ML032890256

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Event Classification Guide Technical Basis, 10/08/03, Change Pages for Revision No. 21
ML032890256
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 10/08/2003
From: Banner C
Public Service Enterprise Group
To: David Pinckney
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML032890256 (14)
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Document Transmittal Form TO  : NRC C/O PINCKNEY, DAVID ID: HECGO065 DOCUMENT CONTROL DESK WASHINGTON, DC 20555 Date: 10/8/03 Please update your controlled set of documents with the following documents:

Document ID Revision Status Quantity Format RecNo PRCIHECG-HECG-TOC-BASISIOOO 21 A I H 177866 PRCIHECG-SECT.06.4 (BASIS)1000 2 A I H 177908 ALL PAGES of this acknowledgement receipt must be returned to:

Document Management PSEG Nuclear PO Box 236 Hancocks Bridge, NJ 08038 MC N04 Your signature below verifies that (1) the above documents have been filed and superseded documents have been removed and destroyed or clearly marked as obsolete.

(2) the mailing address and copyholder information are correct or corrections have been identified on this transmittal.

r] Place checkmark here to be removed from controlled distribution Signature: Date:

/1D4L5

HOPE CREEK GENERATING STATION EVENT CLASSIFICATION GUIDE TECENICAL BASIS October 8, 2003 CHANGE PAGES FOR REVISION #21 The Table of Contents forms a general guide to the current revision of each section and attachment of the Hope Creek ECG Technical Basis. The changes that are made in this TOC Revision

  1. 21.are shown below.
1. Check that your revision packet is complete.
2. Add the revised documents.
3. Remove and recycle the outdated material listed below.

ADD REMOVE Pares Description Rev. Pages Description Rev.

ALL TOC 21 All TOC 20 All Section 6.4 02 All Section 6.4 01 HC-ECG TB 1 of 1

PSEG Internal Use Only 'HC EAL Technical Basis T.O.C.

Pg. I of 4 HOPE CREEK ECG TECHNICAL BASIS TABLE OF CONTENTS/SIGNATURE PAGE SECTION TITLE REV# IPAGES DATE T.O.C. Table of Contents/Signature Page 21 4 10/08/03 i Introduction and Usage 00 3 01/21/97 ii Glossary of Acronyms & Abbreviations 00 5 01/21/97 1.0 Fuel Clad Challenge 01 9 06/14/01 2.0 RCS Challenge 00 8 01/21/97 3.0 Fission Product Barriers (Table) 3.1 Fuel Clad Barrier 03 13 02/01/02 3.2 RCS Barrier 02 18 02/01/02 3.3 Containment Barrier 04 16 11/11/02 4.0 EC Discretion 00 8 01/21/97 5.0 Failure to SCRAM 00 10 01/21/97 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release 00 44 01/21/97 6.2 Liquid Effluent Release 00 4 01/21/97 6.3 In - Plant Radiation Occurrences 00 6 01/21/97 6.4 Irradiated Fuel Event 02 8 10/08/03 7.0 Electrical Power 7.1 Loss of AC Power Capabilities 01 18 05/12/97 7.2 Loss of DC Power Capabilities 00 5 01/21/97 8.0 System Malfunctions 8.1 Loss of Heat Removal Capability 02 8 04/30/03 8.2 Loss of Overhead Annunciators 00 8 01/21/97 8.3 Loss of Communications Capability 00 4 01/21/97 8.4 Control Room Evacuation 00 4 01/21/97 8.5 Technical Specifications 00 2 01/21/97 9.0 Hazards - Internal/External 9.1 Security Threats 02 9 02/01/02 9.2 Fire 01 6 02/01/01 9.3 Explosion 01 5 02/01/01 9.4 Toxic/Flammable (3ases 02 13 11/11/02 9.5 Seismic Event 02 4 11/11/02 9.6 High Winds 01 7 02/01/01 9.7 Flooding 01 5 02/01/01 9.8 Turbine Failure/ye MhiOe Crash/ 7 02/01/01 Missile Impact 9.9 River Level PRE -&G E 00

. I 1 :

I

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4 01/21/97 CONTROI HCGS COPY # hLCC&(O5 Rev. 21

PSEG Internal Use Only HC EAL Technical Basis T.O.C.

Pg. 2 of 4 HOPE CREEK ECG TECHNICAL BASIS TABLE OF CONTENTS/SIGNATURE PAGE SECTION TITLE REV # PAGES DATE 10.0 Reserved for future use 11.0 Reportable Action Levels (RALs) 11.1 Technical Specifications 02 7 01/23/01 11.2 Degraded or Unanalyzed Condition 03 4 02/28/02 11.3 System Actuation 05 7 04/19/02 11.4 Personnel Safety/Overexposure 01 8 01/23/01 11.5 Environmental/State Notifications 02 4 10/01/03 11.6 After-the-Fact 02 1 02/28/02 11.7 Security/Emergency Response 04 5 02/28/02 Capabilities 11.8 Public Interest 01 3 01/23/01 11.9 Accidental Criticality/ 02 8 01/23/01 Special Nuclear Material /

Rad Material Shipments - Releases 11.10 Voluntary Notifications 01 2 01/23/01 HCGS Rev. 21

PSEG Internal Use Only HC EAL Technical Basis T.O.C.

Pg. 3 of 4 REVISION

SUMMARY

Biennial Review Performed: Yes_ _ No X Updated EAL Basis for 6.4.2.a and 6.4.2.b/c to correct reference to non-existent EALs.

HCGS Rev. 21

PSEG Internal Use Only HC EAL Technical Basis T.O.C.

Pg. 4 of 4 SIGNATURE PAGE Prepared By: C. Banner 09/16/03 Date Section/Attachments Revised: N/A (List Non-Editorial Only - Section/Attachments) Date Reviewed By: N/A I OCFR50.54q Effectiveness Reviewer Date Reviewed By: N/A Department Manager Date Reviewed By:

Manager - Licensing Date (Reportable Action Level, Section 11)

Reviewed By:

Date Reviewed By: N/A Manager - Quality Assessment - NBU Date (If Applicable)

SORC Review and Station Approvals N/A N/A Mtg. No. Hope Creek Chairman Vice President - Nuclear Operations Date Date Effective Date of this Revision: Io /OR J0_3 4 - - 04 Date HCGS Rev. 21

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrencps -

6.4 Irradiated Fuel Event PSE&G  ;

UNUSUAL EVENT - 6.4.1.a CONTROL IC Unplanned Increase in Plant Radiation COPY# Hat/-cXYOs EAL Uncontrolled water level drop in the Reactor Cavity as indicated by EITHER one of the following:

  • Visual Observation
  • Reactor Water Level Shutdown Range Indicator lBBLI-R605 OPERATIONAL CONDITION - 5 BASIS An Uncontrolled lowering of Reactor Cavity Level during Refueling (Operational Condition 5) represents a condition which can result in rising radiation levels, due to the loss of radiation shielding, if the Reactor Cavity level drop can not be terminated. This event has a long lead time relative to potential for radiological release outside the site boundary, thus the impact to public health and safety is very low. Uncontrolled means that the level drop can not be terminated.

Determination of an uncontrolled level drop is made through either Visual Observation or indication in the Main Control Room. Visual Observation is the preferred method, whenever possible, however it is NOT intended that an individual must be dispatched for classification purposes, if the existing radiation level rise trend prevents personnel from accessing the Refuel Floor, or if cameras are available to remotely verify the condition. In the event visual observation is not available by any means, then Main Control Room indication should be used.

Barrier Analysis N/A EAL - 6.4.l.a Rev. 02 Page 1 of 2

HCGS EAL/RALTechnical Basis ESCALATION CRITERIA Emergency Classification will escalate to an Alert as a result of uncovery of a fuel assembly and/or indication of high radiation levels on the refueling floor.

DISCUSSION During Refueling operations, the RPV is flooded and RPV level indication is monitored on the shutdown instrument range. Limitations on evolutions on with a potential for draining the RPV are imposed when refueling is in progress. Lowering of RPV level may result in the loss of Shutdown Cooling if RPV level continues to lower unchecked. This may result in the loss of decay heat removal from the fuel contained in the RPV.

Technical Specifications requires at least 22 feet 2 inches of water be maintained over the top of the reactor pressure vessel flange while in Operating Condition 5 and either fuel assemblies are being handled or the fuel assemblies seated within the reactor vessel are irradiated. The Technical Specification minimum water level in the Reactor Vessel under these conditions is based on the minimum water level required to remove 99% of the assumed 10% iodine gap activity that would be released from the rupture of an irradiated fuel assembly.

DEVIATION

1) NUMARC states that this EAL will be applicable in all modes of operation. In other than Operational Condition 5, the RPV head will be fully tensioned, and lowering of vessel level would be classified by EALs in Section 3.0, Fission Product Barriers, or Section
8. 1,Loss of Heat Removal Capability.
2) NUMARC IC AU2 includes unexpected increases in Airborne concentration in addition to plant radiation. The corresponding Hope Creek IC does not address Airborne concentration, since an increase in Airborne concentration is not addressed in the example EALs or the basis for the Unusual Event or Alert. Apparently, the Airborne concentration example EAL was deleted by NUMARC, but the corresponding IC was overlooked.

REFERENCES NUMARC NESP-007, AU2.1 HC.OP-AB.ZZ.0142 (Q), Loss of Shutdown Cooling HC.OP-AB.ZZ-0144 (Q), Loss of Fuel Pool Inventory/Cooling HC.OP-AB.ZZ-0101 (Q), Irradiated Fuel Damage HC.OP-AB.ZZ-126 (Q), Abnormal Release of Gaseous Radioactivity HCGS Technical Specifications Section 3/4 9.8 EAL - 6.4.L.a Rev. 02 Page 2 of 2

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.4 Irradiated Fuel Event UNUSUAL EVENT - 6.4.1.b IC Unplanned Increase in Plant Radiation EAL as indicated by Uncontrolled water level drop in the Spent Fuel Pool Uncontrolled water level drop in the Spent Fuel Pool as indicated by Valid Fuel Pool Low Level Alarm Condition AND Visual Observation OPERATIONAL CONDITION - All BASIS An Uncontrolled drop in Spent Fuel Pool Level represents a condition which can result in rising radiation levels, due to the loss of radiation shielding, if the Spent Fuel Pool level drop can not be terminated. This event has a long lead time relative to potential for radiological release outside the site boundary, thus the impact to public health and safety is very low. Uncontrolled means that the level drop can not be terminated.

Determination of an uncontrolled level drop is made through receipt of the Spent Fuel Pool Low Level Alarm in the Main Control Room and Visual Observation.

Barrier Analysis N/A ESCALATION CRITERIA Emergency Classification will escalate to an Alert as a result of uncovery of irradiated fuel as indicated by high radiation levels on the refueling.

EAL - 6.4. L.b Rev. 02 Page I of 2

HCGS EAL/RALTechnical Basis DISCUSSION Normal Spent Fuel Pool level is at 40' of water in the pool. This level provides approximately 25' of water above the top of fuel stored in pool, and 9' of water above fuel in transit. The low level alarm is set at 39' 9". This is above, but approaching the Technical Specification minimum required water level of 23 feet over the top of irradiated fuel assemblies seated in the spent fuel pool storage racks. The Technical Specification minimum water level in the Spent Fuel Pool is based on the minimum inventory and level required to remove 99% of the assumed 10% iodine gap activity that would be released from the rupture of an irradiated fuel assembly.

To prevent accidental draining of the Spent Fuel Pool, no piping connections are made to the fuel pool below the normal water level. The spent fuel pool cooling water return lines are provided with vacuum breakers to prevent water from being siphoned out of the fuel pool should a break occur in one of these lines. The skimmer surge tanks receive the overflow from the spent fuel pool and serve as the suction source to the fuel pool cooling pumps. Lowering of level in the skimmer surge tank will result in isolation of the pool filter demineralizers. This will result in the loss of the fuel pool cooling pumps. Subsequent heating of the water in the spent fuel pool may occur depending on the heat load present.

DEVIATION NUMARC IC AU2 includes unexpected increases in Airborne concentration in addition to plant radiation. The corresponding Hope Creek IC does not address Airborne concentration, since an increase in Airborne concentration is not addressed in the example EALs or the basis for the Unusual Event or Alert. Apparently, the Airborne concentration example EAL was deleted by NUMARC, but the corresponding IC was overlooked.

REFERENCES NUMARC NESP-007, AU2.2 HC.OP-AR.ZZ-0014(Q), Annunciator Response Procedures, Window D3-A5 (D3834)

HC.OP-AB.ZZ-0 144 (Q), Loss of Fuel Pool Inventory/Cooling HC.OP-AB.ZZ-0IO1 (Q), Irradiated Fuel Damage HC.OP-AB.ZZ-126 (Q), Abnormal Release of Gaseous Radioactivity HCGS Technical Specifications Section 3/4 9.9 HCGS UFSAR, Section 9.2.2.2 EAL - 6.4.L.b Rev. 02 Page 2 of 2

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.4 Irradiated Fuel Event ALERT - 6.4.2.a IC Major Damage to Irradiated Fuel EAL Major Damage to Irradiated Fuel has occurred AND Valid High Alarm received from ANY one of the following RMS channels:

  • Refuel Floor Exhaust Channel A (9RX627)
  • Refuel Floor Exhaust Channel B (9RX628)
  • Refuel Floor Exhaust Channel C (9RX629)

OPERATIONAL CONDITION - All BASIS Damage to an irradiated fuel bundle that results in a High Refuel Floor Exhaust Radiation Monitor alarm warrants declaration of an Alert, due to the potential for an uncontrolled offsite release exceeding the Technical Specification limit. The intent of this EAL is to classify those events that result in the actual release of fission products from an irradiated Fuel Bundle, due to physical damage.

Events that result in rising radiation levels due to shine, as a result of lowered shielding, but do not involve a release of fission products, should not be classified under this EAL, but should be classified EAL 6.4.2.b when those conditions exist. I Major Damage is defined as physical damage to an Irradiated Fuel Bundle that results from either dropping or physical contact with other components in the Fuel Pool or Reactor Cavity, such that the magnitude of the damage specifically results in actuation of a Refuel Floor Exhaust High Radiation Alarm. Valid is defined as the High alarm occurring as a result of the damage to the irradiated fuel bundle which results in an actual release of fission products from the cladding.

EAL - 6.4.2.a Rev. 02 Page 1 of 2

HCGS EAL/RALTechnical Basis Barrier Analysis N/A ESCALATION CRITERIA Emergency Classification will escalate to a Site Area Emergency when loss of control of radioactive materials causes significant offsite doses.

DISCUSSION The Refuel Floor Exhaust Rad Monitors are Process Monitors and are designed to detect a release of Fission Products to the Reactor Building atmosphere. Hence, they are included as part of the EAL threshold, to confinn the magnitude of damage to an irradiated fuel bundle. These monitors can also react as Area Radiation Monitors, in the event of rising radiation levels due to lowered shielding, as would occur during a loss of Fuel Pool inventory event. It is important to distinguish between the cause for rising radiation levels when classifying an event under this EAL.

DEVIATION None REFERENCES NUMARC NESP-007, AA2.1 HC.OP-SO.SM-O001(Q), Isolation Systems Operation HC.OP-AB.ZZ-01 16(Q), Containment Isolations and Recovery from an Isolation HC.RP-AR.SP-0001(Q), Radiation Monitoring System Alarm Response, Att. 54, 55, 56 HCGS Technical Specifications, 3.3.2 Table 3.3.2-2 HCGS-UFSAR, Section 11.5.2 NUREG/CR4982 NRC Information Notice 08 EAL - 6.4.2.a Rev. 02 Page 2 of 2

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.4 Irradiated Fuel Event ALERT - 6.4.2.b/6.4.2.c IC Events that have or may result in uncovering Irradiated Fuel outside the Reactor Vessel EAL EITHER one of the following:

  • Unplanned rise on ANY one of the following Area Rad Monitors or by general area rad survey indicates > 2000 mRem/hr:
  • Spent Fuel Storage Pool Area (9RX707)
  • New Fuel Criticality Storage Channel A (9RX612)
  • New Fuel Criticality Storage Channel B (9RX613)
  • Visual observation of Irradiated Fuel uncovered OPERATIONAL CONDITION - All BASIS An Unplanned Dose Rate of 2000 mRem/hr as indicated on any of the Refuel Floor Area Radiation Monitors (ARMs) warrants declaration of an Alert, as dose rates of this magnitude could be the result of a loss of shielding of irradiated Fuel Bundles or possible damage to an irradiated Fuel Bundle. Offsite doses during these accidents would be well below the EPA Protective Action Guidelines and the classification as an Alert is therefore appropriate.

The intent of these EALs is to classify those events that result in rising dose rates on the Refuel Floor. Specifically, those events that result in rising radiation levels due to shine, as a result of lowered shielding, but do not involve a release of fission products should be classified under this EAL. Those events that result in physical damage to an irradiated fuel assembly and are accompanied by rising radiation levels should not be classified under this EAL, but should be classified EAL 6.4.2.a, when those conditions exist.

I Unplanned is defined as those events or conditions which are not associated with a planned evolution, such as lifting of the Reactor Vessel Internals, that results in radiation levels are rising EAL - 6.4.2.b/6.4.2.c Rev. 02 Page 1 of 2

HCGS EAL/RALTechnical Basis in an uncontrolled manner. The Dose Rate threshold of 2000 mRem/hr was chosen based upon NC.NA-AP.ZZ-0024, Radiation Protection Program Administrative Dose Limits and Extension criteria which requires Senior Radiation Protection Supervisor approval prior to exceeding 2000 mRem/yr TEDE. This value is low enough to ensure classification of an Alert before personnel access is severely hampered and high enough to allow any rise in normal radiation level, by a factor of 1000, to be classified as an Unusual Event per EAL 6.3.1 Radiation levels could be indicated by either ARMs or radiological survey.

Uncovered irradiated fuel will result in Onsite dose rates rising significantly.

Barrier Analysis N/A ESCALATION CRITERIA Emergency Classification will escalate to a Site Area Emergency when loss of control of radioactive materials causes significant offsite doses.

DISCUSSION The Refuel Floor ARMs are designed to detect rising radiation levels on the Refuel Floor.

Hence, they are included as part of the EAL threshold, to determine the magnitude of a loss of shielding to irradiated Fuel Bundles.

Actual Damage to an irradiated fuel bundle will also cause a rise in these ARMs, however the Refuel Floor Exhaust Rad Monitors are specifically designed to detect the actual release of fission products to the atmosphere. It is important to distinguish between the possible causes for rising radiation levels when classifying an event under these EALs.

DEVIATION None REFERENCES NUMARC NESP-007, AA2.3, AA2.4 HCGS Technical Specifications, 3.3.7.1, Table 3.3.7.1-1 HC.RP-AR.SP-0001(Q), Radiation Monitoring System Alarm Response, Att. 41, 42, 77 NUREG-1229, Source Term Estimation During Incident Response to Severe Nuclear Power Plant Accidents EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions For Nuclear Incidents NRC Information Notice 08 EAL - 6.4.2.b/6.4.2.c Rev. 02 Page 2 of 2

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