seabrook, license amendment request 12-01 proposed changes … · 2013. 4. 8. · ener oyok...

NExTeramENERGY

SEABROOKApril 30, 2012

10 CFR 50.90

SBK-L-12062Docket No. 50-443

U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

Seabrook Station

License Amendment Request 12-01

Proposed Changes to Seabrook Station Emergency Action LevelsRegarding Safety System Indications

In accordance with the provisions of Section 50.90 of Title 10 of the Code of FederalRegulations (10 CFR), NextEra Energy Seabrook, LLC (NextEra) is submitting LicenseAmendment Request (LAR) 12-01 to revise the Seabrook Station Emergency Plan. Theproposed changes are associated with the initiating conditions involving a loss of safety systemannunciation or indication in the control room. The current classification scheme includesemergency action levels (EAL) that could place the plant in an emergency classification basedsolely on a loss of radiation monitoring indications. However, a loss of radiation monitoringindications by itself does not represent degradation in the level of plant safety. Therefore, theproposed changes revise the EALs to include radiation monitoring indications within theaggregate of safety system indications that are considered when evaluating a loss of safetysystem indications rather than separate EALs. The changes are consistent with NEI 99-01,"Methodology for Development of Emergency Actions Levels," revision 5.

As discussed in the evaluation, the proposed change does not involve a significant hazardsconsideration pursuant to 10 CFR 50.92, and there are no significant environmental impactsassociated with the change.

The Station Operation Review Committee has reviewed this LAR. NextEra has determined thatwith the proposed changes, the emergency plan will continue to meet the requirements in 10CFR 50, Appendix E, and the planning standards of § 50.47(b). A copy of this LAR has beenforwarded to the New Hampshire State Liaison Officer pursuant to 10 CFR 50.91 (b).

NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

United States Nuclear Regulatory CommissionSBK-L-12062 /

No new commitments are made as a result of this change.

NextEra requests NRC review and approval of LAR 12-01 with issuance of a license amendmentby April 15, 2013 and implementation of the amendment within 90 days.

Should you have any questions regarding this letter, please contact Mr. Michael O'Keefe,Licensing Manager, at (603) 773-7745.

Sincerely,

NextEra Energy Seabrook, LLC

Paul FreemanSite Vice President

Enclosure

cc: NRC Region I AdministratorJ. G. Lamb, NRC Project ManagerW. J. Raymond, NRC Senior Resident Inspector

Mr. Christopher M. Pope, Director Homeland Security and Emergency ManagementNew Hampshire Department of SafetyDivision of Homeland Security and Emergency ManagementBureau of Emergency Management33 Hazen DriveConcord, NH 03305

Mr. John Giarrusso, Jr., Nuclear Preparedness ManagerThe Commonwealth of MassachusettsEmergency Management Agency400 Worcester RoadFramingham, MA 01702-5399

NEXTVraENER OYOK

SEABROOK

AFFIDAVIT

The following information is enclosed in support of this License Amendment Request:

* NextEra Energy Seabrook's Evaluation of the Proposed Change

I, Paul Freeman, Site Vice President of NextEra Energy Seabrook, LLC herebyaffirm that the information and statements contained within this license amendmentrequest are based on facts and circumstances which are true and accurate to thebest of my knowledge and belief.

Sworn and Subscribedbefore me this3D day of AVO*

Notary Pub# .

2012

Paul FreemanSite Vice President

Enclosure

NextEra Energy Seabrook's Evaluation of the Proposed Change

Subject: Proposed Changes to Seabrook Station Emergency Action LevelsRegarding Safety System Indications

1.0 SUMMARY DESCRIPTION

2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

4.2 Significant Hazards Consideration

4.3 Conclusion

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

Attachments:

1. Comparison of the EALs in NEI 99-01, the current Seabrook EALs, and the proposedEALs.

2. Differences and deviations between the proposed EALs and NEI 99-01.

3. Marked up copy of EALs

4. Clean copy of EALs

5. Marked up copy of EAL technical basis

6. Clean copy of EAL technical basis

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1.0 SUMMARY DESCRIPTION

NextEra Energy Seabrook, LLC (NextEra) is proposing changes to the emergency actionlevels (EAL) associated with the initiating conditions involving a loss of safety systemannunciation or indication in the control room. The current classification schemeincludes EALs that could place the plant in an emergency action level based solely on aloss of radiation monitoring indications. These EALs are unnecessarily limiting andinconsistent with the intent of NEI 99-0 1, Methodology for Development of EmergencyAction Levels, because the current scheme could result in an event declaration for a lossof radiation monitors, a condition that does not indicate a reduction in the level of safetyof the plant. Therefore, the proposed changes revise the EALs to include radiationmonitoring indications within the aggregate of safety system indications rather thanseparate EALs.

The proposed changes revise the EALs for the initiating conditions below:

Initiating Condition Classification Level EAL summary Description

SU3 Unusual Event Loss of safety system indicationSA4 Alert Loss of safety system indicationSS6 Site Area Emergency Loss of safety system indication or

annunciation

The Attachments to this Enclosure include:

1. Comparison of the EALs in NEI 99-01, revision 5; the current Seabrook EALs,and the proposed EALs.

2. Differences and deviations between the proposed EALs and NEI 99-01.

3. Marked up copy of EALs

4. Clean copy of EALs

5. Marked up copy of EAL technical basis

6. Clean copy of EAL technical basis

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2.0 DETAILED DESCRIPTION

Below are the proposed changes to the EALS associated with initiating conditions SU3,SA4, and. SS6, which involve a.loss of safety system annunciation or indication in thecontrol room. Changes from the current EALs are shown in bold italic type.

Initiating Condition SU3

Current EAL Proposed EALInitiating Condition SU3 Initiating Condition SU3

UNPLANNED loss of most or all safety UNPLANNED loss of most or all safetysystem annunciation or indication in the system annunciation or indication in theControl Room for > 15 minutes Control Room for > 15 minutesOp. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4

Emergency Action Level(s) Emergency Action Level(s)

Note: The Emergency Director should not

wait until 15 minutes has elapsed, butshould declare the event as soon as it isdetermined that the condition hasexceeded, or will likely exceed 15minutes.

1. UNPLANNED loss of approximately 75% 1. UNPLANNED loss of approximately 75%or more of UA annunciators for > 15 or more of UA annunciators for > 15minutes. minutes.

OR OR

2. UNPLANNED loss of approximately 75% 2. UNPLANNED loss of approximately 75%or more of Main Control Board indications or more of the following safety-relatedfor> 15 minutes. indications for> 15 minutes:

a. Safety-related indications on theMain Control Boards (MCBs)

ANDb. Radiation monitor indications on

CP-180 A and B.

OR

3. UNPLANNED loss of approximately 75%or more of radiation monitor indicationsfor> 15 minutes.

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Initiating Condition SA4

Current EAL Proposed EAL

Initiating Condition SA4 : - " " .... ' , ' Initiating Condition SA4 "'..........

UNPLANNED loss of most or all safety UNPLANNED loss of most or all safetysystem annunciation or indication in Control system annunciation or indication in ControlRoom with either (1) a SIGNIFICANT Room with either (1) a SIGNIFICANTTRANSIENT in progress, or (2) TRANSIENT in progress, or (2)compensatory indicators are unavailable compensatory indicators are unavailable

Op. Modes: 1, 2, 3, 4 Op. Modes. 1, 2, 3, 4


Note: The Emergency Director should notwait until 15 minutes has elapsed, butshould declare the event as soon as itis determined that the condition hasexceeded, or will likely exceed 15minutes.

1. EITHER of thefollowing: (a or b)

1. a. UNPLANNED loss of approximately a. UNPLANNED loss of approximately75% or more of UA annunciators for > 75% or more of UA annunciators for >15 minutes. 15 minutes.

OR OR

b. UNPLANNED loss of approximately b. UNPLANNED loss of approximately75% or more of Main Control Board 75% or more of the following safety-indications for> 15 minutes. related indications for> 15 minutes:

OR 1. Safety-related indications on theMain Control Boards (MCBs)

c. UNPLANNED loss of approximately AND75% or more of radiation monitor 2. Radiation monitor indications onindications for> 15 minutes. CP-180A andB.

AND AND

2. Either of the following: (a or b) 2. EITHER of the following: (a or b)

a. A SIGNIFICANT TRANSIENT is in a. A SIGNIFICANT TRANSIENT is inprogress. progress.

OR OR

b. Compensatory indications are b. Compensatory indications areunavailable. unavailable.

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Initiating Condition SS6

Current EAL Proposed EALInitiating Condition SS6 Initiating Condition SS6:..

Inability to monitor a SIGNIFICANT Inability to monitor a SIGNIFICANTTRANSIENT in progress TRANSIENT in progressOp. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4


Note: The Emergency Director should notwait until 15 minutes has elapsed, butshould declare the event as soon as it isdetermined that the condition hasexceeded, or will likely exceed 15minutes.

1. SIGNIFICANT TRANSIENT in 1. SIGNIFICANT TRANSIENT inprogress. progress.

AND AND2. EITHER of the following: (a or b)

2. a. Loss of approximately 75% or more a. Loss of approximately 75% or moreof UA annunciators. of UA annunciatorsfor > 15 minutes.

OR ORb. Loss of approximately 75% or more b. Loss of approximately 75% or more

of Main Control Board indications, of the following safety-related

OR indicationsfor > 15 minutes:

c. Loss of approximately 75% or more 1. Safety-related indications on the

of radiation monitor indications. Main Control Boards (MCBs)AND

2. Radiation monitor indicationson CP-180 A and B.

AND AND

3. Compensatory indications are 3. Compensatory indications areunavailable, unavailable.

AND AND4. Complete loss of the ability to monitor all 4. Complete loss of the ability to monitor all

Critical Safety Functions. Critical Safety Functions.

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3.0 TECHNICAL EVALUATION

The Seabrook Station emergency classification scheme is based on NEI 99-01,Methodology for Development of Emergency Action Levels, revision4 [Reference 1],which the NRC endorsed for use as guidance in developing or changing a standardemergency classification and action level scheme in Regulatory Issue Summary 2003-18[Reference 2].

On February 22, 2008, the NRC accepted NEI 99-01, revision 5, as providing anacceptable basis for making EAL changes [Reference 3]. Therefore, the changesproposed in this request have been evaluated using the latest approved guidance in NEI99-0 1, revision 5, which did not make significant changes to the EALs affected by theproposed changes.

This proposed change revises the EALs associated with initiating conditions SU3, SA4,and SS6. Initiating conditions SU3 and SA4 address an unplanned loss of safety systemannunciation or indication in the control room, and SS6 involves the inability to monitora significant event in progress. Attachment 1 provides a table that displays the EALs inNEI 99-01, revision 5, for these conditions; the current Seabrook Station EALs, and theproposed EALs.

Proposed change to include radiation monitors in aggregate of safety system indicators

Initiating conditions SU3, SA4, and SS6 in NEI 99-01 are concerned with a loss of theability to monitor changing plant conditions. Each of these initiating conditions containsan EAL that addresses a loss of greater than approximately 75% of the site specificcontrol room safety system indication for 15 minutes or longer. Seabrook'simplementation of this generic EAL established two separate EALs with an "or" logic,one for a loss of main control board indications and another for loss of radiation monitorindications. As a consequence, when evaluating SU3, the loss of greater than 75% of theradiation monitor indications in the control room would place the plant in an unusualevent. Similarly, a loss of greater than 75% of the radiation monitor indications in thecontrol room would meet the threshold for satisfying one attribute in the EAL logic forplacing the plant in an emergency classification under initiating conditions SA4 and SS6.

The declaration of an emergency based only on a loss of radiation monitor indications isoverly restrictive and inconsistent with the guidance in NEI 99-01. A loss of radiationmonitor indications by itself does not meet the threshold for placing the plant in anemergency classification level. This condition does not indicate potential degradation inplant safety that presents a threat to public health and safety or to plant workers. NEI 99-01 does not provide a separate EAL for loss of radiation monitor indications; rather, theEAL specifies a loss of control room safety system indications. Radiation monitors areonly one type of indicator included in the aggregate of control room safety system

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indications. Therefore, the proposed change revises the EAL so that the control roomsafety indications include the combination of main control board indicators and radiationmonitors.

The revised EALs provide more accurate and appropriate criteria for evaluating plantconditions for degradation in the level of safety. As a result,.the determination of.protective measures that would be considered within and outside the site boundary toprotect health and safety will more accurately reflect the threat posed by the plantconditions. The revised EALs will continue to protect the health and safety of the publicand plant personnel by initiating an emergency response commensurate with the extent ofdegradation of plant safety.

Proposed change to identify radiation monitors that function as safety system indications

The intent of initiating conditions SU3, SA4, and SS6 and their associated EALs is torecognize the difficulty associated with monitoring plant conditions following a loss of amajor portion of safety system indications. The EALs are concerned with safety systemindications; therefore, the radiation monitor indications involved with this EAL are thesafety-related monitors. The safety-related radiation monitors are displayed in theSeabrook control room on panels CP-180A and CP-180B. Accordingly, the proposedchange revises the EAL to specify that the radiation monitors of concern in this EAL arethe safety-related radiation monitors on CP-1 80A and CP-1 80B.

A developer note in the generic basis for the affected initiating conditions discusses thatthe site specific control room safety system indications must include those identified inthe abnormal operating procedures, emergency operating procedures, and in other EALs(e.g., area, process, and/or effluent radiation monitors, etc.). The initiating conditions,however, are concerned with "Safety System" indication. Safety-related systems arethose required to function to achieve the system responses assumed in the plant safetyevaluations and those needed to shut down the plant safely. Therefore, limiting theradiation monitoring instrumentation involved in these EALs to the safety relatedindications in the control room is consistent with the intent of the initiating condition,which is to address a loss of safety system indications

Proposed change to SS6 to add 15-minute duration for loss of indication

The proposed change to the EAL for SS6 adds a 15-minute duration for a loss of safetysystem annunciation or safety system indication. The current EAL does not specify aduration for the loss of indication, so the EAL is met immediately upon a loss ofannunciation or indication. Adding the 15-minute criterion provides a threshold toexclude a loss of annunciation or indication that is the result of a transient or momentarypower loss. This change is consistent with NEI 99-01, revision 5, which added the 15-minute criterion that was not included in revision 4.

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Provosed chanve to add note to EALs

The proposed change includes adding a note to the EALs for initiating conditions SU3,SA4, and SS6. The note states "The Emergency Director should not wait until 15minutes has elapsed, but should declare the event as soon as it is determined that thecondition has exceeded, or will likely exceed 15 minutes.'" The addition of this note isconsistent with the intent of NEI 99-01.

Differences and Deviations

Attachment 2 identifies differences and deviations between the proposed changes to theSeabrook EALs and the EALs in NEI 99-01. Regulatory Issue Summary (RIS) 2003-18,Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology forDevelopment of Emergency Action Levels," [Reference 4] defines differences anddeviations.

A difference is an EAL change where the basis scheme guidance differs inwording but agrees in meaning and intent, such that classification of an eventwould be the same, whether using the basis scheme guidance or the site-specificproposed EAL. Examples of differences include the use of site-specificterminology or administrative re-formatting of site-specific EALs.

A deviation is an EAL change where the basis scheme guidance differs in wordingand is altered in meaning or intent, such that classification of the event could bedifferent between the basis scheme guidance and the site-specific proposed EAL.Examples of deviations include the use of altered mode applicability, altering keywords or time limits, or changing words ofphysical reference (protected area,safety-related equipment, etc.).

Attachments 3 and 4 provide markups and clean copies of the EALs, respectively,showing the proposed changes. Markups and clean copies of the revised EAL technicalbasis are provide in Attachments 5 and 6, respectively.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

10 CFR 50.47 establishes the standards for offsite emergency response plans fornuclear power reactors. 10 CFR 50.47(b)(4) states "A standard emergencyclassification and action level scheme, the bases of which include facility systemand effluent parameters, is in use by the nuclear facility licensee, and State and

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local response plans call for reliance on information provided by facility licenseesfor determinations of minimum initial offsite response measures."

10 CFR 50, Appendix E, Section IV, Content of Emergency Plans, item B. 1,Assessment Actions, states "The means to be used for determining the magnitude

1of, and for continually assessing the impact.of, the.release..of.radioactive -materialsshall be described, including emergency action levels that are to be used ascriteria for determining the need for notification and participation of local andState agencies, the Commission, and other Federal agencies, and the emergencyaction levels that are to be used for determining when and what type of protectivemeasures should be considered within and outside the site boundary to protecthealth and safety. The emergency action levels shall be based on in-plantconditions and instrumentation in addition to onsite and offsite monitoring."

10 CFR 50.54, Conditions of licenses, paragraph (q)(4) states "The changes to alicensee's emergency plan that reduce the effectiveness of the plan as defined inparagraph (q)(1)(iv) of this section may not be implemented without priorapproval by the NRC. A licensee desiring to make such a change after February21, 2012 shall submit an application for an amendment to its license. In additionto the filing requirements of §§ 50.90 and 50.91, the request must include allemergency plan pages affected by that change and must be accompanied by aforwarding letter identifying the change, the reason for the change, and the basisfor concluding that the licensee's emergency plan, as revised, will continue tomeet the requirements in appendix E to this part and, for nuclear power reactorlicensees, the planning standards of § 50.47(b)."

Conclusion

Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans forNuclear Power Reactors [Reference 5], discusses that NRC approval could berequired for a change to the logic of an EAL that would result in a particular eventnot being declared when the declaration would have occurred before the change.The proposed changes will result in an event not being declared when thedeclaration would have occurred before the change. Therefore, the proposedchanges reduce the effectiveness of the emergency plan and require NRCapproval prior to implementation.

NextEra has determined that with the proposed changes, the emergency plan willcontinue to meet the requirements in 10 CFR 50, Appendix E, and the planningstandards of § 50.47(b). The proposed changes are consistent with NEI 99-01.The changecontains one variation from the developer note in the generic basisregarding the scope of radiation monitors that provide safety system indication.However, the scope of radiation monitors proposed for consideration in the EALsincludes the safety related radiation monitor indications in the control room,

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which addresses a loss of safety system indications consistent with the intent ofthe generic EALs.

'4.2 Significant Hazards Consideration

No Significant Hazards Consideration

In accordance with 10 CFR 50.92, NextEra Energy Seabrook has concluded thatthe proposed change does not involve a significant hazards consideration (SHC).The basis for the conclusion that the proposed change does not involve a SHC isas follows:

1. The proposed change does not involve a significant increase in the probabilityor consequences of an accident previously evaluated

The proposed changes to the Seabrook Station emergency plan do not impactthe physical function of plant structures, systems, or components (SSCs) orthe manner in which SSCs perform their design function. The proposedchanges neither adversely affect accident initiators or precursors, nor alterdesign assumptions. The proposed changes do not alter or prevent the abilityof operable SSCs to perform their intended function to mitigate theconsequences of an initiating event within assumed acceptance limits. Nooperating procedures or administrative controls that function to prevent ormitigate accidents are affected by the proposed changes.

Therefore, the proposed changes do not involve a significant increase in theprobability or consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or different kindof accident from any previously evaluated

The proposed changes will not impact the accident analysis. The changes donot involve a physical alteration of the plant (i.e., no new or different type ofequipment will be installed), a change in the method of plant operation, ornew operator actions. The proposed changes will not introduce failure modesthat could result in a new accident, and the change does not alter assumptionsmade in the safety analysis. The proposed changes revise emergency actionlevels (EAL), which establish the thresholds for placing the plant in anemergency classification. EALs are not initiators of any accidents.

Therefore, the proposed change does not create the possibility of a new ordifferent kind of accident from any accident previously evaluated.

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3. The proposed change does not involve a significant reduction in the margin ofsafety.

Margin of safety is associated with confidence in the ability of the fissionproduct barriers (i.e., fuel cladding, reactor coolant system pressure boundary,and containment structure) to. limit the level of radiation dose to. the public.The proposed changes are associated with the EALs and do not impactoperation of the plant or its response to transients or accidents. The changesdo not affect the Technical Specifications or the operating license. Theproposed changes do not involve a change in the method of plant operation,and no accident analyses will be affected by the proposed changes.Additionally, the proposed changes will not relax any criteria used to establishsafety limits and will not relax any safety system settings. The safety analysisacceptance criteria are not affected by these changes. The proposed changeswill not result in plant operation in a configuration outside the design basis.The proposed changes do not adversely affect systems that respond to safelyshutdown the plant and to maintain the plant in a safe shutdown condition.

The revised EALs provide more appropriate and accurate criteria fordetermining protective measures that should be considered within and outsidethe site boundary to protect health and safety. The emergency plan willcontinue to activate an emergency response commensurate with the extent ofdegradation of plant safety.

Therefore, the proposed changes do not involve a significant reduction in amargin of safety.

Based on the above, NextEra concludes that the proposed amendment does notinvolve a significant hazards consideration under the standards set forth in 10CFR 50.92(b), and, accordingly, a finding of "no significant hazardsconsideration" is justified.

4.3 Conclusions

Based on the considerations discussed above, (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in theproposed manner, (2) such activities will be conducted in compliance with theCommission's regulations, and (3) the issuance of the amendment will not beinimical to the common defense and security or to the health and safety of thepublic.

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5.0 ENVIRONMENTAL CONSIDERATION

NextEra has evaluated the proposed amendment for environmental considerations. Thereview has determined that the proposed amendment would change a requirement withrespect to installation or use of a facility component located within the restricted area, asdefined in 10 CFR 20, or would change an inspection or surveillance requirements.However, the proposed amendment does not involve (i) a significant hazardsconsideration, (ii) a significant change in the types or significant increase in the amountsof any effluent that may be released offsite, or (iii) a significant increase in individual orcumulative occupational radiation exposure. Accordingly, the proposed amendmentsmeet the eligibility criterion for categorical exclusion set for in 10 CFR 51.22(c)(9) and(10)(ii). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement orenvironmental assessment needs to be prepared in connection with the proposedamendment.

6.0 REFERENCES

1. NEI-99-01, Methodology for Development of Emergency Action Levels, revision 4,January 2003

2. Regulatory Issue Summary 2003-18, "Use of Nuclear Energy Institute (NEI) 99-01,Methodology for Development of Emergency Action Levels," Revision 4, DatedJanuary 2003; October 8, 2003

3. NRC letter "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI99-01, Revision 5, dated February 2008," February 22, 2008 (ADAMS accession No.ML 080430535)

4. Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy Institute(NEI) 99-01, Methodology for Development of Emergency Action Levels," Revision4, Dated January 2003

5. Regulatory Guide 1.219, "Guidance on Making Changes to Emergency Plans forNuclear Power Reactors," November 2011

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Attachment 1

Comparison of the EALs in NEI 99-01, revision 5; the current Seabrook EALs,And the proposed EALs

Attachment 1Comparison of the EALs in NEI 99-01, the current Seabrook EALs, and the proposed EALs

(Proposed changes to the Seabrook EAL are shown in bold italic type.)

Initiating Condition SU3

NEI 99-01, Rev. 5 Seabrook Procedure ER 1.1 - Current Seabrook Procedure ER 1.1 - Proposed

Initiating Condition SU3 Initiating Condition SU3 Initiating Condition SU3

UNPLANNED loss of safety system annunciation UNPLANNED loss of most or all safety system UNPLANNED loss of most or all safety systemor indication in the control room for 15 minutes or annunciation or indication in the Control Room for annunciation or indication in the Control Room forlonger. > 15 minutes > 15 minutesOp. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4

Emergency Action Level(s) Emergency Action Level(s) Emergency Action Level(s)Note: The Emergency Director should not wait Note: The Emergency Director should not wait

until the applicable time has elapsed, but until 15 minutes has elapsed, but shouldshould declare the event as soon as it is declare the event as soon as it isdetermined that the condition has exceeded, determined that the condition hasor will likely exceed, the applicable time. exceeded, or will likely exceed 15 minutes.

1. UNPLANNED loss of greater than 1. UNPLANNED loss of approximately 75% or 1. UNPLANNED loss of approximately 75% orapproximately 75% of the following for 15 more of UA annunciators for > 15 minutes. more of UA annunciators for > 15 minutes.minutes or longer:

a. (Site specific control room safety systemannunciation)

OR OR ORb. (Site specific control room safety system 2. UNPLANNED loss of approximately 75% or 2. UNPLANNED loss of approximately 75% or

indication) more of Main Control Board indications for > more of the following safety-related15 minutes. indications for > 15 minutes:

c. Safety-related indications on the MainControl Boards (MCBs)

ANDd. Radiation monitor indications on CP-

180 A and B.

OR

3. UNPLANNED loss of approximately 75% ormore of radiation monitor indications for > 15minutes.

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Initiatinq Condition SA4


Initiating Condition SA4 Initiating Condition SA4 Initiating Condition SA4

UNPLANNED Loss of safety system annunciation UNPLANNED loss of most or all safety system UNPLANNED loss of most or all safety systemor indication in the control room with EITHER (1) a annunciation or indication in Control Room with annunciation or indication in Control Room withSIGNIFICANT TRANSIENT in progress, or (2) either (1) a SIGNIFICANT TRANSIENT in either (1) a SIGNIFICANT TRANSIENT incompensatory indicators unavailable, progress, or (2) compensatory indicators are progress, or (2) compensatory indicators areOp. Modes: 1, 2, 3, 4 unavailable unavailable

Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4

Emergency Action Level(s) Emergency Action Level(s) Emergency Action Level(s)

Note: The Emergency Director should not wait Note: The Emergency Director should not waituntil the applicable time has elapsed, but until 15 minutes has elapsed, butshould declare the event as soon as it is should declare the event as soon as itdetermined that the condition has is determined that the condition hasexceeded, or will likely exceed, the exceeded, or will likely exceed 15applicable time. minutes.

1. a. UNPLANNED loss of greater than 1. EITHER of the following: (a orb)approximately 75% of the following for 15minutes or longer:

* (Site specific control room safety 1. a. UNPLANNED loss of approximately 75% a. UNPLANNED loss of approximately 75%system annunciation) or more of UA annunciators for > 15 or more of UA annunciators for > 15

minutes. minutes.

OR OR OR

* (Site specific control room safety b. UNPLANNED loss of approximately 75% b. UNPLANNED loss of approximately 75%system indication or more of Main Control Board indications or more of the following safety-related

for > 15 minutes. indications for > 15 minutes:OR 1. Safety-related indications on the

Main Control Boards (MCBs)c. UNPLANNED loss of approximately 75% AND

or more of radiation monitor indications for 2. Radiation monitor indications on> 15 minutes. CP-180 A and B.

AND AND

b. EITHER of the following: 2. Either of the following: (a or b) 2. EITHER of the following: (a or b)

2



" A SIGNIFICANT TRANSIENT is in a. A SIGNIFICANT TRANSIENT is in a. A SIGNIFICANT TRANSIENT is inprogress. progress. progress.

" Compensatory indications are OR ORunavailable

b. Compensatory indications are b. Compensatory indications areunavailable, unavailable.



Initiating Condition SS6 Initiating Condition SS6 Initiating Condition SS6

Inability to Monitor a SIGNIFICANT TRANSIENT Inability to monitor a SIGNIFICANT TRANSIENT Inability to monitor a SIGNIFICANT TRANSIENTin Progress. in progress in progressOp. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4

Emergency Action Level(s) Emergency Action Level(s) Emergency Action Level(s)

Note: The Emergency Director should not wait Note: The Emergency Director should not waituntil the applicable time has elapsed, but until 15 minutes has elapsed, butshould declare the event as soon as it is should declare the event as soon as itdetermined that the condition has is determined that the condition hasexceeded, or will likely exceed, the exceeded, or will likely exceed 15applicable time. minutes.

1. a. Loss of greater than approximately 75% of 1. SIGNIFICANT TRANSIENT in progress. 1. SIGNIFICANT TRANSIENT in progress.the following for 15 minutes or longer: AND AND

2. EITHER of the following: (a or b)* (Site specific control room safety 2. a. Loss of approximately 75% or more of a. Loss of approximately 75% or more of

system annunciation) UA annunciators. UA annunciators for> 15 minutes.

OR OR ORb. Loss of approximately 75% or more of b. Loss of approximately 75% or more of

" (Site specific safety system Main Control Board indications, the following safety-related indicationsindication) OR for > 15 minutes:

c. Loss of approximately 75% or more of 1. Safety-related indications on the

radiation monitor indications. Main Control Boards (MCBs)AND

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2. Radiation monitor indications onCP-180 A and B.

AND AND AND

b. A SIGNIFICANT TRANSIENT is in 3. Compensatory indications are unavailable. 3. Compensatory indications are unavailable.progress.

AND AND ANDc Compensatory indications are unavailable. 4. Complete loss of the ability to monitor all 4. Complete loss of the ability to monitor all

Critical Safety Functions. Critical Safety Functions.

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Attachment 2

Differences and Deviations

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Attachment 2Differences and Deviations

Initiatinq Condition SU3

NEI 99-01, Rev. 5 Seabrook Procedure ER 1.1 - Proposed Differences and Deviationschanges are shown in bold italic type

Initiating Condition SU3 Initiating Condition SU3UNPLANNED loss of safety system UNPLANNED loss of most or all safety Note: Differences and deviations between NEI 99-01 and theannunciation or indication in the control system annunciation or indication in the Seabrook proposed changes are discussed below. Proposedroom for 15 minutes or longer. Control Room for > 15 minutes changes to the Seabrook EALs are shown in bold italic type.Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4

Emergency Action Level(s) Emergency Action Level(s)Note: The Emergency Director should Note: The Emergency Director should not Difference

not wait until the applicable time has wait until 15 minutes has elapsed,elapsed, but should declare the but should declare the event as The Seabrook-specific EAL replaces "the applicable time" used inevent as soon as it is determined soon as it is determined that the NEI 99-01 with "15 minutes." This difference only adds specificitythat the condition has exceeded, or condition has exceeded, or will to the note and is consistent with the intent of the generic EAL.will likely exceed, the applicable likely exceed 15 minutes.time. Deviation

None1. UNPLANNED loss of greater than 1. UNPLANNED loss of approximately 75%

approximately 75% of the following or more of UA annunciators for > 15for 15 minutes or longer: minutes.

a. (Site specific control room safety (No change to current EAL)system annunciation)

OR OR

b. (Site specific control room safety 2. UNPLANNED loss of approximately Differencesystem indication) 75% or more of the following safety-

related indications for > 15 minutes: The Seabrook-specific EAL identifies the site specific controle. Safety-related indications on the room safety indications for the generic EAL in NEI 99-01. Safety

Main Control Boards (MCBs) system indication includes the safety-related indications on theAND main control board and the safety-related radiation monitor

f Radiation monitor indications on indications in the control room, which are located on controlCP-180 A and B. panels CP-180A and CP-180B. This difference from the generic

EAL adds site-specific instrumentation to the EAL and isconsistent with the intent of NEI 99-01.

I


Although not part of the basis, the generic basis for this initiatingcondition includes a developer note, which discusses that the sitespecific indicators for this EAL must include those identified in theabnormal operating procedures, emergency operatingprocedures, and in other EALs (e.g., area, process, and/oreffluent radiation monitors, etc.). The initiating condition,however, is concerned with "Safety System" indication. Safety-related systems are those required to function to achieve thesystem responses assumed in the plant safety evaluations andthose needed to shutdown the plant safely. Therefore, limitingthe instrumentation involved in this EAL to the safety relatedindications in the control room is consistent with the intent of theinitiating condition, which is to address a loss of safety systemindications. This variation from the developer note does not alterthe intent of the EAL.

Deviation

None

2


Initiating Condition SA4


Initiating Condition SA4 Initiating Condition SA4Note: Differences and deviations between NEI 99-01 and the

UNPLANNED Loss of Safety System UNPLANNED loss of most or all safety Seabrook proposed changes are discussed below. ProposedAnnunciation or Indication in the Control system annunciation or indication in Control changeskoptheosebrooknEAs are showned bold ictpe.

Room With Either (1) a SIGNIFICANT Room with either (1) a SIGNIFICANT changes to the Seabrook EALs are shown in bold italic type.

TRANSIENT in Progress, or (2) TRANSIENT in progress, or (2)Compensatory Indicators Unavailable. compensatory indicators are unavailableOp. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4


Note: The Emergency Director should Note: The Emergency Director should not Differencenot wait until the applicable time has wait until 15 minutes has elapsed,elapsed, but should declare the but should declare the event as The Seabrook-specific EAL replaces "the applicable time" used inevent as soon as it is determined soon as it is determined that the NEI 99-01 with "15 minutes." This difference only adds specificitythat the condition has exceeded, or condition has exceeded, or will to the note and is consistent with the intent of the generic EAL.will likely exceed, the applicable likely exceed 15 minutes.time. Deviation

None1. a. UNPLANNED loss of greater than 1. EITHER of the following: (a orb) Difference

approximately 75% of thefollowing for 15 minutes or longer: The Seabrook-specific EAL uses a format different from that in

NEI 99-01. This administrative re-formatting is a difference fromthe generic EAL that does not alter the initiating condition, EAL,or logic scheme.

* (Site specific control room a. UNPLANNED loss of approximatelysafety system annunciation) 75% or more of UA annunciators for (No 'change to current EAL)

> 15 minutes.

OR OR

3


(Site specific control roomsafety system indication

b. UNPLANNED loss of approximately75% or more of the followingsafety-related indications for> 15minutes:1. Safety-related indications on

the Main Control Boards(MCBs)

AND2. Radiation monitor indications

on CP-180 A and B

Difference

The Seabrook-specific EAL identifies the site specific controlroom safety indications for the generic EAL in NEI 99-01. Safetysystem indication includes the safety-related indications on themain control board and the safety-related radiation monitorindications in the control room, which are located on controlpanels CP-180A and CP-180B. This difference from the genericEAL adds site-specific instrumentation to the EAL and isconsistent with the intent of NEI 99-01.


Deviation

None

AND

b. EITHER of the following: 2. EITHER of the following: (a or b)(No change to current EAL)" A SIGNIFICANT

TRANSIENT is in progress." Compensatory indications

are unavailable.

a. A SIGNIFICANT TRANSIENT is inprogress.

OR

b. Compensatory indications areunavailable.

4




Initiating Condition SS6 Initiating Condition SS6

Inability to Monitor a SIGNIFICANT Inability to monitor a SIGNIFICANT Note: Differences and deviations between NEI 99-01 and theTRANSIENT in Progress. TRANSIENT in progress Seabrook proposed changes are discussed below. ProposedOp. ModesN 1, Z 3, 4 Op. Modes: 1, Z 3, 4 changes to the Seabrook EALs are shown in bold italic type.


Note: The Emergency Director should Note: The Emergency Director should not Differencenot wait until the applicable time has wait until 15 minutes has elapsed,elapsed, but should declare the but should declare the event as The Seabrook-specific EAL replaces "the applicable time" used inevent as soon as it is determined soon as it is determined that the NEI 99-01 with "15 minutes." This difference only adds specificitythat the condition has exceeded, or condition has exceeded, or will to the note and is consistent with the intent of the generic EAL.will likely exceed, the applicable likely exceed 15 minutes.time. Deviation

None1. a. Loss of greater than 1. SIGNIFICANT TRANSIENT in

approximately 75% of the progress. (No change to current EAL)following for 15 minutes or ANDlonger: 2. EITHER of the following: (a or b) Difference

(Site specific control room a. Loss of approximately 75% ormore of UA annunciators for > The Seabrook-specific EAL uses a format different from that in15minutes. NEI 99-01. This administrative re-formatting is a difference from

the generic EAL that does not alter the initiating condition, EAL,or logic scheme.

OR OR

5


* (Site specific safety systemindication)

b. Loss of approximately 75% ormore of the following safety-related indications for> 15minutes:1. Safety-related indications

on the Main Control Boards(MCBs)

AND2. Radiation monitor

indications on CP-180 A andB.

Difference

The Seabrook-specific EAL identifies the site specific controlroom safety indications for the generic EAL in NEI 99-01. Safetysystem indication includes the safety-related indications on themain control board and the safety-related radiation monitorindications in the E0fitrol room, which are located on controlpanels CP-180A and CP-180B. This difference from the genericEAL adds site-specific instrumentation to the EAL and isconsistent with the intent of NEI 99-01.


Deviation

NoneAND AND

b. A SIGNIFICANT TRANSIENT is 3. Compensatory indications arein progress. unavailable.

AND AND (NO change to current EAL)c Compensatory indications are 4. Complete loss of the ability to monitor

unavailable, all Critical Safety Functions.

6

Attachment 3

Marked up Copy of EALs

ER 1.1 Page43Rev. 50

Figure 1

Initiating Conditions and Emergency Action Levels

SYSTEM MALFUNCTION

Initiating Condition -- UNUSUAL EVENT

UNPLANNED loss of most or all safety system annunciation or indication in the Control Roomfor > 15 minutes

Operating Mode Applicability: 1, 2, 3 and 4

Emergency Action Levels:

Note: The Emergency Director should not wait until 15 minutes has elapsed, but should declare theevent as soon as it is determined that the condition has exceeded, or will likely exceed 15minutes.

1. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15 minutes.

** OR **

2. UNPLANNED loss of approximately 75% or more of Main Control Bard thefollowing safety-related indications for > 15 minutes.

a. Safety-related indications on the Main Control Boards (MCBs)

AND

b. Radiation monitor indications on CP-180 A and B.

3. UNPLANNED les of approximately 750% or more of radiaton monitor- indieations for > 15

ER 1.1 Page 49Rev. 50

Figure 1Initiating Conditions and Emergency Action Levels

SYSTEM MALFUNCTION

Initiating Condition -- ALERT

UNPLANNED loss of most or all safety system annunciation or indication in Control Room witheither (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators areunavailable




1. EITHER of thefollowing: (a or b)

a. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15 minutes.

OR

b. UNPLANNED loss of approximately 75% or more of Main Control Board the followingsafety-related indications for > 15 minutes:

1. Safety-related indications on the Main Control Boards (MCBs)

AND

2. Radiation monitor indications on CP-180 A and B.

OR

-- T ThTTbT A xThTI•T'• ! ---- ~ '*7~*fl/c. U1NrL2AIT-rJ1u" tos1o approximately -""~ or- mere et raitatatn momiter inuietattans iorf -2

AND

2. Either of the following: (a or b)

a. A SIGNIFICANT TRANSIENT is in progress.

OR



b. Compensatory indications are unavailable.

NOTE

SIGNIFICANT TRANSIENT is an UNPLANNED event involving one or more of thefollowing: (1) automatic turbine runback >25% thermal reactor power, (2) electrical loadrejection >25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5)thermal power oscillations >10%



SYSTEM MALFUNCTION

Initiating Condition -- SITE AREA EMERGENCY

Inability to monitor a SIGNIFICANT TRANSIENT in progress




1. SIGNIFICANT TRANSIENT in progress.

AND

2. Either of thefollowing: (a or b)

a. Loss of approximately 75% or more of UA annunciatorsfor > 15 minutes..

OR

b. Loss of approximately 75% or more of Main Control Board the following safety-relatedindications for > 15 minutes:


AND


OR

G. Less of approeximately 75,0% or- mor-e of radiation monitor indications.

AND

3. Compensatory indications are unavailable.



AND

4. Complete loss of the ability to monitor all Critical Safety Functions.

NOTE

SIGNIFICANT TRANSIENT is an UNPLANNED event involving one or more of thefollowing: (1) automatic turbine runback >25% thermal reactor power, (2) electrical loadrejection >25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5)thermal power oscillations >10%

Attachment 4

Clean Copy of EALs

ER 1.1 Page43

Rev. 50


SYSTEM MALFUNCTION


UNPLANNED loss of most or all safety system annunciation or indication in the Control Roomfor > 15 minutes



Note: The Emergency Director should not wait until 15 minutes has elapsed, but should declare theevent as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.


** OR **

2. UNPLANNED loss of approximately 75% or more of the following safety-related indications for >15 minutes.


AND


ER 1.1 Page49Rev. 50


SYSTEM MALFUNCTION


UNPLANNED loss of most or all safety system annunciation or indication in Control Room witheither (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators areunavailable




I1. EITHER of the following: (a or b)

a. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15 minutes.

OR

b. UNPLANNED loss of approximately 75% or more of the following safety-related indicationsfor > 15 minutes-


AND


AND



OR




NOTE

SIGNIFICANT TRANSIENT is an UNPLANNED event involving one or more of thefollowing: (1) automatic turbine runback >25% thermal reactor power, (2)- electrical loadrejection >25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5)thermal power oscillations >10%



SYSTEM MALFUNCTION

Initiating Condition-- SITE AREA EMERGENCY-






AND


a. Loss of approximately 75% or more of UA annunciators for > 15 minutes..

OR

b. Loss of approximately 75% or more of the following safety-related indications for > 15minutes:


AND


AND


AND




NOTE

SIGNIFICANT TRANSIENT is an UNPLANNED event involving one or more of thefollowing: (1) automatic turbine runback >25% thermal reactor power, (2) electrical loadrejection >.25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5)thermal power oscillations >10%

Attachment 5

Marked up Copy of EAL Technical Basis

0

EALDBD Rev. 32

SYSTEM MALFUNCTION


UNPLANNED loss of most or all safety system annunciation-or indication in the ControlRoom for > 15 minutes



Note: The Emergency Director should not wait until 15 minutes has elapsed, but shoulddeclare the event as soon as it is determined that the condition has exceeded, orwill likely exceed 15 minutes.


** OR **

2. UNPLANNED loss of approximately 75% or more of Main Control Board the followingsafety-related indications for > 15 minutes.


AND

b. Radiation monitor indications on CP-180 A and B.** OR **

TThTTbT A~.TNTr'Th ~ C .. .. •*. . .• - _ - - --/. . . . . . JO Jl *_*= -

UI4.LUWg.L ioi- 0: approima-telv 7;z!5ý ormore of- rudiation monitor- ineteatuons for15 minutes.

Basis:

This IC and its associated EAL are intended to recognize the difficulty associated withmonitoring changing plant conditions without the use of a major portion of the annunciation orindication equipment. Recognition of the availability of computer based indication equipment isconsidered (e.g., SPDS, plant computer, etc.).

"Planned" loss of annunciators or indicators includes scheduled maintenance andtesting activities.

The UA annunciators assist the operator in determining the cause of a reactor trip or safetyinjection. A following set of essential parameters is also monitored.

" Reactor Trip Signals" ESF Actuation Signals

Page 109 04/09/12

EALDBD Rev. 32

" Certain Technical Specification Deviations" Important Systems

It is estimated that if approximately 75% of the safety system annunciators or indicators arelost, there is an increased risk that a degraded plant condition could go undetected. It is notintended that plant personnel perform a detailed count of the instrumentation lost but use thevalue as a judgment threshold for determining the severity of the plant conditions.

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, anddefueled modes, no IC is indicated during these modes of operation.

It is recognized that most plant designs provide redundant safety system indication poweredfrom separate uninterruptable power supplies. While failure of a large portion of annunciators ismore likely than a failure of a large portion of indications, the concern is included in this EALdue 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 componentoperability status. This will be addressed by the specific Technical Specification. The initiationof a Technical Specification imposed plant shutdown related to the instrument loss will bereported via 10 CFR50.72. If the shutdown is not in compliance with the Technical Specificationaction, the Unusual Event is based on SU2.

DiisGussmon on RDMS Indications and the "76%" limit

This section documents the numerical basis for the following statement.

.- ,If both RDMVS (VA X) hot computers are simultaneously lo. t removing radiation monitordisplay availability to both CP295 and the Main Plant computer,AD

2. At least 19 radiation monitor channels in Attachment B to AOP OS1252.04 are available,THEN

3. The number of lost radiate•n monitoring indic a•i•onis 7.5%, AND4. An Unusual Event declaration is•ROt required.

See the basis for Initiating Condition SM;A. fo-r a discuss6ion Of compensator,' measures to takeninth.eet that lost indications meet orF excGeed 75%.

Assumptions and Limitations:

" The scope of this assessment includes radiation monitorF indications, available in thoControl Room, from detectors located within seismic Category Istructures and/or atmRonitored effluent points. Indications from radiation monitors inthe AdministrationBuildin wee eXcluded to be consistent with NEI 99 01 guidance (i.e., limit to in plant

montor).In addition, Administration Building monitors are not relied upon to assesreactor operation or nuclear safety.

" The seetdmonitor indications must be tho-se that would be assessed during theperformance of AOPs and EOPs, and emergency action levels.

" Radiation monitors that are not routinely available in Modes 1, 2, 3 and 4 (i.e., they arcbrough in sR.'e during Modes 5 o-r 6) were not included in this aseset since this

Initiating Condition is applicable in Modes 1 through 4 only" Boeth RIDIVS (VAX) host comnputers fail at the same time; monto iniatosnC 295

Page 110 04/09/12

EALDBD Rev. 32

and the MPCS are simultaneously lost." The idicGatiens on the safety related Control Panels CP R8A and GP 180B r

available." The RM 6550 indication On the Control Room stanchioG near OP-295 remains available." All RM 80s in the feld, aRnd the associated local readouts, remain available.

Firs~t, determine the total ml-numbr of radiation mnontoridcain using the above assumptionSand limitations.

SArea Radiation Monitor indications - 30- Process Radiation Monitor indications - 20" Airborne Radiation MonR11itor • indications - 25 [Note that RM 6528 is counted I times since

this point simply displays the coretlmid/hi indication from RM 6528 1, 2 and 3.]

The total number of idctos-30 + 20 + 25 -47-5

Operations provided input that the following mnientor indications are not referenced in EOPS or

A;Ps. EP verfi•ed that these monitors are not necessary for evaluation of EALs.

* RM 6568 1, Norm (ED "A" RM 6566 1, E~mergency CEVASRM6531 1, PB Gas

Ajusting the total number fo1 these mnitors yields 75 3•I-7-2

e Iitiating Condition SUI, an emergency declaration ma be required flost RDA S Aindications meet or eXceed approximately 75%. Therefore, the number of available andcompensator' indications should be apprimtely 26% or more of the total indications.

The l total Of indications necessary is 72*0.26 18.72; round to 1n-9 indicaivtionRs needed.

The following 22 monitor indications f. lP 190A, GP 18 OB, and RM6550 On the stanchioq

near GP 295 ma" be counted towards this requirement

*Area Radiation Monitor indicationse RM 6576 A and RM 6576 Be R M R M 6-550Q

* AiborFne Radiation Monitor niain" RK 6548 displays 1 channel RM 6548 A!" RK 6506A displays 2 channels RM 6506 ,A! and A2

oRK 6507A displays 2 c-hannels RM 6507 Al and A2" RK 6506B displays 2 channels RM-6506 B! an B2" RK 6507B displays 2 channels RM 6507 B! and B2" RK 6526 displays RM-6526 1 and 2" RK 6527A displays 2 channels RM 6527 ,A! and A2" RK 6527B displays 2 channels RM 6527 BI and B2" RK 6528 displays 4 channels RM 6528 1, RM 6528 2, RM 6528 3, and RM 6528-4,

If less thanp 19 of the 22 indications listed are operable, than an Unusual Evenmt dec-laration is

requiwed.

Page 111 04/09/12

EALDBD Rev. 32

The following table can be used to tabulate the total number of available radiation monitorindications for any given failure or set of failures. AS noted above, the required total i 9

Page 112 04/09/12

EALDBD Rev. 32

Table of Radiation Monitors

A bale # INSTRUMENT C-HANlI DESCRIPTION LOCATIDN

1 RKR6506 A 4- CR East Air Intake 1 RM GP 180-A

2 1-RK-6506-A 2 CR East Air Intake 1 RM GP 1

3 1•RK 657-A- 4 Re+tAr Int+ak-e -1 RM OP 180A

4 4-RK-6507- A 2 CR West Air Intake 1 RM OP 180-A

5 RM RK 65761- Cont Hi Range Rad 1-RM O- P 180 A

6 .1-RK 6527 A 4- Gent Bl!dg Purge Line 1 RM OP 180 -A.7 RK 6527-A -2 Cent Bldg Purge Line 1 RM OP 180 A

8 _RK 6526 1 Cant Par-tiUiate 1 RM OP 180 A

g 1 R- 6526 GCent Gas 1RMGP180A

4o 1 RK 6548 Cant Gas Back-up 1-RM OP 180.4A

44 1 RK 6528 ow .Range Plant Vent WR Gas 1 RM GP1 A

421 RK 6528 22 Mid Range (Note!) Plant Vent WR Gas 1 RM GP 180A

!-RK 6528 3 High Range (Note!) Plant Vent WR Gas 1 RM OP 180A

-1-4 !RK-6528-4 EffluentI-eave Plant Vent WVR Gas 1-RM OP 180 A

.1 -RK 6506•4 1- CR East Air Intake 1-RM GP 180 B

-1-6 1 RK 6506 2 OR East Air Intake 1_RM OP 180 B

4-7 1!RK 6507-R 4- CR West Air Intake 1-RM OP 180 B

1 -RK 6507 B 2 CR West Air intake 1-RM CP 18B

49 1 RI "65776B 4 G1nt Hi Range Rad 1 RM OP 180 B

2o 4 RK 6527 B 4 Cant Bldg Purge Line 1 RM OP 180 B

24 1- RK 6527-B 2 Cant Bldg Purge Line 1 RM OP 180 B

22 RM RM-6550 GR-AFea Stanchian near______PP225

T.Note 1:/f W ,,w ,aneg mo.it.r is op. rabe, "M 6526- 2 mid r; nge and gMi6528 3 hig ran go is assumed to be operable so green (opeF) LED light i

_ not -app~akea.

,L ---- ='--• ,L L--...... JL .....

An Unusuail •event can be e.aated to an • .e,• t via i W vif ir orn pelnsatery auo• n cGainn BetakeR Within 15 minutes Of maniRtar lass 9F a transient sinpragress during the lass af

; +; ; A; +;• v

•nRHHYFIG cl "m Rr- ri 160 Ofi-.

Page 113 04/09/12

EALDBD Rev. 32

Reference: Attachment B to OS1252.04, Fai!ure of RDMS Computer or Control RoomRadiation Mon•"ito.r Display. UFSAR section 7.5, Safety-Related DisplayInstrumentation

Page 114 04/09/12

EALDBD Rev. 32

SYSTEM MALFUNCTION


UNPLANNED loss of most or all safety system annunciation or indication in Control Roomwith either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicatorsare unavailable




1. EITHER of the following: (a or b)

a. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15minutes.

OR

b. UNPLANNED loss of approximately 75% or more of Main Control Board thefollowing safety-related indications for > 15 minutes-


AND


OR

e. LJ1sPLAN'NED lesof fappr-afor-> 15 mninutes.

•XEimately 750% ormore of r-adiation monitor- n 4iA-4 A".4

AND



OR


Basis:

Page 120 04/09/12

EALDBD Rev. 32

This IC and its associated EAL are intended to recognize the difficulty associated withmonitoring changing plant conditions without the use of a major portion of the annunciation orindication equipment during a transient. Recognition of the availability of computer basedindication equipment is considered (e.g., SPDS, plant computer, etc.).

"Planned" loss of annunciators or indicators includes scheduled maintenance and testingactivities..



" Reactor Trip Signals" ESF Actuation Signals" Certain Technical Specification Deviations" Important Systems

It is recognized that most plant designs provide redundant safety system indication poweredfrom separate uninterruptable power supplies. While failure of a large portion of annunciators ismore likely than a failure of a large portion of indications, the concern is included in this EALdue 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 componentoperability status. This will be addressed by the specific Technical Specification. The initiationof a Technical Specification imposed plant shutdown related to the instrument loss will bereported via 10 CFR 50.72. If the shutdown is not in compliance with the TechnicalSpecification action, the Unusual Event is based on SU2.

"Compensatory indications" in this context includes computer-based information such as theVideo Alarm System (VAS), Safety Parameter Display System (SPDS), etc. If both a majorportion of the annunciation system and all computer monitoring are unavailable, the Alert isrequired. it respect to radiati•on monito indications, compensatory SOUrces of data are otherRDMS consoles located outside the Control Room. Use of these consoles as a comnpensatorymeasure may require assigning dedicated cOm•muc•ators to relay information to the ControlReemn.

Compensator; actions for a significant loss of radiation moniRtor indications are specified inAttachment C of Procedure OS1252.0h. Implementation of these c.Mpe.satey' ac•tinS within15 minutes9 06 su1fficient may preclude an Alert declaration based On SA4.

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 anddefueled modes, no IC is indicated during these modes of operation.

Dais•ussein on RDMS Cmnensator': Measures and the "75%" limit

Page 121 04/09/12

EALDBD Rev. 32

Thai sIection documents the numerical basis foF the 'OMpeRsator. actioRn preseRte inProcedu--re 0S1 252.04, Fmailure of RDMS Computer or Control Room-F Radiation Moni~tor Display.These actionRS may be implemented in response to the loss of a signifficant number of RDMSindications i" nR the Control Room. More spe•ifi•ally, timely implementation of these actions willobviate the need fr a.n Aler declaration since the "approximately 75% o/r more." EAI criterion

Page 122 04/09/12

EALDBD Rev. 32

AssumWtions and Limitations:

" The .cope of this assessment includes radiation monitor indiations, available On theControl Room, from dctectorFs located within seismic Categor,' I structur~es and/or atmonitored effluent points. Indications. from radiation monitorFs in the Administration

Building were excluided to be consistent with NEI 99 01 guidance (i.e., limit to in plantnoniRrGs). In addition, Admnifstration Building monit•r ae not.Frelied upon to assessreactor operation Or nuclear safety.

" The selected mon)itorF indicatio)S ns mut be those that would be assessed dupring hepen rnmaRne of AOP a•nd EDPs, and ermergency aGt•on levels.i RadiatonR monitors that are not rou1tinely available in Modes 1, 2, 3 and i (i.e., they are1brought in serAce duFring Modes 5 or 6) were not included in this assessmnent sine thiSInitiating Gondliion is appliGable i Modes n i iv;I through i oliylE3GtH MLPa HS IIU G UUfp~iiU1~ fil at te sam trie; rAGITOriw IRGIuaIcGRw OR up 4oand the MPCS are simul1taneously lost-

*The ind-ica-;tionsm on the safety related Control Pane-ls C-Pl R- QA. and GP 1 808 remnainavafiable

*The RM 6550 indication on the Control ROOM stanchion near GP 295 remafins available.*All RM 80s in the field, and the assocGiated local readouts, remain available.

First, dete~rmine the total number of radiation monitor indicationsG using the above assumptionsand limitations.

" Area Radiation MonitorF indications - 30" Process Radiation Moni~tor indications - 2-0" Airborne Radiation Moni~tor indications - 25 [Note that RM 6528 is coun~ted 4 tim~es since

this point simply displays the Gcorrect le/mid/hi indication fromF RM 6528 1, 2 and 3.].

The total numoer of InuicationS - Au +~ zzW *s Z /:)

O~perations provided input that the fcG~l~ wingmontorindcatonsare not referenc ?d OnEQPs oF0. vl=r- V cl Con r"Wri WrIco C11-0 ri" rir"ýýOocjt-r "-Apý I 1ý "" " N

0 RDA 6568 1, Normal CE.A_ R 6566 1, E.mergency CEVA

RM 6531 1, WPB Gas

Adj6,,,qtgI I J I I II *l

the total num-mer mtor thlese mnonitors yieldis 75 -3 -7

Perz Ini~tiating Condition SM4, an emergency declaration mnay be requirFed if lost RDMSindications meet or exceed approximately 75%. Therefore, the number of available andcomnpensator; indications should be aprxmtely 26% Or mor~e of the total indications.

The total num~ber of . I= I=inaiations necessary is 72 * .26 - 18.72 F~ ound to 19 indIcGations, needed.

Page 123 04/09/12

EALDBD Rev. 32

The followinOg 22 monRitorinictin fromF GP 180A, GP 180B, and RM6550 On the stanchionnear GP 295 mna" be counted towards this requiremnent:

. Area Radiat-in Moni÷tor indication,

" RM 6576 A and RM 6576 B" RM RM 6550)

" Airborne Radiation Monitor indications_E) RK 65418 displays 1 channel RM 65418 -A!" RK 6506A displays 2 channels RM 6506 Al andA2" RK 6507A displays 2 channels RM 6507 Al and A2" RK 6506B displays 2 channels RM 6506 B! and B2

oRK 6507B3 displays 2 channels RM -6507-81 and EB2" RK 6526 displays RM 6526 1 and-2" RK 6527A displays 2 channels RM 6527 Al and A2" RK 6527B displays 2 channelrs RM 6527 B1 and EB2" RK 6528 displays 4 hnnl RNA 6528 1, RM-6528 2, RMA 6528 3, and R 581

In other words, if 19 of 22 indications in the Control Room are available, no specificcomipensator' measures !r eurd to preclude an Alert declaration.

If less than; 19 of the radiation monEitor indications listed are NOT inOPERATE STATUS, thenAttachment G to G, 1252.04, Failurep of RDAS• 4S; Computer or Co.ntrol Room Radiation MonitorDis~play identifies additional local idton s asneet ?opnsate for the loss of an"fradiation mo•nRito indications dropping the co.int below 19, On a one for one basis.

WIth respect to tiFmni for implementation Of coIpensator' measures, note that EAL 1.G states,"UNPLANNED loss of approximately 75% or more of radiation monitor indications for 15miRutes." EAL 2.b states, "ComrpeRsatr,' iRdiGations are u navailable. " IR other words, ar Aler,i s required if 1 5 Minutes elapses after an UNPLANNED loss of approximately 75% Or more ofradiation mon..ito indications, and there a. e no compensator' indications available (sufficient to

get below the 75% riterion). For this reasn, the compensator' measures presented091252.04 should be implemented within 15 minutes of the loss of both RDMS host

The follo)wing table can be used to tabulate the total number of available radiation monitorindications for any given failure or set of failuires. As noted above, the required total i 9

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EALDBD Rev. 32

Table of Radiation Mon tors

Available # INSTRUMENT GHANNE-L- DESCRIPTION LOCATION

4- RK-6506-A 4- CR East Air Intake I RM GP 180 A

2 1 RK 6506 A 2 CR East Air Intake 1 RM CP 180A,

3 1 RK 67A 4 GR West Air ntake 1 RM--P8-A

4 1-RK-6507-A 2 CR West Air Intake 1 RMCP8O

5 RM RK 6576 A ,,ont Hi Rage Rad 1-RM GP 180 A

6 4 ,6527 A 4- C ,nt Bldg Purge Line 1-RM OP 180- -

7 1 RK-6527-A 2 Cant Bl!dg Purge Line 1 RM OP 18A

I 1RK-6.5264 Cent Pa~icuate 1 RM OP 18A

1-RK 6526 ! GRMP 8OA.

g 1 RK•6"548 Cent Gas Bakup

- 1-RK 654 LowRaRge Plant Vent W.R Gas 1 RM GP-180 A

- 1-RK-65282- Mod Range (Nate!) Plant Vent VVR Gas

_1Z RK 652.8 3 High Range (Nate!) Plant Vent WVR Gas I RM G. 180

44 4 RK-65ffueR Leve4 Plant Vent WR Gas 1 RM CP 180 A

1•-RK- 6506B 4- CR East Air Intake 1 RM GP 180 B

4-6 1 •K-•5 2 CR East Air Wntake 1 RM CP 180 B

4-7 I RK-6507 B 4 CR West Air intake 1 RM CP 80 B

4- 4-RK 6507-B 2 CR WestAir Intake I-RM OP 180 B

4- 1-RK 6576 B 4 Cant Hi RaRnge Rad 1 RM CP 180 B

2-1 RK 6527 B 4 Cant Bl•dg Purge Line 1 1RM GP 1 B

24 1 RK 65 2 Cant Bldg Purge Line 1 RM CP1 180 B

22 RM-RM 6550 GR-AFea Stanchian nea

TtNote 1., if WRGM low ran go mn~itor- is operable, PM 6528 2 m~id rneadP6528 3 high range is asisumed to be operable soq gr~een (oper) LED light isnotappfiGable-7

Reference: Attachmnent B to 051252.01, Failure of RDMS Camnputer or Cantral ReeamRadiatien Manitar Display UFSAR section 7.5, Safety-Related DisplayInstrumentation

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EALDBD Rev. 32

SYSTEM MALFUNCTION







AND



OR

b. Loss of approximately 75% or more of Main Control Board the following safety-related indications for > 15 minutes:


AND


OR

e. Less of approximately 759%, ormore ef r-adiation monitorindications.

AND


AND


Basis:

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EALDBD Rev. 32

This IC and its associated EAL are intended to recognize the inability of the control room staffto monitor the plant response to a transient. A Site Area Emergency is considered to exist if thecontrol room staff cannot monitor the Critical Safety Functions during a transient.


N Reactor Trip SignalsM ESF Actuation Signals0 Certain Technical Specification Deviations0 Important Systems


"Compensatory indications" include analog/digital readouts, and computer-based informationsuch as.the Video Alarm System (VAS) or Safety Parameter Display System (SPDS).

SIGNIFICANT TRANSIENT: is an UNPLANNED event involving one or more of the following:(1) automatic turbine runback >25% thermal reactor power, (2) electrical load rejection >25%full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal poweroscillations >10%

"Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentation ofthis magnitude is of such significance during a transient that the cause of the loss is not anameliorating factor.

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

Reference: UFSAR Section 7.5, Safety-Related Display Instrumentation.

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Attachment 6

Clean Copy of EAL Technical Basis

EALDBD Rev. 32

SYSTEM MALFUNCTION


UNPLANNED loss of most or all safety system annunciation orindication in theControlRoom for > 15 minutes



Note: The Emergency Director should not wait until 15 minutes has elapsed, but should declarethe event as soon as it is determined that the condition has exceeded, or will likely exceed15 minutes.


** OR **

2. UNPLANNED loss of approximately 75% or more the following safety-related indicationsfor > 15 minutes.


AND


Basis:

This IC and its associated EAL are intended to recognize the difficulty associated withmonitoring changing plant conditions without the use of a major portion of the annunciation orindication equipment. Recognition of the availability of computer based indication equipment isconsidered (e.g., SPDS, plant computer, etc.).

"Planned" loss of annunciators or indicators includes scheduled maintenance and testingactivities.


U

U

U

U

Reactor Trip SignalsESF Actuation SignalsCertain Technical Specification DeviationsImportant Systems

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EALDBD Rev. 32


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, anddefueled modes, no IC is indicated during these modes of operation.-.

It is recognized that most plant designs provide redundant safety system indication poweredfrom separate uninterruptable power supplies. While failure of a large portion of annunciators ismore likely than a failure of a large portion of indications, the concern is included in this EALdue 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 componentoperability status. This will be addressed by the specific Technical Specification. The initiationof a Technical Specification imposed plant shutdown related to the instrument loss will bereported via 10CFR50.72. If the shutdown is not in compliance with the Technical Specificationaction, the Unusual Event is based on SU2.

Reference: UFSAR section 7.5, Safety-Related Display Instrumentation

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EALDBD Rev. 32

SYSTEM MALFUNCTION


UNPLANNED loss of most or all safety system annunciation or indication in Control Roomwith either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicatorsare unavailable




1. EITHER of the following: (a or b)

a. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15minutes.

OR

b. UNPLANNED loss of approximately 75% or more of the following safety-relatedindications for > 15 minutes-


AND


AND



OR


Basis:

This IC and its associated EAL are intended to recognize the difficulty associated withmonitoring changing plant conditions without the use of a major portion of the annunciation orindication equipment during a transient. Recognition of the availability of computer basedindication equipment is considered (e.g., SPDS, plant computer, etc.).

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EALDBD Rev. 32

"Planned" loss of annunciators or indicators includes scheduled maintenance and testingactivities.

It is estimated that if approximately 75% of the safety system annunciators or indicators arelost, there is an increased risk that a degraded plant condition could go undetected. It is notintended that plant personnel perform a detailed count of the instrumentation lost but use thevalue as a judgment threshold for determining the severity of the plant .conditions....


" Reactor Trip Signals" ESF Actuation Signals" Certain Technical Specification DeviationsM Important Systems

It is recognized that most plant designs provide redundant safety system indication poweredfrom separate uninterruptable power supplies. While failure of a large portion of annunciators ismore likely than a failure of a large portion of indications, the concern is included in this EALdue 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 componentoperability status. This will be addressed by the specific Technical Specification. The initiationof a Technical Specification imposed plant shutdown related to the instrument loss will bereported via 10 CFR 50.72. If the shutdown is not in compliance with the TechnicalSpecification action, the Unusual Event is based on SU2.

"Compensatory indications" in this context includes computer-based information such as theVideo Alarm System (VAS), Safety Parameter Display System (SPDS), etc. If both a majorportion of the annunciation system and all computer monitoring are unavailable, the Alert isrequired.


Reference: UFSAR section 7.5, Safety-Related Display Instrumentation

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EALDBD Rev. 32

SYSTEM MALFUNCTION







AND



OR

b. Loss of approximately 75% or more of the following safety-related indications for > 15minutes:


AND

2. Radiation monitor indications on CP-1 80 A and B.

AND


AND


Basis:

This IC and its associated EAL are intended to recognize the inability of the control room staffto monitor the plant response to a transient. A Site Area Emergency is considered to exist if thecontrol room staff cannot monitor the Critical Safety Functions during a transient.

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EALDBD Rev. 32


" Reactor Trip Signals" ESF Actuation Signals" Certain Technical Specification Deviations" Important Systems


"Compensatory indications" include analog/digital readouts, and computer-based informationsuch as the Video Alarm System (VAS) or Safety Parameter Display System (SPDS).

SIGNIFICANT TRANSIENT: is an UNPLANNED event involving one or more of the following:(1) automatic turbine runback >25% thermal reactor power, (2) electrical load rejection >25%full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal poweroscillations >10%

"Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentation ofthis magnitude is of such significance during a transient that the cause of the loss is not anameliorating factor.


Reference: UFSAR Section 7.5, Safety-Related Display Instrumentation.

Page 125 04/09/12 1

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