

Unusual Event Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Valid Supported or corroborated on a sound basis.

Vent To open an efQuent (exhaust) flowpath from an enclosed volume; to reduce pressure in an enclosed volume.

A-8

OSSI-92-402A-4-IP2 IP2 EAL Technical Bases Document, Rev 0 Verify To confirm a condition and take action to establish that condition ifrequired.

"Verifyreactor trip, verify SI pumps running."

A-9

Indian Point 2 Emergency Action Levels Category 1.0 CSFST Status Category 2.0 Reactor Fuel Category 3.0 Reactor Coolant System Category 4.0 Containment Category 5.0 Radioactivity Release Category 6.0 Electrical Failures Category 7.0 Equipment Failures Category 8.0 Hazards Category 9.0 Other 6/20/94

0

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1

Category 1.0 CSFST Status 1.0 CSFST Status 1.1.3 General Emergency 1.1 Subcriticality RED path in F-0.1, SUBCRITICALITY AND 1.1.1 Alert Emergency boration is required AND Either: RED path in F-0.3, HEAT SINK ORANGE path F-0.1 SUBCRITICALITY AND AND Heat sink is required Emergency boration is required OR Power Operations RED path F-0.1 SUBCRITICALITY AND Emergency boration is required Power Operations, Hot Shut'down 1.1.2 Site Area Emergency RED path in F-0.1 SUBCRITICALITY AND either:

Emergency boration is inoperable OR

(

Power range not 6% within 15 min. of initiation of emergency boration Power Operations, Hot Shutdown

Category 1.0 CSFST Status 1.0 CSFST Status 1.0 CSFST Status 12 Core Cooling 18 Heat Sink 1.2.1 Site Area Emergency 1.8.1 Site Area Emergency ORANGE or RED path in F-0.2, CORE COOLING RED path in F-0.3, HEAT SINK AND Power Operations, Hot Shutdown Heat sink is required Power Operations, Hot Shutdown 1.R2 General Emergency RED path in F-0.2, CORE COOLING 1.8.2 General Emergency AND Functional restoration actions taken and procedures RED path in F-0.3, HEAT SINK not effective within 15 min. AND Heat sink is required Power Operations, Hot Shutdown AND RED path in F-0.1, SUBCRITICALITY AND Emergency boration is required Power Operations 1-3

Category 1.0 CSFST Status 1.0 CSFST Status 1.0 CSFST Status 1.4 Integrity 1.5 Contauunent 1.4.1 Alert 1.5.1 General Emergency RED path on F-0.4, INTEGRITY RED path F-0.5, CONTAINMENTresulting from loss of coolant Power Operations, Hot Shutdown Power Operations, Hot Shutdown 1-4

Category 2.0 Reactor Fuel 2.0 Reactor Fuel 2.0 Reactor Fuel 2.1 Coolant Activity 2.2 Containment Radiation 2.1.1 Unusual Event 2.2.1 Alert Coolant sample activity > 60/(E bar) pCi/cc Rapid rise on R-41 or R-42 with coolant sample activity 2 60/(E bar) pCi/cc and increasing RCS leakage Power operation, hot shutdown 2.12 Alert 2.2.2 Site Area Emergency Coolant activity > 300 pCi/cc I-131 equivalent Containment radiation monitor R-25 or R-26 > 17 R/hr Power operation, hot shutdown Power operation, hot shutdown 2.2.3 General Emergency Containment radiation monitor R-25 or R-26 > 68 R/hr Power operation, hot shutdown

Category 2.0 Reactor Fuel 2.0 Reactor Fuel 2.8 Refueling Accidents or Other Radiation Monitors 2.8.1 Unusual Event Spent fuel pool (reactor cavity during refueling) water level cannot be restored and maintained above the Technical Specification minimum water level 2.3.2 Alert Confirmed sustained alarm on any of the following radiation monitors resulting from fuel damage caused by an uncontrolled fuel handling process:

~ R-2/R-7 Vapor Containment Area Monitors

~ R-5 Fuel Storage Building Area Monitor

~ R-25/26 Vapor Containment High Radiation Area Monitors AIE 2.3.8 Alert Report of visual observation of irradiated fuel uncovered

0)

Category 8.0 Reactor Coolant System 8.0 Reactor Coolant System 8.0 Reactor Coolant System 3.1 RCS Leakage 3.2 Primary to Secondary Leakage 8.1.1 Unusual Event 3.2.1 Unusual Event Unidentified or pressure boundary leakage > 10 gym Unisolable release of secondary side to atmosphere OR from the affected steam generator(s) with primary to Identified leakage > 25 gpm )

'econdary leakage 0.8 gym in any steam generator Power operation, hot shutdown Power operation, hot shutdown 3.1.2 Alert 3.2.2 Site Area Emergency Primary system leakage exceeding capacity (> 75 Unisolable release of secondary side to atmosphere gpm) of a single charging pump from the affected steam generator(s) with primary to secondary leakage exceeding capacity (> 75 gym) of a Power operation, hot shutdown single charging pump Power operation, hot shutdown 8.1.3 Site Area Emergency RVLIS cannot be maintained > 39% with no RCPs 8.2.8 Site Area Emergency running OR Unisolable release of secondary side to atmosphere With the reactor vessel head removed, it is reported from the affected steam generator(s) with primary to that water level in the reactor vessel is dropping in an secondary leakage ) 0.8 gym in any steam generator uncontrolled manner and core uncovery is likely AND Coolant activity > 300 pCi/cc of I-131 Power operation, hot shutdown, cold shutdown, refuel Power operation, hot shutdown 3-1

Category 3.0 Reactor Coolant System 3.0 Reactor Coolant System 3.3 RCS Subcooling 3.3.1 Alert RCS subcooling < SI initiation setpoint due to RCS leakage Power operation, hot shutdown 3-2

Category 4.0 Containment 4.0 Containment 4.0 Containment 4.1 Containment Integrity Status 4.1 Containment Integrity Status 4.1.1 Unusual Event 4.1.8 Site Area Emergency Both doors open on a VC airlock for > 4 hrs. Either:

OR Any Phase "A" or Phase "B" or containment Inability to close containment pressure relief or purge ventilation isolation valve(s) not closed when valves which results in a radiological release pathway required following confirmed LOCA to the environment for > 4 hrs. OR Inability to isolate any primary system discharging Power operation, hot shutdown outside containment AND Radiological release to the environment exists as a 4.1.2 Site Area Emergency result Rapid uncontrolled decrease in containment pressure Power operation, hot shutdown following initial increase due to RCS failure OR Loss of primary coolant inside containment with 4.1.4 General Emergency containment pressure or sump level response not consistent with LOCA conditions Confirmed phase "B" isolation signal with less than minimum containment cooling safeguards equipment Power operation, hot shutdown operating, Table 4.3 AND Any indicators of fuel clad loss, Table 4.1 Power operation, hot shutdown

Category 4.0 Containment 4.0 Containment 4.0 Containment 4.1 Containment Integrity Status 4.2 SG Tube Rupture w/ Secondary Release 4.1.5 General Emergency 4.2.1 Site Area Emergency Either: Unisolated faulted (outside VC) ruptured steam Rapid uncontrolled decrease in containment generator pressure following initial increase due to RCS failure Power operation, hot shutdown OR Loss of primary coolant inside containment with containment pressure or sump level response not 4.2.2 General Emergency consistent with LOCA conditions AND Unisolated faulted (outside VC) ruptured steam Any indicators of fuel clad damage, Table 4.2 generator AND Power operation, hot shutdown Any indicators of fuel clad damage, Table 4.2 4.1.6 General Emergency Power operation, hot shutdown Either.'ny Phase "A" or Phase "B" or containment ventilation isolation valve(s) not closed when required following confirmed LOCA OR Inability to isolate any primary system discharging outside containment AND Radiological release to the environment exists as a result AND Any indicators of fuel clad damage, Table 4.2 Power operation, hot shutdown

Category 4.0 Containment 4.0 Containment 4.3 Combustible Gas Concentrations 4.3.1 General Emergency 2 4% hydrogen concentration in containment Power operation, hot shutdown Table 4.3 Minimum Containment Cooling Table 4.1 Fuel Clad Loss Indicators Safe ards E ui ment FanCooler Units 0 eratin S ra Pum sRe uired

1. Coolant activity > 300 pCi/cc of I-131

2. Containment radiation monitor R-25/R-26 (3 reading >17 R/hr 3 5

Table 4.2 Fuel Clad Dama e Indicators

1. ORANGE or RED path in F-0.2, CORE COOLING

2. RED path in F-0.3, HEAT SINK AND Heat sink is required

3. Coolant activity > 300 pCi/cc of I-131

4. Containment radiation monitor,R-25/R-26 reading >17 R/hr 4-3

Category 6.0 Radioactivity Release 6.0 Radioactivity Release /Area Radiation 6.0 Radioactivity Release / Area Radiation 6.1 EQluent Monitors 6.2 Dose Projections/ Environmental Measurements/ Release Rates 6.1.1 Unusual Event 6.2.1 Unusual Event A valid reading on any monitors Table 5,1 column "NUE" for > 60 min. Confirmed sample analyses for gaseous or liquid release rates > 2 x technical specifications limits for >

60 min.

6.1.2 Alert A valid reading on any monitors Table 5.1 column 6.2.2 Alert "Alert"for > 15 min.

Confirmed sample analyses for gaseous or liquid release rates > 200 x technical specifications limits for

> 15 min.

6.1.3 Site Area Emergency All A valid reading on any monitors Table 5.1 column "SAE" for > 15 min. 6.2.3 Alert Dose projections or field surveys which indicate doses /

dose rates > Table 5.2 column "Alert" at the site boundary or beyond.

6.1.4 General Emergency A valid reading on any monitors Table 5.1 column "GE" for > 15 min.

5-1

Category 6.0 Radioactivity Release 6.0 Radioactivity Release /Area Radiation 6.0 Radioactivity Release /Area Radiation 5.2 Dose Projections/ Environmental 6.3 Area Radiation Levels Measurements/ Release Rates 6.3.1 Unusual Event 6.2.4 Site Area Emergency Any sustained direct ARM readings > 100 x alarm or Dose projections or field surveys which indicate doses / offscale hi resulting from an uncontrolled process dose rates > Table 5.2 column "SAE" at the site boundary or beyond. All 6.3.2 Alert

'=

6.2.6 General Emergency Sustained area radiation levels > 15 mR/hr in either:

Control Room Dose projections or field surveys which indicate doses / OR dose rates > Table 5.2 column "GE" at the site Central Alarm Station and Secondary Alarm boundary or beyond. Station All 6.3.3 Alert Sustained abnormal area radiation levels > 8 R/hr within any areas, Table 5.3 AND Access is required for safe operation or shutdown 5-2

Category 6.0 Radioactivity Release Table 5.1 EfHuent Monitor Classification Thresholds Monitor GE R-27 53 pCi/cc 5.3 pCi/cc 5.3E-1 pCi/cc 2.3E-3 pCi/cc RM 53 pCi/cc 5.3 pCi/cc 5.3E-1 p,Ci/cc 2.3E-3 pCi/cc R-54 N/A N/A 2.5E-1 pCi/cc 2.5E-3 pCi/cc R-49 N/A N/A 2.7E-2 p,Ci/cc 2.7E-4 pCi/cc Table 5.2 Dose Pro ection/Env. Measurement Classification Thresholds GE TEDE 1000 mR 100 mR 10 mR CDE Thyroid 5000 mR 500 mR N/A TEDE rate 1000 mR/hr 100 mR/hr 10 mR/hr CDE Thyroid rate 5000 mR/hr 500 mR/hr N/A 5-3

Category 5.0 Radioactivity Release Table 5.3 Plant Areas

~ Condensate Storage Tank

~ RWST

~ Service Water Pump Structure

~ Service Water Valve Pit East

~ Fuel Storage Building

~ Primary AuxiliaryBuilding/Fan House

~ 480 Volt Switchgear Room (Control Building)

~ Cable Spreading Room/Electrical Tunnel

~ Diesel Generator Building/Fuel Tank Area

~ AuxiliaryFeedwater Pump Building

~ Battery Room (Control Building 33'" ele.)

5-4

Category 6.0 Electrical Failures 6.0 Electrical Failures 6.0 Electrical Failures 6.1 Loss of AC Power Sources 6.1 Loss of AC Power Sources 6.1.1 Unusual Event 6.1.3 Alert None of the following sources of o6site power available Available emergency bus AC power sources reduced to for > 15 min.: only one of the following for > 15 min.:

~ Unit Auxiliarytransformer ~ 480V EDG 21

~ Station Auxiliarytransformer ~ 480V EDG 22

~ 13.8 KV gas turbine transformer ~ 480V EDG 23

~ Unit Auxiliarytransformer

~ Station Auxiliarytransformer

~ 13.8 KV gas turbine transformer 6.1.2 Alert Power operation, hot shutdown Loss of AC power to all 480 volt busses (5A, 2A/3A, 6A) 6.1.4 Site Area Emergency for > 15 min.

AND Loss of AC power to all 480 volt busses (5A, 2A/3A, 6A)

Inability to power required core cooling systems with for > 15 min.

alternate power sources for > 15 min. AND Inability to power required core cooling systems with Cold Shutdown, Refueling alternate power sources for > 15 min.

Power operation, hot shutdown

Category 6.0 Electrical Failures 6.0 Electrical Failures 8.0 Electrical Failures 6.1 Loss of AC Power Sources 6.2 Loss of DC Power Sources 8.1.5 General Emergency 6.2.1 Unusual Event Loss of all emergency bus AC power < 105 vdc bus voltage indications for > 15 min. on the AND either: switchable voltmeter for all of the following panels:

Power cannot be restored to required core cooling ~ 21 systems in < 1 hr 22 OR 23 ORANGE or RED path on F-0.2, "CORE ~ 24 COOLING" Cold Shutdown, Refueling Power operation, hot shutdown 6.2.2 Site Area Emergency

< 105 vdc bus voltage indications for > 15 min. on the switchable voltmeter for all of the following panels:

~ 21 22 23

~ 24 Power operat'ion, hot shutdown

Category V.O Equipment Failures V.O Equipment Failures 7.0 Equipment Failures V.1 Technical SpeciGcationXRequirements 7.2 System Failures or Control Room Evacuation V.1.1 Unusual Event V.2.1 Unusual Event Plant is not brought to required operating mode within Technical Specifications LCO Action Statement Time. Report of main turbine failure requiring turbine trip resulting in:

Power operat'ion, hot shutdown Damage to turbine generator seals OR Casing penetration Power Operations 7.2.2 Alert Turbine failure generated missiles which causes or potentially causes any required safety related system or structure to become inoperable Power Operations, Hot Shutdown 7.2.3 Alert Control Room evacuation

Category V.O Equipment Failures V.O Equipment Failures 7.0 Equipment Failures 7.2 System Failures or Control Room V.3 Loss of Indications /Alarms /

Evacuation Communication Capability V.2.4 Alert V.3.1 Unusual Event Reactor coolant temperature cannot be maintained ( Unplanned loss of most (approx. 75%) annunciators or 200 'F indications on Control Room Panels for > 15 min.

AND Cold Shutdown, Refueling Increased surveillance is required for safe plant operation 7.2.6 Site Area Emergency Power operation, hot shutdown Control Room evacuation AND 7.3.2 Unusual Event Core cooling cannot be established per AOI 27.1.9, "Control Room Inaccessibility/Safe Shutdown" in ~ 15 Loss of all communications capability affecting the min. ability to either:

Perform routine operations OR Notify offsite agencies or personnel 7-2

Category 7.0 Equipment Failures 7.0 Equipment Failures V.3 Loss of Indications /Alarms /

Communication Capability V.3.3 Alert Unplanned loss of most (approx. 75%) annunciators or indications on Control Room Panels for > 15 min.

AND Increased surveillance is required for safe plant operation AND either:

A plant transient in progress OR PROTEUS and SAS are unavailable Power operation, hot shutdown V.3.4 Site Area Emergency Loss of most (approx. 75%) annunciators or indications on Control Room Panels AND Complete loss of ability to monitor all critical safety function status AND A plant transient in progress Power operation, hot shutdown

Category 8.0 Hazards 8.0 Hazards 8.0 Hazards 8.1 Security Threats 8.2 Fire or Explosion 8.1.1 Unusual Event 8.2.1 Unusual Event Bomb device or other indication of attempted sabotage Confirmed fire in any plant area, Table 8.2 not discovered within plant Protected Area. extinguished in 6 15 min. of Control Room notification.

8.1.2 Alert 8.2.2 Unusual Event Intrusion into plant Protected Area by an adversary. Report by plant personnel of an explosion within Protected Area boundary which impacts plant safety All related systems or structures.

8.1.3 Site Area Emergency Intrusion into a plant security vital area by an 8.2.3 Alert adversary.

Fire or explosion in any plant area, Table 8.2 which causes or potentially causes any required safety related system or structure to become inoperable 8.1.4 General Emergency Security event which results in:

Loss of plant control from the Control Room AND Loss of remote shutdown capability 8-1

Category 8.0 Hazards 8.0 Hazards 8.0 Hazards 8.3 Man-Made Events 8.3 Man-Made Events 8.3.1 Unusual Event 8.3.4 Alert Vehicle crash into or projectile which impacts plant Report or detection of toxic or flammable gases within safety related structures or systems within Protected a plant area, Table 8.2, in concentrations that will be Area boundary life threatening to plant personnel or preclude access to equipment (even when using personal protective equipment) needed for safe plant operation ALL 8.3.2 Unusual Event Report or detection of toxic or flammable gases that could enter or have entered within the Protected Area boundary in amounts that could affect the health of plant personnel or safe plant operation OR Report by local, county or state of6cials, or Unit 3, for potential evacuation of site personnel based on offsite event 8.3.3 Alert Vehicle crash or projectile impact which causes or potentially causes any required safety related system or structure to become inoperable, Table 8.2 8-2

Category 8.0 Hazards 8.0 Hazards 8.0 Hazards 8.4 Natural Events 8.4 Natural Events 8.4.1 Unusual Event 8.4.4 Unusual Event Earthquake felt in plant by any plant operator River level > 14.5'OMSL)

AND OR Notification received from Unit 3 that an earthquake Service water bay level < -4.5'OMSL) has been detected on their instrumentation 8.4.5 Alert

'.4.2 Unusual Event Earthquake felt in plant by any plant operator Report by plant personnel of tornado within plant AND Protected Area boundary Notification from Unit 3 that an earthquake of a t

magnitude > 0.15 g horizontal or 0.10 g vertical has occurred.

8.4.3 Unusual Event Assessment by Control Room personnel that a natural 8.4.6 Alert event has occurred which impacts plant safety related structures or systems, Table 8.2 Sustained winds > 100 mph onsite OR Tornado strikes a plant vital area, Table 8.2 8-3

Category 8.0 Hazards 8.0 Hazards 8.4 Natural Events Table 8.2 Plant Vital Areas 8.4.7 Alert ~ Condensate Storage Tank Assessment by the Control Room personnel that a

~ RWST natural event has occurred which causes or potentially Service Water Pump Structure causes any required safety related system or structure

~ Service Water Valve Pit East to become inoperable, Table 8.2

~ Fuel Storage Building

~ Primary AuxiliaryBuilding/Fan House

~ Vapor Containment Building

~ 480 Volt Switchgear Room (Control Bldg.)

~ Cable Spreading Room/Electrical Tunnel 8.4.8 Alert

~ Central Control Room

~ Diesel Generator Building/Fuel Tank Area River level > 16'OMSL)

~ AuxiliaryFeedwater Pump Building OR

~ Battery Room (Control Bldg. 33'0" ele)

Low service water bay level resulting in a loss of

~ Central Alarm Station service water Qow 8-4

Category 9.0 Other 9.0 Other 9.0 Other 9.1.1 Unusual Event 9.1.4 Alert Any event, as determined by the Senior Watch Any event, as determined by the Senior Watch Supervisor, POM or Emergency Director, that could Supervisor, POM or Emergency Director, that could lead to or has led to a potential degradation of the level lead or has led to a loss or potential loss of either fuel of safety of the plant. clad or RCS barrier.

Power operation, hot shutdown 9.1.2 Unusual Event 9.1.5 Site Area Emergency Any event, as determined by the Senior Watch As determined by the Senior Watch Supervisor, POM Supervisor, POM or Emergency Director, that could or Emergency Director, events are in progress which lead to or has led to a loss or potential loss of indicate actual or likely failures of plant systems containment. needed to protect the public. Any releases are not expected to result in exposures which exceed EPA Power operation, hot shutdown PAGs.

All 9.1.3 Alert Any event, as determined by the Senior Watch 9.1.6 Site Area Emergency Supervisor, POM or Emergency Director, that could cause or has caused actual substantial degradation of Any event, as determined by the Senior Watch the level of safety of the plant. Supervisor, POM or Emergency Director, that could lead or has led to either:

Loss or potential loss of both fuel clad and RCS barrier OR Loss or potential loss of either fuel clad or RCS barrier in conjunction with a loss of containment Power operation, hot shutdown

I Category 9.0 Other 9.0 Other 9.1.7 General Emergency As determined by the Senior Watch Supervisor, POM or Emergency Director, events are in progress which indicate actual or imminent core damage and the potential for a large release of radioactive material in excess of EPA PAGs outside the site boundary.

9.1.8 General Emergency Any event, as determined by the Senior Watch Supervisor, POM or Emergency Director, that could lead or has led to a loss of any two fission product barriers and loss or potential loss of the third.

Power operation, hot shutdown

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