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PROC)RI EY 1.(ACCELERATED RIDS PROCESSIi

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9503130365 DOC.DATE: 95/03/07 NOTARIZED: NO DOCKETFACIL:50-275 Diablo Canyon Nuclear Power Plant, Unit 1, Pacific Ga 05000275

50-323 Diablo Canyon Nuclear Power Plant, Unit 2, Pacific Ga 05000323AUTH.NAME AUTHOR AFFILIATION

RUEGER,G.M. Pacific Gas & Electric Co.RECIP.NAME RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)

P

SUBJECT: Forwards licensing basis impact evaluation to assist NRC inIreview of revised Emergncy Plan G-1, "Accident

Classification 6 Emergency Plan Activation," submitted toNRC on 950118.

DISTRIBUTION CODE: A045D COPIES RECEIVED:LTR j ENCL I SIZE:TITLE: OR Submittal: Emergency Preparedness Plans, Implement'g rocedures, C

NOTES:

RECIPIENTID CODE/NAME

PD4-2 PD

INTERN 'L: FILE CENTER 0:UDOCS-ABSTRACT

EXTERNAL: NOAC

COPIESLTTR ENCL

1 1

1 11 1

1 1

RECIPIENTID CODE/NAME

MILLER,M

NRR/DRSS/PEPB

NRC PDR

COPIESLTTR ENCL

1 1

1 1

1 1

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NOTE TO ALL"RIDS" RECIPIENTS:PLEASE HELP US TO REDUCE iVASTE! CONTACTTHE DOCUMENT CONTROLDESK, ROOM PI-37 (EXT. 504-2083 ) TO ELINIINATEYOUR NANIE PRO%IDISTRIBUTIONLISTS I'OR DOCUMENTS YOU DON"I'L'ED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 7 ENCL 7

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Pacific Gas and Electric Company 77 Beaie Street, Room1451P.O. Box 770000San Francisco, CA 94177415/973-4684Fax 415/973-2313

Gregory M. Rueger

Senior Vice President and

General ManagerNuctear Power Generation

March 7, 1995

PG&E Letter DCL-95-048

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D.C. 20555

Docket No. 50-275, OL-DPR-80Docket No. 50-323, OL-DPR-82Diablo Canyon Units 1 and 2Pro osed Revision of Accident Classification

Gentlemen:

PG&E submitted a proposed revision of Emergency Plan (EP) G-1, "Accident .

Classification and Emergency Plan, Activation," to the NRC on January 18, 1995in PG&E Letter DCL-95-006. In that letter, PG&E requested NRC approval ofthe proposed revision of EP G-1.

To assist the NRC in the review of the revised EP, PG&E is providing a copy ofthe Licensing Basis Impact Evaluation of the proposed change to Art IVlcQueen.

Sincerely,

cc: L. J. Callan (w/o enc.)Arthur McQueen

Enclosure

6808S/DDS/1 345

9503i30365 950307PDR ADQCK 05000275F PDR

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PG8 E Letter DCL-95-048

ENCLOSURE

LICENSING BASIS IMPACT EVALUATION(Reference Document Number: EP G-1)

E

i'60;10430 08/24/93CIFIC GAS AND ELECTRIC COMPANY

NUCLEAR POMER GENERATION~ Xi IDAP TS3.ID2

TITLE: LICENSING BASIS IMPACT EVALUATION (LBIE) SCREEN

Page 1 of 3

REFERENCE DOCUMENT No. . ~-/ Doc. Rev. No..'.(i.e., indicate the Proce ure um er, um er or o er reference document orwhich .the Screen is done, including the document revision number or date).

I

Reference Document Title ~S~C (~~IRc.&LW~ ~C < 6-W ~~I~Sponsoring Organization Sponsor

nntDESCRIPTION

Summarize the proposed activity, CTE or existing problem and how itpresently approved condition. The reason for the proposed activityalso be described. Cite applicable drawings and other documents asdescrib'e the current condition. Briefly describe how the issue maythe licensing basis (documents).

ala

differs from theor CTE shouldnecessary tointerface with

&fr +. /

C uAiu&W~~

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SCREENING FOR DETERMINI THE N D FOR PRIOR REGULATORY AGENCY APPROVALYes No

Does this activity, CTE or problem involve a change to the Facility t>*Operating License (OL), including OL Attachments (TechnicalSpecifications, Environmental Protection Plan and Antitrust Conditions)?

* If "Yes", submit an LAR to the NRC and. continue this Screen subject tothe approval of the contents of the LAR. LAR¹ Do not releasethe Reference Document above for use, construction, etc., until the LAis received. The originator of the Reference Document should providea reconciliation between the LA and LAR to the PSRC to justify releasefor use, construction, etc.

Is the Reference Document a procedure?(If "No", skip the next question.)

Does the Procedure Commitment Database (PCD) contain any commitment to a ( )**Regulatory Agency that must be changed and which would either:

a} Require notification to that agency, orb) Require prior approval from that agency?

** Follow the requirements of IDAP XI4. ID2, Commitment Change Process.Continue this Screen subject to the contents of the request for priorregulatory approval. Requesting document ¹ If no priorapproval is required, continue the Screen.

TS200500.SF 57

'Ij

'69~10430 08/24/93IDAP TS3.ID2

Page 2 of 3

TITLE: LICENSING BASIS IHPACT EVALUATION (LBIE) SCREEN

Yes NoSECTION 1. 10 CFR 50.59 10 CFR 50.54 a 3 and OL Condition

2.C. 5 b. 2.C. 4 b. Screen

( ) CK)a) Does it involve a change to the facility design, function ormethod of performing the function as described in the SAR,including text, tables and figures and including the FireProtection Program (FSAR Update, Section 9.5) and gualityAssurance Program (FSAR Update, Chapter 17)2

b) Does it involve a change to procedures, system operation or - ( )administrative control over plant activities as described in theSAR, including procedures related to the Fire Protection Program(FSAR Update, Section 9.5) and the guality Assurance Program (FSARUpdate, Chapter 17)?

c) Does it result in a test, experiment, condition or configuration ( )that might affect safe operation of the plant but was notanticipated, described or evaluated in the SAR?

SECTION 2. Environmental Protection Screen

SCREENING FOR DETERMINING THE NEED FOR A SPECIFIC EVALUATION

For the activity, CTE or problem under consid'eration answer the following questions.Any "Yes" response (except the answers for items 3.a and 4.a below) requires theappropriate sections of Form 69-10431 (LBIE) to be completed.

a)

b)

c)

d)

e)

Does it involve changes to or new effluents discharged to air,fresh water, sea water or land?

Does it involve a change in quantity or use or storage ofmaterials classified as hazardous (including oils) or thegeneration of hazardous wastes?

Does it result in disturbance of any previously undisturbed land? ( )

Does it alter surface water runoff patterns or amounts? ()Does it involve work within the SLO-2 archeological site boundary? ( )

SECTION 3. Emer enc Plan Screen

a) Does the Emergency Plan (EP) require review on the basis ofAppendix 7.1? If "No", skip the next question and signature. IQ ()

b) If "Yes", does the activity, CTE or problem resu1t in a change to PQthe EP?

Emergency Plan Reviewer Signature / D te

TS200500.SF 58

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J

6g.-10430 08/24/g3~

~ IDAP TS3. ID2Page 3 of 3

TITLE"

LICENSING BASIS IMPACT EVALUATION (LBIE) SCREENgv~t

SECTION 4. Securit Plans'creenYes No

a),Do any of the security plans (PSP, SCP, ST(P) require review on ( )the basis of Appendix 7.2? 'If "No", skip the next question andsignature.

b) If "Yes", does the activity, CTE or problem result in a change to ( ) ( )a security plan?

If so, which plan(s)?

Security Plan Reviewer Signature / Date

RBNRKS: For each Screen Section above having all "No" answers, provide the logicfor the "No" answers if clarification is required.

REFERENCES/ATTACHMENTS:

Based upon the above criteria, i have determined that an LBIE is id is notrequired.

!6!dN ~~

~

Preparer Signature"/ 8.d't ~8

Date

Based upon my independent technica1 review, I co c r with the above conclusion.

'Ib~l9'ndependentTechnical.-R viewer Signature Date

TS200500.SF 59

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69-10431 08/24/93ACIFIC GAS AND ELECTRIC COHPANY

NUCLEAR POWER GENERATIONIDAP TS3. ID2

Page 1 of 9

TITLE: LICENSING BASIS IHPACT EVALUATION (LBIE)

REFERENCE DOCUHENT No.(i.e., indicate the Proce ure um er,which=,the Evaluation is done, including

Reference Document Title

Sponsoring Organization

Doc. Rev. No. ~c~ Aum er or ot er reference document or

the document revision number or date).

9 F ~ m M~3 C~~ . p~ ~~P~W] Sponsor Lab +

l lnt

As a result of the LBIE Screen (Form 69-10430), indicate which sections of thisLBIE have been completed and are attached. Refer to TS3.ID2 to complete eachevaluation.

[ ] SECTION 1 10 CFR 50.59 Safety Evaluation (including 10 CFR 50.54(a)(3) andOL Condition '2.C.(5)b./2.C.(4)b. Evaluations)

[ ] SECTION 2 Environmental Protection EvaluationSECTION 3 'mergency Plan Evaluation — 10 CFR 50.54(q)

] SECTION 4 Security Plans'valuation — 10 CFR 50.54(p)

Explain why this LBIE is being performed (i.e., Why were Screen questions answered"Yes"7)

~k — R

PSRC REVIEW: HEETING NO.pc~~'~ DATE

APPROVEO (PLANT MANAGER)

Yes NoRECOHHEND APPROVAL (+ ( )

DATE +~

TS200500.SF 60

l

~ 69-. 10431 08/24/93~ ~ IDAP TS3.ID2

TITLE:'ICENSING BASIS IMPACT EVALUATION (LBIE)

Page 8 of 9

g 47'4?, ~ asr> P- 7 ™C ~IJ/R

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SECTION 3. Emer enc Plan Evaluation — 10 CFR 50.54

The DCPP Emergency Planning group can provide help to prepare this evaluation andshall be the ITR.

1. Describe the proposed change(s) to the Emergency Plan.(tF' . (e)m( 4 l-l

Z. Describe the effect f Phe proposed change(s) on the effectiveness of the

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b Crt,? S.

3. Describe if and how the revised Emergency 'Plan will continue to meet thestandards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50.

go.+7 4 'A Ill ) s~ 4 l~~l~ ~ u

L, ~?.~ 0~&& .c

Based upon the above criteria and justification, I have determined that a decreasein the effectiveness of the Emergency Plan or a deviation from the standards of10 CFR 50.47(b) or requirements of Appendix E to 10 CFR 50 is* is not ~iinvolved.

Preparer Signature Date

REVIEWED: Based upon my independent technical review, I concur with the above

'Ng %L( — 'Jl >l(~I(I'I 'Ibl l(tIndependent Techn'cal Reviewer Signature Date

*Ifthe effectiveness of the Emergency Plan is decreased, or if a deviation from thestandards of 10 CFR 50.47(b) or requirements of Appendix E to 10 CFR 50 isinvolved, NRC approval is required prior to implementing the activity or CTE.

TS200500.SF 67

l

Form 69-10431 (LBIE),Page 8, Section 3 continued, EP G-1 Rev. 24 (Em. Class. and EP Activ.)

10CFR50.47(b)(4) states the following:2 standard emergency classification and action level scheme, the bases ofwhich include facilitysystem andevent parameters, is in use by the nuclear facilitylicensee, and State and local response plans callforreliance on information provided byfacilitylicensees for determinations ofminimum initialoffsite responsemeasures.

10CFR50 Appendix E, section IV.B. (Assessment Actions) states the following:The means to be used for determining the magnitude ofand for continually assessing the impact ofthe releaseofradioactive-material. shall be described; includingcmergency action levels-that-are to-be used as criteriafordetermining the need fornotification and participation oflocal and State agencies, the Commission, and otherFederal agencies, and the emergency action levels that are to be used for determining when and what type ofprotective measures should be considered within and outside the site boundary to protect health and safety.The emergency action levels shall be based on in-plant conditions and instrumentation in addi tion to onsiteand offsite monitoring. These emergency action levels shall be discussed and agreed on by the applicant andState and local governmental authorities and approved by the NRC They shall also be reviewed with the Stateand local governmental authorities on an annual basis.

1. Describe the proposed change(s) to the Emergency Plan.See individual descriptions below.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.See individual descriptions below.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50. (Note: The followingstatementis a GENERALDESCRlPTION applicable to all the individual changes listed below.)

The revision to Attachment 7.1 (EAL Classification Chart) ofEP G-1, Rev. 24, willcontinue to support thestandards of 10CFR50.47(b)(4) and 10CFR50 App.B, IV.B. The Rev. 24 changes are at a finer level ofdetailthan discussed in 10CFRSO, and there is no decrease in the general level of support as described in theregulation. The detail of the changes, however, willalso continue to support the guidance contained inNUREG-0654, Appendix 1, as updated by the NRC Regulatory Analysis of the Revision ofRegulatory Guide1.101. The general intent of the changes listed below is to enhance the Emergency Plan by

1. Eliminating EALs that are redundant, that do not meet emergency classification definitions, orthat are not direct precursors to more serious events. This is done to simplify the classificationchart for use by the operators, focusing their attention on the remaining EALs to yield eventdeclarations that are correct and timely.

2. Adding Mode dependency to EALs for which itwas not already stated or directly implied.Where applicable, add new EALs to give a risk-logical flow to the event escalation.

3. Where applicable, adding a 15 minute time criterion, or changing the existing time criterion to 15minutes. This is done to avoid declarations for transitory events not warranting emergencyclassification, and also to standardize the time criterion as an aid to operational staff.

4. Implementing other modifications with the intent of making the EALs more explicit andrelationally consistent with each other and with the classification levels they represent, withoutover- or under-classifying events.

Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q )jc Q Q Q Q Q Q Q )ftQ Q Q Q $ Q )jc Q

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The following references apply to Classification Sections in EP G-l, Attachment 7.1 (first table column).

Rev. 23 Section ¹: I Rev. 24 Section ¹: eleted

1. Describe the proposed change(s) to the Emergency Plan.Rev. 23 U.E. ¹1 is the only EAL in this section. This event does not meet the threshold for the emergencyclass definition and is not a direct precursor to a more serious event. This event is reportable under10CFR50.72 as a non-emergency.'t has'therefore been"deleted from the EALclhssification chart.'

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This change willimprove the Emergency Plan by deleting the declaration of an Unusual Event for a situationwhich is not an emergency threatening the general public safety, nor a direct precursor to such an event. Theremoval of this EALwillenhance the importance of the remaining U.E. classification EALs by avoidingimplementation of the Emergency Plan for non-emergency events.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above. The State and County have no direct involvement withoverexposed or contaminated medical evacuees from DCPP. Any event resulting in such evacuees that haspotential for escalating to a situation potentially affecting public health and safety is adequately covered byother U.E. level and higher level EALs.

Rev. 23 Section ¹: II Rev. 24 Section ¹: I1. Describe the proposed change(s) to the Emergency Plan.

"(AllModes)" added for clarity and consistency. There is no actual change in this section, since in the lack ofthis added phrase, the "AllModes" applicability was implied in the previous revision.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by explicitly stating in a more consistent manner what was implied in theprevious revision.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to IOCFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 Section ¹: III Rev. 24 Section ¹: II

1. Describe the proposed change(s) to the Emergency Plan."(Modes 1-4)" added-for clarity and consistency: -Modes 5 and 6 are excluded since littlemotive power existsin these modes to force activity to atmosphere. Despite this, should there be a significant release, EALs inRev. 24 Section IV (Rev. 23 Section VI)willapply to AllModes.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.These changes willenhance the Emergency Plan by adding clarity and consistency in specifying Modedependency for all EALs and precluding potential confusion resulting from the attempt to interpret an EAL ina Mode for which it doesn't apply.

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3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 Section ¹: IV Rev. 24 Section ¹: III

1. Describe the proposed change(s) to the Emergency Plan."(AllModes)" added for clarity and consistency. There is no actual change in this section, since in the lack ofthis added phrase, the "AllModes" applicability was implied in the previous revision.

2. Describe'the effect 'of the proposed'chang'e(s)'on the effectiveness of t'he'Einergeiicy'Plan.This revision willenhance the Plan by explicitly stating in a more consistent manner what was implied in theprevious revision.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 Section ¹: V Rev. 24 Section ¹: eleted

1. Describe the proposed change(s) to the Emergency Plan.Rev. 23 U.E. ¹6 was the only EAL in this section. Itwas essentially redundant to Rev. 23 U.E. ¹12 (TechSpec required shutdown). Rev. 23 U.E. ¹12 has been revised to Rev. 24 U.E. ¹9, which as before is a moregeneral statement of the concern of Rev. 23 U.E. ¹6. The latter has therefore been deleted from the EALclassification chart, resulting in the elimination ofRev. 23 Section V.

2. Describe the effect of the proposed change(s) o'n the effectiveness of the Emergency Plan.This change willimprove the Emergency Plan by deleting a redundant and potentially confusing EAL. Theremoval of this EALwillenhance the importance of the remaining U.E. classification EAL that gives thegeneral staement ofconcern (Tech Spec shutdown). See Rev. 24 U.E. ¹9 for explanation of changes in thisEAL (formerly Rev. 23 U.E. ¹12).

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 Section ¹: VI Rev. 24 Section ¹: IV

1. Describe the proposed change(s) to the Emergency Plan."(AllModes)" added for clarity and consistency. There is no actual change in this section, since in the lack ofthis added phrase, the "AllModes" applicability was implied in the previous revision.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by explicitly stating in a more consistent manner what was implied in theprevious revision.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to IOCFR50.

See the GENERAL DESCRIPTION above.

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Rev. 23 Section ¹: VH Rev. 24 Section ¹: V

1. Describe the proposed change(s) to the Emergency Plan."(AllModes)" added for clarity and consistency. There is no actual change in this section, since in the lack ofthis added phrase, the "AllModes" applicability was implied in the previous revision.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by explicitly stating in a more consistent manner what was implied in theprevious revision.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the'GENERAL DESCRIPTION'above.

Rev. 23 Section ¹: VIH Rev. 24 Section ¹: VI

No Mode limitations added to section title. The various EALs in this section have Mode applicabilityspecifically indicated or implied.

Rev. 23 Section ¹: IX Rev. 24 Section ¹: VH

No Mode limitations added to section title. The various EALs in this section have Mode applicabilityspecifically indicated.

Rev. 23 Section ¹: X Rev. 24 Section ¹: VIII

1. Describe the proposed change(s) to the Emergency Plan."(AllModes)" added for clarity and consistency. There is no actual change in this section, since in the lack ofthis added phrase, the "AllModes" applicability was implied in the previous revision.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by explicitly stating in a more consistent manner what was implied in theprevious revision.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of IOCFR50.47(b)and the requirements ofAppendix E to IOCFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 Section ¹: XI Rev. 24 Section ¹: IX

1. Describe the proposed change(s) to the Emergency Plan."(AllModes)" added for clarity and consistency. There is no actual change in this section, since in the lack ofthis added phrase, the "AllModes" applicability was implied in the previous revision.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by explicitly stating in a more consistent manner what was implied in theprevious revision.

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3. Describe if-and how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 Section ¹: XII Rev. 24 Section ¹: X

1. Describe the proposed change(s) to the Emergency Plan. ~

"(Modes 1-4)" added for clarity and consistency. These EALs have no applicability to Modes 5 and 6.2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.

These changes will"enhance the Emergency'Plan'by adding clarity and consistency in specifjing'Modedependency for all EALs and precluding potential confusion resulting from the attempt to interpret an EAL ina Mode for which it doesn't apply.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 Section ¹: XIII Rev. 24 Section ¹: XI

1. Describe the proposed change(s) to the Emergency Plan."(Modes 1-4)" added for clarity and consistency. These EALs have no applicability to Modes 5 and 6.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.These changes will enhance the Emergency Plan by adding clarity and consistency in specifying Modedependency for all EALs and precluding potential confusion resulting from the attempt to interpret an EAL ina Mode for which it doesn't apply.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 Section ¹t XIV Rev. 24 Section ¹: XH

1. Describe the proposed change(s) to the Emergency Plan."(AllModes)" added for clarity and consistency. There is no actual change in this section, since in the lack ofthis added phrase, the "AllModes" applicability was implied in the previous revision.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by explicitly stating in a more consistent manner what was implied in theprevious revision.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix.E to 10CFR50.

See the GENERAL DESCRIPTION above.

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Rey 23 Section¹: XV Rev. 24 Section ¹: XIII

1. Describe the proposed change(s) to the Emergency Plan."(AllModes)" added for clarity and consistency. There is no actual change in this section, since in the lack ofthis added phrase, the "AllModes" applicability was implied in the previous revision.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by explicitly stating in a more consistent manner what was implied in theprevious revision.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERA'L DESCRIPTION above.

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The following references apply to individual EALs in EP G-l, attachment 7.1.

Rev. 23¹: U.E.¹1 Rev. 24 ¹: eleted 0654 ¹: U.E. ¹16

I. Describe the proposed change(s) to the Emergency Plan.This event does not meet the threshold for the emergency class definition and is not a direct precursor to amore serious event.'his event is reportable'under-'10CFR'50:72'as'a non-em'ergency'. 'It has th'er'efore beendeleted from the EAL classification chart.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This change willimprove the Emergency Plan by deleting the declaration of an Unusual Event for a situationwhich is not an emergency threatening the general public safety, nor a direct precursor to such an event. Theremoval of this EALwillenhance the importance of the remaining U.E. classification EALs by avoidingimplementation of the Emergency Plan for non-emergency events.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above. The State and County have no direct involvement withoverexposed or contaminated medical evacuees from DCPP. Any event resulting in such evacuees that haspotential for escalating to a situation potentially affecting public health and safety is adequately covered byother U.E. level and higher level EALs.

Rev. 23¹: U.E.¹2 Rev. 24 ¹: V.E. ¹1 0654 ¹: U.E. ¹10

1. Describe the proposed change(s) to the Emergency Plan.Delete reference to oQsite assistance, change 10 minutes to 15 minutes, and add qualifier regarding effects ofthe fire.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.Elimination of the offsite assistance criterion willpreclude declaration of a U.E. for fires that have no nuclearsafety significance. For example, U.E.s have been declared in the past for grass fires well away from the plantprotected area that do not threaten power supplies to the plant. It serves no purpose to declare such events.The revised U.E. time limithas been increased from 10 minutes to 15 minutes to be consistent in use withother EALs. Application of a consistent time criterion is considered advantageous in terms of actual use ofEALs by operators. Additionally, in order that the event be declared for nuclear safety significance, areference is given to the plant equipment or power supplies in or near the Protected Area(s). These changesshould enhance the Plan by eliminating U.E. declarations for non-nuclear safety incidents, therebyemphasizing the importance of the remaining incidents that qualify under the new EAL.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

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Rev,23 ¹: Alert ¹1 Rev. 24¹: Alert¹1 0654¹: Alert ¹13

1. Describe the proposed change(s) to the Emergency Plan.Change 10 minutes to 15 minutes. Change "operability" to "loss of function." Change "safety relatedequipment (required by Tech Specs)" to "safety related systems required for safe shutdown." Changefollowing list of safety related systems.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.These changes are made to better meet the intent of NUREG-0654 and for added clarity and ease ofapplication. The time limithas been increased from 10 minutes to a 15 minute standard to be consistent in usewith other EALs. Application of a consistent time criterion is considered advantageous in terms of actual useofEALs by operator's.- 'B'y limitingconsideration to fun'ctionality versus'tecKnical'operability, this revision willenhance the Plan and help ensure the event is not mis-declared or overclassified. Functionality is furtherenhanced by the reference to safe shutdown systems (defined per EP M-10) versus Tech Spec equipment andby the new systems listing, which is more "big picture," logical and comprehensive than the one it replaces.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: S.A.E. ¹1 Rev. 24 ¹: S.A.E. ¹1 0654 ¹: S.A.E. ¹11

1. Describe the proposed change(s) to the Emergency Plan."Threatening the operability" replaced by "causing the complete loss of function." 10 minute time referencedeleted as unnecessary under this new criterion. Change "safety related equipment (required by Tech Specs)"to "safety related systems required for safe shutdown." Change following list of safety related systems.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.These changes are made to better meet the intent of NUREG-0654 and for added clarity and ease ofapplication, and to be consistent with new Rev. 24 Alert ¹1 described above. By limitingconsideration tofunctionality versus technical operability, this revision willenhance the Plan and help ensure the event is notmis-declared or overclassified. Functionality is further enhanced by the reference to safe shutdown systems(defined per EP M-10) versus Tech Spec equipment and by the new systems listing, which is more "bigpicture," logical and comprehensive than the one it replaces.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of IOCFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23¹: Alert ¹2 Rev. 24¹: Alert¹2

1. Describe the proposed change(s) to the Emergency Plan.Add clause regarding equivalent fuel failure measured by exposure rate..

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.An RCS sample drawn via the PASS may take up to three hours to evaluate. In a scenario in which the core isdamaged by mechanical versus thermal means, installed monitoring may not indicate the fuel damage. Aquick check for fuel damage could shorten the response time to correctly declare an Alert. This addition willallow such a classification by checking RCS lines for activity well in excess of the criteria in Rev. 24 U.E. ¹2,a crud burst, or other non-gross fuel failure causes.

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3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

The above standards and requirements willcontinue to be met. The addition willpotentially quicken theresponse time to declare a fuel failure based Alert.

Rev. 23¹i U.E.¹4 Rev. 24 ¹: eleted 0654 ¹ 'U.E. ¹4

1. Describe the proposed change(s) to the Emergency Plan.Rev. 23 U.E. ¹4 is essentially redundant to Rev. 23 U.E. ¹12 (Tech Spec required shutdown). Rev. 23 U.E.¹12'has been revised to"Rev. 24'U;E. ¹9, which again is'a more general statement of'the concern of Rev. 23U.E. ¹4. Therefore, Rev 23 U.E. ¹4 has been deleted from the EAL classification chart.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This change will improve the Emergency Plan by deleting a redundant and potentially confusing EAL. Theremoval of this EALwillenhance the importance of the remaining U.E. classification EAL that gives thegeneral statement ofconcern (Tech Spec shutdown). See Rev. 24 U.E. ¹ 9 for explanation of changes in thisEAL (formerly Rev. 23 U.E. ¹12).

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23¹: Alert ¹3 Rev. 24 ¹: eleted 0654¹: Alert ¹9

1. Describe the proposed change(s) to the Emergency Plan.Coolant pump seizure is a precursor event that willgenerally not lead to fuel failure, given the redundantcoolant injection systems to compensate for coolant pump loss. The key concern is fuel failure, not the pump,and fuel failure is a declarable event under other EALs, such as Rev. 24 Alert ¹2.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This change willimprove the Emergency Plan by deleting an unnecessary, redundant and possibly confusingEAL. The removal of this EALwillsimplify the Classification Chart 'and enhance the importance of theremaining Alert classification EALs.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to IOCFR50.

See the GENERAL DESCRIPTION above.

Rev. 23¹: G.E. ¹3 Rev. 24 ¹: G.E. ¹3 0654¹: G.E. ¹2

1. Describe the proposed change(s) to the Emergency Plan.Part A): Second AND statement ("Condenser is unavailable...") is replaced by "Steam release ... steamlinebreak."Part B): Third AND statement, "offunction" added to "loss" regarding Containment Spray trains and CFCUs,and "two CFCUs" changed to "four CFCUs."

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2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.These changes are made to better meet the intent of NUEEG-0654 and for added clarity. Part A) change willmake this EAL consistent with Rev. 24 S.A.E. ¹18. Part B) change willlimitconsideration to functionalityversus technical operability and thereby enhance the Plan by ensuring the event is not overclassifted. Thechange from two to four CFCUs was made to exceed the requirements in Tech Spec 3.6.2.3, Action b.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23¹: U.E.¹6 Rev. 24 ¹: eleted 0654¹: U.E. ¹8

1. Describe the proposed change(s) to the Emergency Plan.Rev. 23 U.E. ¹6 is essentially redundant to Rev. 23 U.E. ¹12 (Tech Spec required shutdown). Rev. 23 U.E.¹12 has been revised to Rev. 24 U.E. ¹9, which is a more general statement of the concern of Rev. 23 U.E.¹6. Therefore, Rev. 23 U.E. ¹6 has been deleted from the EAL classification chart. Since this was the onlyunique EAL in Rev. 23 Section V, this section has been deleted from the chart.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This change willimprove the Emergency Plan by deleting a redundant and potentially confusing EAL. Theremoval of this EALwillenhance the importance of the remaining U.E. classification EAL that gives thegeneral statement of concern (Tech Spec shutdown). See Rev. 24 U.E. ¹ 9 for explanation of changes in thisEAL (formerly Rev. 23 U.E. ¹12).

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23¹: Alert¹7 Rev. 24¹: Alert ¹6

1. Describe the proposed change(s) to the Emergency Plan.Deleted reference to AP A-81. This procedure has been superceded by remaining reference CY2.ID1.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.Editorial change only - no effect on Plan.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of IOCFR50.47(b)and the requirements ofAppendix E to 10CFR50.

The revised EALwillcontinue to meet the referenced standards.

Rev. 23¹: Alert ¹8 Rev. 24¹: Alert¹7

Describe the proposed change(s) to the Emergency Plan.Words "reasonable" and "significant" removed from previous revision as in phrases "a reasonable potentialexists" and "a significant loss ofability."

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2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The last section of this EALwas added in Rev. 23. Concerns were raised by Region 1V NRC as to a consistentinterpretation of the words in question. Itwas agreed that these words do not add value to the EAL and are sodeleted.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

The revised EALwillcontinue to meet the referenced standards.

Rev. 23 ¹: U.E. ¹Il Rev. 24 ¹: U.E.¹8

1. Describe the proposed change(s) to the Emergency Plan.Deleted reference to AP A-81. This procedure has been superceded by remaining reference CY2.ID1.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.Editorial change only - no effect on Plan.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

The revised EALwillcontinue to meet the referenced standards.

Rev. 23¹: Alert ¹10 Rev. 24 ¹: Alert ¹9 0654¹: Alert¹20

1. Describe the proposed change(s) to the Emergency Plan.EAL completely reworded, keying offentry into OP AP-8A. Time criterion added using standard 15 minutes.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The revised EALwillcontinue to fullyaddress the concern of0654 and willmake for easier recognition of theevent by operators. Thus it should enhance the Plan.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: S.A.E. ¹7 Rev. 24 ¹: S.A.E. ¹7 0654 ¹: S.A.E. ¹18

1. Describe the proposed change(s) to the Emergency Plan.EAL completely reworded, keying offentry into OP AP-8A. Time criterion added using standard 15 minutes.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The revised EALwillcontinue to fullyaddress the concern of 0654 and willmake for easier recognition of theevent by operators. Itwillalso be consistent with companion Rev. 24 Alert ¹9. Thus it should enhance thePlan.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above. l

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Rev,.23 ¹: U.E. ¹12 Rev. 24 ¹: U.E. ¹9 0654 ¹: U.E. ¹9

1. Describe the proposed change(s) to the Emergency Plan.This EAL is revised to require a U.E. not for any Tech Spec related plant shutdown as previous, but only for aTech Spec related plant shutdown that exceeds the Action Statement time. Limitto Modes 1-4 added.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This change willenhance the Plan for the following reasons. Entry into a Tech Spec Action Statement doesnot constitute an emergency. The initiation of a plant shutdown required by Technical Specifications requiresa one-hour report under 10CFR50.72. Exceeding the Action Statement time limitwith possibility of fuel claddegradation as a precursor to more serious problems meets the intent of the U.E. definition. This EAL changeshould significantly reduce'the probability ofunnecessary U;E.s reported'to State and'Courity'overnments.The revised EALwillenhance the importance of the U.E. classification by eliminating the declaration ofnon-useful U.E.s. Note that this general statement V.E. is replacing specific cause Tech Spec shutdown Rev. 23U.E.s ¹4 8c ¹6.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: S.A.E. ¹8Rev.23¹: V.E.¹14

Rev. 24 ¹: S.A.E. ¹8Rev. 24¹: U.E. ¹11

Editorial change for consistency ("Modes 1-4" replacing "Modes 1 through 4" and "Modes 1, 2, 3, or 4.").

Rev. 23 ¹: Alert ¹11 Rev. 24¹: Alert ¹10 0654¹: Alert¹10

1. Describe the proposed change(s) to the Emergency Plan.Standard 15 minute time criterion added and Modes limited to 1-4. Note - more changes in this EAL that arecommon to other EAL changes are discussed in group explanations below.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The addition of the time criterion willdiscriminate against momentary losses, and the Mode applicabilitychange from 1-4 to 1-3 willbe consistent with Tech Specs 3.1.4.3 and 3.5.3. This should assist the operatorsin correctly applying this EAL and hence enhance the Plan.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: Alert ¹11Rev. 23 ¹: S.A.E. ¹8Rev. 23 ¹: U.E. ¹13Rev. 23 ¹: U.E. ¹14Rev. 23¹: Alert¹13

Rev.24¹: Alert¹10Rev. 24¹: S;A.E. ¹8Rev. 24¹: U.E. ¹10Rev. 24 ¹: U.E. ¹11Rev. 24¹: Alert¹12

0654¹: Alert¹100654 ¹: S.A.E.¹80654¹: U.E. ¹90654 ¹: U.E. ¹140654¹: Alert¹10

1. Describe the proposed change(s) to the Emergency Plan."Offunction" added to "loss" of indicated systems or components.

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2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.These changes made to better meet the intent of NUREG-0654 and for added clarity. By limitingconsideration to functionality versus technical operability, this revision willenhance the Plan and help ensurethe event is not overclassified.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of IOCFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: S.A.E. ¹8Rev. 23 ¹: U.E. ¹13Rev. 23¹: U.E.¹14Rev.23¹: Alert¹13

Rev. 24 ¹: S.A.E. ¹8Rev.24¹: V.E.¹10Rev. 24¹: U.E. ¹11Rev.24¹: Alert¹12

0654 ¹: S.A.E. ¹80654 ¹ V.E. ¹90654¹: U.E. ¹90654¹: Alert¹10

1. Describe the proposed change(s) to the Emergency Plan.Standard 15 minute time criterion added.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The addition of a standard 15 minute time criterion willdiscriminate against momentary losses that don'warrant an emergency declaration. Application of a consistent time criterion is considered advantageous interms of actual use ofEALs by operators. Note that for Rev. 24 U.E. ¹10 and Alert ¹12, the 15 minutecriterion willreplace the 10 minute criterion as previously stated in the following references: DCL-87-099,p.4; DCL-87-233, p.9 and 13; DCL-88-046, item V.3; and NCR DC2-87-OP-N040, p. 4.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of IOCFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: G.E. ¹5 Rev. 24 ¹: G.E. ¹5

Editorial change - "EOP" added for clarity (to designate an Emergency Operating Procedure).

Rev. 23 ¹: U.E. ¹15 Rev. 24 ¹: U.E. ¹12 0654¹: U.E. ¹7

1. Describe the proposed change(s) to the Emergency Plan.Rev. 23 U.E. ¹15 was split into two new U.E.s, this one for Modes 1-4 and Rev. 24 U.E. ¹13 for Modes 5 2 6(see below). For Rev. 24 U.E. ¹12, a standard 15 minute time criterion is added, Modes 1-4 dependencyadded, and a requirement for at least two functioning diesel generators added.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The addition of a standard 15 minute time criterion willdiscriminate against momentary losses that don'warrant an emergency declaration. Application of a consistent time criterion is considered advantageous in;terms of actual use ofEALs by operators. Mode 1-4 dependency is added consistent with Tech Spec 3.8.1.1.This differentiates between increased power requirements for these operations as opposed to lesserrequirements for Modes 5 Ec 6 (see new Rev. 24 U.E. ¹13 described below). Added requirement for 2 D/Gswilldifferentiate this U.E. from the new Rev. 24 Alert ¹13 described below.

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3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: Alert ¹14 Rev.24¹: Alert¹13 0654 ¹:.Alert ¹7

1. Describe the proposed change(s) to the Emergency Plan.Rev. 23 Alert ¹14 is being split into two new Alerts, Rev. 24 ¹13 for Modes 1-4 and ¹14 for Modes 5 8'c 6.As compared to the former EAL, Rev. 24 Alert ¹13 reverses the time sense of the 15 minute criterion, butrequires the Alert declaration with soine on-site power still available.

*

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The two new EALs willprove more useful, first by precluding the declaration of a required, but unnecessary,Alert under the old Rev. 23 Alert ¹14 for the case in which all on-site and off-site power is lost but regainedwithin 15 minutes. For new Rev. 24 Alert ¹13, the Alert is declared for the higher power modes in which asingle source ofpower remains, the loss ofwhich willresult in a station blackout, thereby requiring declarationof an S.A.E. (see Rev. 24 S.A.E. ¹9). This change willenhance the Plan by better differentiating the risks ofthis initiating condition as related to operating Mode. Itwillhelp preclude the declaration of a non-necessaryAlert (loss ofall on-site and off-site AC power for less than 15 minutes). This will in turn preclude theactivation of the County Plan for a condition not warranting such activation. With Rev. 24 U.E. ¹12 and Rev.24 S.A.E. ¹9, this new Alertwillprovide a logical escalation based on numbers of diesel generators availablewhen off-site power is lost.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: U.E. ¹15 Rev. 24 ¹: U.E. ¹13 0654¹: U.E.¹7

1. Describe the proposed change(s) to the Emergency Plan.Rev. 23 U.E. ¹15 was split into two new U.E.s, this one for Modes 5 8c 6 and Rev. 24 U.E. ¹12 for Modes 1-4(see above). For Rev. 24 U.E. ¹13, a standard 15 minute time is criterion added, Modes 5 Ec 6 dependencyadded, and a requirement for at least one functioning diesel generator added.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The addition of a standard 15 minute time criterion willdiscriminate against momentary losses that don'warrant an emergency declaration. Application of a consistent time criterion is considered advantageous interms of actual use ofEALs by operators. Modes 5 k 6 dependency is added consistent with Tech

Spec'.8.1.2.This differentiates between lesser power requirements for these operations as opposed to increasedrequirements for Modes 1-4 (see new Rev. 24 U.E. ¹12 described above).

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

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Rev..23 ¹: S.A.E. ¹9 Rev. 24 ¹: S.A.E. ¹9 0654 ¹: S.A.E. ¹6

1. Describe the proposed change(s) to the Emergency Plan.Mode dependency added, restricting this EAL to Modes 1-4. The same plant condition in Modes 5 and 6would become an Alert versus an S.A.E.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This change willenhance the Plan by better differentiating the risks of this initiating condition as related tooperating Mode. Itwillhelp preclude the declaration of a non-necessary S.A.E. The severity of the powerloss depends on the Mode of operation. This condition is classified as an Alert for Modes 5 and 6 (see Rev. 24Alert ¹14) due to the decreased decay heat, and substantially increased times for cladding damage andradiological'releases. 'The'.A.E: classification is proposed for'Modules 1-4 because'6f the much greaterpotential for core damage and fission product barrier challenges resulting from the increased risk associatedwith the removal of the decay heat.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: Alert ¹14 Rev. 24¹: Alert ¹14 0654¹: Alert ¹7

1. Describe the proposed change(s) to the Emergency Plan.Rev. 23 Alert ¹14 is being split into two new Alerts, Rev. 24 ¹13 for Modes 1-4 and ¹14 for Modes 5 &'6.As compared to the former EAL, Rev. 24 Alert ¹14 reverses the time sense of the 15 minute criterion and addsthe Mode 5 & 6 dependency..

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The two new EALs willprove more useful, first by precluding the declaration of a required, but unnecessary,Alert under the old Rev. 23 Alert ¹14 for the case in which all on-site and off-site power is lost but regainedwithin 15 minutes. For new Rev. 24 Alert ¹14, the Alert is declared for the lower power modes in which astation blackout occurs. This change willenhance the Plan by better differentiating the risks of this initiatingcondition as related to operating Mode (refer to discussion ofRev. 24 S.A.E. ¹9 above). Itwillhelp precludethe declaration of a non-necessary Alert (loss of all on-site and off-site AC power for less than 15 minutes).

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: N/A Rev. 24 ¹: U.E. ¹14 0654¹: Alert ¹15

1. Describe the proposed change(s) to the Emergency Plan.New U.E. added, similar to Rev. 23 Alert ¹15, with 15 minute criterion changed in sense and Mode limitationto 5 & 6 added.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by giving a wider and more logical action level span to DC power loss-based events. This level was added to give consistency to the escalation of onsite DC power loss-related action

. levels, leading to the modified Rev. 24 Alert ¹15 and ending with the modified Rev. 24 S.A.E. ¹10 (seeexplanation for this EAL). Inability to remove decay heat in Modes 5 and 6 due to DC loss is adequatelycovered at an escalated risk level by Rev. 24 Alerts 2, 4-8, 11 and 12.

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3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23¹: Alert ¹15Rev. 23 ¹: S.A.E. ¹10

Rev. 24¹: Alert ¹15Rev. 24 ¹: S.A.E. ¹10

Editorial change - delete "on-site" reference to DC power, as there exists no "off-site" DC power.

Rev. 23 ¹: Alert ¹15 Rev. 24¹: Alert ¹15 0654¹: Alert ¹15

1. Describe the proposed change(s) to the Emergency Plan.Alert modified by adding Mode 1-4 dependency. This event in Modes 5 and 6 becomes new Rev. 24 U.E. ¹15discussed above, while the same condition in Modes 1-4 for over 15 minutes becomes S.A.E. ¹10 discussedbelow.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by giving a wider and more logical action level span to DC power loss-based events. This Alertwas modified to give consistency to the escalation of onsite DC power loss relatedaction levels, from Rev. 24 U.E ¹15 to Rev. 24 S.A.E. ¹10 (see explanation for this EAL).

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: S.A.E. ¹10 Rev. 24 ¹: S.A.E. ¹10 0654 ¹: S.A.E. ¹7

1. Describe the proposed change(s) to the Emergency Plan.S.A.E. modified by adding Mode 1-4 dependency.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by giving a wider and more logical action level span to DC power loss-based events. This level was modified to give consistency to the escalation of onsite DC power loss relatedaction levels, starting with new Rev. 24 U.E. ¹15, leading to modified Rev. 24 Alert ¹15, and ending with thismodified Rev. 24 S.A.E. ¹10. This series ofaction levels was changed to reflect the relative risk ofDC loss atpower operations as opposed to shutdown and refueling, given the role ofDC power in controlling andmonitoring functions necessary to maintain critical safety functions.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to IOCFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: N/A Rev. 24¹: U.E. ¹16

1. Describe the proposed change(s) to the Emergency Plan.New U.E. added, similar to Rev. 23 Alert ¹16, with 15 minute criterion added.

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2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by giving a wider and more logical action level span to annunciator-basedevents. This level was added to give consistency to the escalation ofannunciator-related action levels,leading to the modified Rev. 24 Alert ¹16 and ending with the modified Rev. 24 S.A.E. ¹11 (see explanationfor this EAL).

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: Alert ¹16 '- -Rev:24'¹:"Alert¹16 '--" '4654'¹:-'Alert ¹14

I. Describe the proposed change(s) to the Emergency Plan.Alert modified, similar to Rev. 23 S.A.E. ¹16, with "significant transient" defined in parens and 15 minutecriterion added.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by giving a wider and more logical action level span to annunciator-basedevents. This level was changed to give consistency to the escalation of annunciator-related action levels,beginning with the new Rev. 24 U.E. ¹16 and ending with the modified Rev. 24 S.A.E. ¹11 (see explanationfor this EAL).

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: S.A.E. ¹11 Rev. 24 ¹: S.A.E. ¹11 0654 ¹: S.A.E. ¹12

1. Describe the proposed change(s) to the Emergency Plan.15 minute criterion and failure ofbackup, nonannunciating systems added to this S.A.E.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by giving a wider and more logical action level span to annunciator-basedevents. This level was changed to give consistency to the escalation ofannunciator-related action levels,beginning with the new Rev. 24 U.E. ¹16, leading to the modified Rev. 24 Alert ¹16, and ending with thismodified Rev. 24 S.A.E. ¹11. The PPC and SPDS are redundant systems that serve as backups to the plantannunciators. When in addition to the anriunciators these redundant systems fail during a significant planttransient, the risk has escalated to the S.A.E. level. The new U.E., Alert and S.A.E. provide better risk-relatedmanagement of annunciator failure events without overclassification as compared to the old Alert and S.A.E.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: U.E. ¹17 Rev. 24¹: U.E. ¹17

1. Describe the proposed change(s) to the Emergency Plan."(all Modes)" added for clarity and consistency. There is no actual change in this EAL, since in the lack ofthis added phrase, the "all Modes" applicability was implied in the previous revision.

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2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by explicitly stating in a more consistent manner what was implied in theprevious revision.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: U.E. ¹18 Rev. 24 ¹: U.E. ¹18 0654 ¹: U.E. ¹13a

1. Describe the proposed'change(s) Xo the'Emergency'Plan.As compared to the old revision, this new U.E. defines the earthquake as felt by a consensus of the ControlRoom operators, as opposed to anyone anywhere in the plant, per the old revision. The qualifying "or" ischanged to "AND " and the specific detector for the 0.01g threshold level is specified.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This revision willenhance the Plan by eliminating U.E. declarations for negligible earthquakes. Seismicinstrumentation at DCPP can generally record quakes too small to be felt in the Control Room. Also, quakeswhich may be felt in parts of the Protected Area, such as in the Administration Building, for example, mightnot be felt in the Control Room or other main plant areas which are seismically qualified or otherwise morefirmlybraced. Lastly, DCPP is engineered with significantly higher ground motions in mind than most otherU.S. nuclear power plants (i.e., a "significant" acceleration at another plant is likely much less "significant" atDCPP). Therefore, in order to preclude meaningless U.E. declarations at or below 0.01g acceleration, thisEAL has been rewritten as a reasonable interpretation of the EPRI-sponsored "Guidelines for Nuclear PlantResponse to an Earthquake" (10/89), to require the quake be both felt in the Control Room and be greate'r than0.01g in order to declare the event. An example of a "nuisance" U.E. declaration occurred at DCPP on 2/6/90.The quake was not felt in the Control Room, and was measured at 0.002g. However, the U.E. was declaredbecause one individual in the Administration Building (inside the plant Protected Area) felt the quake. Thesubsequent plant walkdown identified no

irregularities.'.

Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: U.E. ¹24 Rev. 24 ¹: U.E. ¹24 0654¹: U.E.¹14.d e

1. Describe the proposed change(s) to the Emergency Plan.This EAL has been revised to require that significant turbine damage has occurred, not that a rotatingcomponent has technically failed.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The minimum requirements of the previous revision do not warrant declaration of a U.E. The current revisionwas strengthened to require potential missiles or flammable gas or liquid release, in keeping with the definitionand anticipatory nature of a U.E. This should enhance the Plan by eliminating non-useful U.E. declarationsand limitingoperator attention to cases which indeed have real safety significance.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

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Rev. 23 ¹: Alert ¹22 Rev. 24¹: Alert ¹22 0654 ¹r Alert ¹18.e

1. Describe the proposed change(s) to the Emergency Plan.This EAL has been modified to require visual damage to safety related systems, not merely a turbine casingpenetration.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.In keeping with the Alert emergency level definition and the escalation of risk with increasing action level, thisEALwas changed to require apparent damage to safety related systems from the turbine break. This shouldenhancethePlan.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements'of Appendix'E to'IOCFR50.

'ee

the GENERAL DESCRIPTION above.

Rev. 23 ¹: U.E. ¹25 Rev. 24¹: U.E. ¹25 0654 ¹: U.E. ¹14.c

I. Describe the proposed change(s) to the Emergency Plan.Both bulk chlorine and now ammonia have been removed from the site, replaced by less dangerouscompounds. Rather than eliminate this EAL, it is being converted to a broad statement on all potentially toxicor flammable gasses and liquids.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The Plan should be enhanced by the new focus on a broad range ofpotentially dangerous compounds ratherthan on a particularly dangerous bulk compound that has been eliminated from the site. Refer to the new Rev.24 Alert ¹23.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: Alert¹23 Rev. 24¹: Alert ¹23 0654 ¹t Alert ¹18.d

1. Describe the proposed change(s) to the Emergency Plan.Both bulk chlorine and now ammonia have been removed from the site, replaced by less dangerouscompounds. Rather than eliminate this EAL, it is being converted to a broad statement on all potentially toxicor flammable gasses and liquids.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The Plan should be enhanced by the new focus on a broad range ofpotentially dangerous compounds ratherthan on a particularly dangerous bulk compound that has been eliminated from the site. Refer to the new Rev.24 U.E. ¹25.

3. Describe ifand how the revised Emergency plan.willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRXPTION above.

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Rev. 23 ¹: S.A.E. ¹16 Rev. 24 ¹r eleted 0654 ¹: S.A.E. ¹16.c

1. Describe the proposed change(s) to the Emergency Plan.This Rev. 23 EAL is being deleted.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.Both bulk chlorine and now ammonia have been removed from,the site, replaced by less dangerouscompounds. Revised Rev. 24 U.E. ¹25 and Alert ¹23 adequately cover the generic risk of toxic andfiammable gasses and liquids. Any needed S.A.E. declaration for such hazards may be made for the actualloss ofsafety systems and/or for radioactive releases under the remaining Rev. 24 S.A.E.s. The Plan should beenhanced by shifting focus away from a particularly dangerous bulk compound that has been eliminated fromthe site.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: U.E. ¹26 Rev. 24¹: U.E. ¹26 0654¹: U.E. ¹5

1. Describe the proposed change(s) to-the Emergency Plan.The previous plant shutdown-based EAL referencing Tech Spec 3.4.6.2 is replaced by one referencing specificRCS leakage limits (10gpm unidentified or 25gpm identified).

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This change willenhance the Plan for the following reasons. Entry into a plant shutdown Tech Spec ActionStatement does not constitute an emergency. If, however, the Action Statement time limitis exceeded, a U.E.willbe declared per new Rev. 24 U.E. ¹9. This Rev. 24 U.E. ¹26 willspecifically address RCS leakage limits.This EAL change should significantly reduce the probability ofunnecessary U.E.s reported to State andCounty governments. The new U.E. leakage limits, indicative ofpotential fuel clad degradation as a precursorto more serious problems, better meet the intent of the U.E. definition. Escalation to Alert level from this U.E.is addressed by Rev. 24 Sections II(Alert¹ 2), IV(Alert ¹s 4-8) and VI (Alerts ¹s 10-12). This revised EALwillenhance the importance of the U.E. classification by eliminating the declaration ofnon-useful U.E.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to IOCFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: S.A.E. ¹17 Rev. 24 ¹: S.A.E. ¹16 0654 ¹: S.A.E. ¹1

1. Describe the proposed change(s) to the Emergency Plan.This change willreplace the criterion of initiation of Safety Injection with that ofminimum subcoolingmargin and pressurizer level. Revision 10 to OP AP-1 now indicates the conservative action of manuallyinitiating SI ifthe primary leak rate exceeds 50 gpm. Thus, operationally, there is no difference between Rev.23 Alert ¹24 and Rev. 23 S.A.E. ¹17. In order to give a graded response to escalating risk in keeping with thegeneral descriptions of the accident classifications, this S.A.E., now Rev. 24 S.A.E. ¹16, is being modified perthe SI Actuation Criteria in EOP E-O.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This change willmaintain the effectiveness of the Plan by retaining the escalation of response appropriate tothe increase in risk for the LOCA initiating condition, despite the change in OP AP-1.

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3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to IOCFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: U.E. ¹27 Rev. 24¹: U.E. ¹27 0654¹: U.E.¹1

1. Describe the proposed change(s) to the Emergency Plan.Qualifier added that the SI signal must be a valid signal based on actual plant conditions.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.The revised'EAL willdistinguish'between a'vali'd arid non-valid SI. The'iion-valid'SI willlikely be reportableunder 10CFR50.72(b)(2)(ii) as a non-emergency event (four hour report). The valid SI willbe declared a U.E.per this revised EAL, better meeting the definition of a U.E.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: S.A.E. ¹18 Rev. 24 ¹: eleted

1. Describe the proposed change(s) to the Emergency Plan.This S.A.E. is being deleted.

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.This EAL is redundant to criteria in G.E. ¹3 (Loss ofFission Product Bamers). This revision willenhance thePlan by eliminating a redundant and potentially confusing EAL.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹: S.A.E. ¹19 Rev. 24 ¹: S.A.E. ¹17

1. Describe the proposed change(s) to the Emergency Plan.Editorial changes made to clarify intent, including changing "secondary" to "steamline."

2. Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.-This revision willenhance the Plan by explicitly stating in a more specific manner what was intended in theprevious revision.

3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of 10CFR50.47(b)and the requirements ofAppendix E to 10CFR50.

See the GENERAL DESCRIPTION above.

Rev. 23 ¹i V.E. ¹29 Rev. 24¹: V.E. ¹29

1. Describe the proposed change(s) to the Emergency Plan.Add "fails" as an editorial clarification (originally intended meaning unchanged).

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~'.Describe the effect of the proposed change(s) on the effectiveness of the Emergency Plan.

This change should enhance the plan by clarifying the original intent of this EAL.3. Describe ifand how the revised Emergency plan willcontinue to meet the standards of IOCFR50.47(b)

and the requirements ofAppendix E to 10CFR50.See the GENERAL DESCRIP rlON above.

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