ML032890431

Event Classification Guide Technical Basis, 10/08/03, Change Pages for Revision No. 18

ML032890431
Person / Time
Site:	Salem
Issue date:	10/08/2003
From:	Banner C Public Service Enterprise Group
To:	David Pinckney Document Control Desk, Office of Nuclear Security and Incident Response
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Document Transmittal Form TO  : NRCC/O PINCKNEY, DAVID ID: SECGO101 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 PRCISECG-SECG-TOCBASIS1000 18 A I H 177791 PRCISECG-SECT.06.4 (BASIS)1000 I A I H 177829 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(1) the above documents have been filed and superseded documents have been removed and destroyed or clearly marked as obsolete.

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JNOLV5

SALEM GENERATING STATION EVENT CLASSIFICATION GUIDE TECHNICAL BASIS October 08, 2003 CHANGE PAGES FOR REVISION #18 The Table of Contents forms a general guide to the current revision of each section and attachment of the Salem ECG Technical Basis. The changes that are made in this TOC Revision #18 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 Remove and recycle the outdated material listed below.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 18 All TOC 17 All Section 6.4 01 All Section 6.4 00 S-ECG 1 of 1

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

Pg. 1 of 4 SALEM ECG TECHNICAL 3ASIS TABLE OF CONTENTS/SIGNATURE PAGE SECTION TITLE REV # PAGES DATE T.O.C. Table of Contents/Signature Page 18 4 10/08/03 i Introduction and Usage 00 3 01/21/97 ii Glossary of Acronyms & Abbreviations 00 6 01/21/97 1.0 Fuel Clad Challenge 01 4 12/29/99 2.0 RCS Challenge 01 2 07/24/00 3.0 Fission Product Barriers (Table) 3.1 Fuel Clad Barrier 02 20 02/27/03 3.2 RCS Barrier 02 16 01/16/01 3.3 Containment Barrier 05 26 01/31/03 4.0 EC Discretion 00 8 01/21/97 5.0 Failure to Trip 03 9 12/18/01 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release 00 42 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 01 10 10/08/03 7.0 Electrical Power 7.1 Loss of AC Power Capabilities 02 11 01/16/01 7.2 Loss of DC Power Capabilities 00 8 01/21/97 8.0 System Malfunctions 8.1 Loss of Heat Removal Capability 01 10 12/29/99 8.2 Loss of Overhead Annunciators 02 6 07/24/00 8.3 Loss of Communications Capability 00 4 01/21/97 8.4 Control Room Evacuation 01 4 12/18/01 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 02 6 01/16/01 9.3 Explosion 02 5 01/16/01 9.4 Toxic/Flammable Gases 03 12 09/26/02 9.5 Seismic Event 02 4 09/26/02 9.6 High Winds 01 5 01116/01 9.7 Flooding 02 5 01/16/01 9.8 Turbine Failure/Vehicle Crash/Missile Impact 02 7 01/16/01 9.9 River Level 01 4 01/16/01 PSE&G xi>

CONTROL 1-SGS COPY #SFUC&,)01 Rev. 18

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

Pg. 2 of 4 SALEM ECG TECHNICAL BASIS TABLE OF CONTENTS/SIGNATURE PAGE SECTION TITLE REV # PAGES DATE 10.0 Reserved for future use Licensing is responsible for the Reportable Action Level (Section 11)

Reportable Action Levels (RALs) 11.1 Technical Specifications 01 9 01/23/01 11.2 Degraded or Unanalyzed Condition 02 4 01/23/01 11.3 System Actuation 04 7 04/19/02 11.4 Personnel Safety/Overexposure 01 7 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 03 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 SGS Rev. 18

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

Pg. 3 of 4 REVISION

SUMMARY

Biennial Review Perforned: Yes__ No X Updated EAL Basis for 6.4.2.a and 6.4.2.b to correct reference to EALs for other conditions.

SGS Rev. 18

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

Pg. 4 of 4 SIGNATURE PAGE Prepared By: Craig Banner 09/17/03 Date Section/Attachments Revised: N/A N/A (List Non Editorial Only - Section/Attachments) Date Reviewed By: N/A N/A 10CFR50.54q Effectiveness Reviewer Date Reviewed By: N/A N/A Department Manager Date Reviewed By: N/A N/A Manager - Licensing Date Reviewed By:

EP Managei ate Reviewed By: NA N/A Manager - Quality Assurance Date (If Applicable)

SORC Review and Station Approvals NA N/A Mtg. No. Salem Chairman Vice President - Nuclear Operations N/A N/A Date Date Effective Date of this Revision:

Date SGS Rev. +- /6

SGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.4 Irradiated Fuel Event PSE&G  ; t. -

UNUSUAL EVENT - 6.4.1.a CONTROL by I-Vs IC Unplanned increase in Plant Radiation COPY #Quito I EAL An uncontrolled level drop in the Refueling Cavity as indicated by EITHER one of the following:

• Visual observation

• RVLIS - Refueling Mode MODE - 6 BASIS This EAL condition indicates a possible failure of the Refueling Cavity Seal or RHR System that results in inventory loss from the Refueling Cavity when flooded. Coverage of these events is appropriate due to the potential for higher doses to plant staff. These events have 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. Classification as an Unusual Event is warranted as a precursor to a more serious event. Uncontrolled means that the level drop cannot be terminated, or level cannot be maintained by operator action.

Barrier Analysis N/A ESCALATION CRITERIA This event will be escalated to an Alert as a result of uncovery of a fuel assembly and/or indication of high radiation levels on the refueling floor.

DISCUSSION Design of the Refueling Cavity is such that a liner failure in these volumes is unlikely; however, should such a failure occur, it would come under this EAL. If uncovery of fuel elements occur or EAL - 6.4.L.a Rev. 01 Page 1 of 2

SGS EAL/RALTechnical Basis if there is indication of high radiation levels on the refuel floor then the event will be classified as an Alert.

During refueling operations the Reactor Vessel and Refuel Cavity are flooded. During fuel handling operations, the Fuel Transfer Tube will connect the Reactor Cavity and the Spent Fuel Pool. An unexplained lowering of Refuel Cavity level or Spent Fuel Pool level can be an indication that these volumes are draining. A drop in Reactor Cavity and Spent Fuel Pool level may result in a Spent Fuel Pool low level alarm. This alarm would be validated by visual observation of lowering level in the Refuel Cavity/Spent Fuel Pool.

DEVIATION NUMARC states that this EAL will be applicable in all modes of operation. In modes other than Mode 6 the Reactor Vessel head will be fully tensioned and there will be no interconnection between the Refueling Cavity and the Spent Fuel Pool. In other modes, a loss of Reactor Vessel inventory is addressed in Section 3. Uncontrolled loss of water level in the Spent Fuel Pool, however, is classified under EAL 6.4.1.b in all modes of operation.

REFERENCES NUMARC NESP-007, AU2.1 OP-ARZZ-0003(Q) OHA-C35 OP-AB.FUEL-0002(Q)

EAL - 6.4.1.a Rev. 01 Page 2 of 2

SGS 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 Valid SFP Low Level alarm - OHA C-35 AND Visual observation of an uncontrolled level drop in the Spent Fuel Pool MODE - All BASIS These EAL conditions indicate a possible failure of the Spent Fuel Pool Cooling System that results in inventory loss from the Spent Fuel Pool. This EAL also works in conjunction with the loss of Refueling Cavity EAL for Mode 6 operations, with the Spent Fuel Pool and Refueling Cavity connected via the Fuel Transfer Canal.

Coverage of this event is appropriate due to the potential for higher doses to plant staff. 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. Classification as an Unusual Event is warranted as a precursor to a more serious event. Uncontrolled means that the level drop cannot be terminated, or level cannot be maintained by operator action.

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

EAL - 6.4.L.b Rev. 01 Page 1 of 2

SGS EAL/RALTechnical Basis DISCUSSION Design of the Spent Fuel Pool (SFP) is such that a liner failure in this volume is unlikely; however, should such a failure occur, it would be classified under this EAL. Lowering of water level in the SFP to below the level of the spent fuel bundles may result in a rise in the airborne contamination level in the Fuel Handling Building. If uncovery of fuel elements occurs or if there is indication of high radiation levels in the Fuel Handling Building, then the event will be classified as an Alert.

This alarm would be validated by visual observation of lowering level in the Spent Fuel Pool.

The added requirement for an uncontrolled drop in SFP level with a low level alarm is included to allow normal makeup to recover level for minor level deviations due to evaporation losses, etc.

DEVIATION None REFERENCES NUMARC NESP-007, AU2.2 OP-AR.ZZ-0003(Q) OHA-C35 OP-AB.FUEL-0002(Q)

EAL - 6.4.L.b Rev. 01 Page 2 of 2

SGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.4 Irradiated Fuel Event ALERT - 6.4.2.a IC Major Damage to Irradiated Fuel or Loss of Water Level that has or will result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel EAL Major Damage to Irradiated Fuel reported in the Fuel Handling Bldg.

AND Valid High Alarm is received on EITHER one of the following RMS channels:

• R5

• R32A AND Valid High Alarm received from EITHER one of the following RMS channels:

• R41

• R45 MODE - All BASIS Major Damage to an irradiated fuel bundle that results in a High Fuel Handling Building Radiation Monitor alarm coincident with a Plant Vent Effluent Process Radiation Monitor alarm warrants declaration of an Alert, due to the potential for an 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 higher 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.c, when those conditions exist. I1-Major Damage is defined as physical damage to an Irradiated Fuel Bundle that results from either dropping or physical contact with other components, such that the magnitude of the EAL - 6.4.2.a Rev. 01 Page 1 of 2

SGS EAL/RALTechnical Basis damage specifically results in actuation of an Area Radiation Alarm. Valid is defined as the High alarm occurring as a result of the damage to the irradiated fuel bundle.

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 Fuel Handling Building Area Monitors provide an early warning of developing problems which may be related to a damaged fuel bundle. The Plant Vent Exhaust Rad Monitors are Process Monitors and are designed to detect a release of Fission Products. Hence, they are included as part of the EAL threshold, to confirm the magnitude of damage to an irradiated fuel bundle.

DEVIATION None REFERENCES NUMARC NESP-007, AA2.1 OP-AR.ZZ-0003(Q) OHA-C35 OP-AB.FUEL-0002(Q)

NUREG/CR-4982 NRC Information Notice no. 90-08 10CFR50 EAL - 6.4.2.a Rev. 01 Page 2 of 2

SGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.4 Irradiated Fuel Event ALERT - 6.4.2.b IC Major Damage to Irradiated Fuel or Loss of Water Level that has or will result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel EAL Major Damage to Irradiated Fuel reported in the Containment AND Valid High Alarm received on ANY one of the following RMS channels:

R2

• R1OA

• ROB AND Valid High Alarm received from ANY one of the following RMS channels:

• RlA

• R12A

• R12B MODE - All BASIS Major Damage to an irradiated fuel bundle that result in a High Containment Area Radiation Monitor alarm coincident with a Containment Process Radiation Monitors alarm warrants declaration of an Alert, due to the potential for an offsite release exceeding the Technical Specification limit. The intent of this EAL is to classify those events that result in the potential release of fission products from an irradiated Fuel Bundle, due to physical damage. Events that result in higher 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.c, when those conditions exist. I EAL - 6.4.2.b Rev. 01 Page 1 of 2

SGS EAL/RALTechnical Basis Major Damage is defined as physical damage to an Irradiated Fuel Bundle that results from either dropping or physical contact with other components, such that the magnitude of the damage specifically results in actuation of an Area Radiation Alarm. Valid is defined as the High alarm occurring as a result bf the damage to the irradiated fuel bundle.

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 Containment Area Monitors provide an early warning of developing problems which may be related to a damaged fuel bundle. The Containment Rad Monitors are Process Monitors and are designed to detect a release of Fission Products. Hence, they are included as part of the EAL threshold, to confirm the magnitude of damage to an irradiated fuel bundle.

DEVIATION None REFERENCES NUMARC NESP-007, AA2.1 OP-AR.ZZ-0003(Q) OHA-C35 OP-AB.FUEL-0002(Q)

NUREG/CR-4982 NRC Information Notice no. 90-08 EPA 400-R-92-00 1,Manual of Protective Action Guide and Protective Actions for Nuclear Incidents EAL - 6.4.2.b Rev. 01 Page 2 of 2

SGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.4 Irradiated Fuel Event ALERT - 6.4.2.c/6.4.2.d IC Major Damage to Irradiated Fuel or Loss of Water Level that has or will result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel 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

• R2

• R5 R9

• R32A

• Visual observation of Irradiated Fuel uncovered MODE - All BASIS This EAL indicates a possible failure of the Refueling Cavity Seal, RHR System, or Spent Fuel Pool Cooling System that results in inventory loss from the Refueling Cavity when flooded or the Spent Fuel Pool. Design of the Refueling Cavity and Spent Fuel Pool is such that a liner failure in these volumes is unlikely; however, should such a failure occur, it would come under this EAL. Lowering of water level in the Spent Fuel Pool to such a value as to cause Dose Rates to increase to this value will result in evacuation of the local areas. Uncovery of irradiated fuel elements can lead to their fuel clad failure due to loss of cooling.

The term "unplanned" is defined as those events which are not associated with a pre-planned evolutions such that radiation levels are increasing for reasons which cannot be immediately explained. The EAL addresses radiation levels which would impede operation of systems required to continue efforts to stop the loss of Refueling water level. Radiation levels could be indicated by ARM or radiological survey. The Dose Rate of 2000 mRem/hr was chosen as a threshold based upon NAP-24 Administrative Dose Limits and Extension criteria which has Senior Radiation Protection Supervisor approval required prior to exceeding 2000 mRem/yr.

EAL - 6.4.2.c/ 6.4.2.d Rev. 01 Page 1 of 2

SGS EAL/RALTechnical Basis This value is low enough to ensure classification of an Alert before personnel access is severely hampered and high enough to allow any unplanned rise in normal radiation level, by a factor of 1000, to be classified as an Unusual Event per EAL 6.3.1.

Visual observation of irradiated fuel uncovered will result in onsite dose levels changing significantly.

The Area Radiation Monitors included in this EAL are:

• R2 Containment, General Area Low

• R5 Fuel Handling Building Area Fuel Pool

• R9 Fuel Handling Building Fuel Storage Area

• R32A Spent Fuel Handling Crane, Area Monitor Barrier Analysis N/A ESCALATION CRITERIA This event will be escalated to a Site Area Emergency when loss of control of radioactive materials causes significant offsite doses.

DISCUSSION It is understood that a drop in Refueling Cavity water level will cause Dose Rates to rise due to the uncovery of irradiated Reactor components other than a spent fuel assembly. However, Dose Rates in excess of 2 Rem/hr indicate a loss of level such that recovery options may be limited and thus an Alert declaration is warranted.

DEVIATION None REFERENCES NUMARC NESP-007, AA2.3 and AA2.4 OP-AR.ZZ-0003(Q) OHA-C35 OP-AB.FUEL-0002(Q)

NUREG/CR-4982 NRC Information Notice no. 90-08 EAL - 6.4.2.c/ 6.4.2.d Rev. 01 Page 2 of 2