ML033030477
| ML033030477 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  (DPR-049) |
| Issue date: | 10/21/2003 |
| From: | Dunlap K Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EBD-H, Rev 6 | |
| Download: ML033030477 (33) | |
Text
-'--I NMC Committed to Nuclear Excellence DAEC EMERGENCY PLANNING DEPARTMENT PROCEDURE TRANSMITTAL ACKNOWLEDGEMENT MEMO (TAM-94)
To:
NRC-NRR Document Control Desk US NRC Washington DC 20555 Re:
Entire EAL Basis Document (Table of Contents Rev) (Copy 91)
PSM
Title:
n/a Distribution Date:
Effective Date of Change:
Return by:
10 /21 /2003 10 /21 /2003 11/03/2003 Please perform the following to your assigned manual. If you have any questions regarding this TAM please contact Don A. Johnson at 319-851-7872.
REMOVE Rev. 15 WIRL-Table of Contents Revision INSERT Rev. 16 Revved
- A1 EAL EBD-H (PWR: 22850)
Remove rev 6 and insert rev 6A.
Rev./
PERFORMED BY:
Print Name Sign Name Date Please return to:
K. Dunlap PSC/Emergency Planning 3313 DAEC Rd.
Palo, IA 52324 To be completed by DAEC EP personnel only:
Date TAM returned:
EPTools updated:
A04S
Committed to Nuclear Excellenc Duane Arnold Energy Center Operated by Nuclear Management Company, LLC Tuesday, October 21, 2003 NRC-NRR Document Control Desk US NRC Washington, DC 20555 To: NRC-NRR Document Control Desk From: DAEC Emergency Planning Department Re: Description of changes to the following documents EAL EBD-H Hazards and Other Conditions Affecting Plant Safety Category This revision corrects a discrepancy in the Threshold Criteria for HU-1 re: earthquakes.
Please contact Paul Sullivan, Manager of Emergency Preparedness at DAEC, (319)851-7191, if you require further information.
3313 DAEC Road - Palo, Iowa 52324-9785 Telephone: 319.851.7191 - Fax: 319.851.7364
- L.
ABASES DOCUMENTs -
- Rev. 16 INDEX Page 1 of 1 PROCEDURE TITLE REV #
REV. DATE Introduction 1
2/01/2000 Definitions 2
8/5/2003 Organization of Basis Information 3
8/5/2003 EBD-A Abnormal Rad Levels/Radiological Effluent 6
8/29/03 Category EBD-F Fission Product Barrier Degradation 4
10/6/03 Category EBD-H Hazards and Other Conditions Affecting 6-A 10/21/03 Plant Safety Category EBD-S System Malfunction Category 4
9/30/2002 EBD-E ISFSI Abnormal Events Category 0
8/5/2003
~~~EAL BASES.DOCUMENT-2 EBD-H
'HAZARDS & OTHER CONDITIONS AFFECTINGPLANT SAFETY CATEGORY Rv -
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- ; PROCEDURE'APPROVAL"-k.L I am responsible for the technical content of this procedure and for obtaining the necessary approval from the'State'and County-Emerfg-e'n6'Ma'na'gem'ent officials'prior to implementation.
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- IiEAL BASES' DOCUMENT l-;!:A-,4 ' s i; '-
EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 2 of 30 Table of Contents HUI - Natural and Destructive Phenomena Affecting the Protected Area................... H-3 HU2 - Fire Within Protected Area Not Extinguished Within 15 Minutes of Detection...H-6 HU3 - Release of Toxic or Flammable Gases Deemed Detrimental to Safe Operation of the Plant.............
H-7 HU4 - Confirmed Security Event Which Indicates a Potential Degradation in the Level of Safety of the Plant.............
H-8 HU5 - Other Conditions Existing Which in the Judgment of the EC/OSM Warrant Declaration of an Unusual Event.............
H-10 HAI - Natural and Destructive Phenomena-Affecting the Plant Vital Area................. H-i 1 HA2 - Fire Affecting the Operability of Plant Safety Systems Required to Establish or MaiMaintai n
Safe Shutdown.................................................. H-15 HA3 - Release of Toxic or Flammable Gases Within a Facility Structure Which Jeopardizes Operation of Systems Required to Maintain Safe Operations or to Establish or Maintai n
Cold Shutdown................................................
H-T HA4 - Security Event in a Plant Protected Area....................................................
H-19 HAS - Control Room Evacuation Has Been Initiated.................................................. H-21 HA6 - Other Conditions Existing Which in the Judgment of the EC/OSM Warrant Declaration of an Alert....................................................
H-22 HSI - Security Event in a Plant Vital'Aea....................
A..............................
H-23
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HS2 - Control Room Evacuation Has Been Initiated and Plant Control Cannot Be Established H-25, HS3 -Other Conditions Existing Which in the Judgment of the EC/OSM Warrant Declaration of a Site Area Emergency.................................................. H-27 HG1 - Security Event Resulting in LOSM Of Ability to Reach and Maintain Cold Shutdown
';H-28
.H 2
HG2 - Other Conditions Existing Which in the Judgment of the EC/OSM Warrant Declaration of a General Emergency H-29
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EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY:
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HUl Natural and Destructive Phenomena Affecting the Protected Area EVENT TYPE: Natural Disasters, Other Hazards and Failures OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
Any one of the following phenomena affecting the Protected Area:
- 1. Receipt of the Amber.OIG Recorders Running Light and the wailing seismic alarm on 1C35.
.7
- 2. Report by plant personnel of tornado striking within protected area boundary.
- 3. Assessment by the control room that a destructive event has occurred.
- 4. Vehicle crash into plant structures or systems within protected area boundary that are determined to be Safe Shutdown Areas.
- 5. Report by plant personnel of an unanticipated explosion within the protected area boundary resulting in visible damage to permanent structures or equipment required for Safe Shutdown.
- . Report of turbine failure resulting in casing penetration or damage to turbine or generator seals.
- 7. River flood water levels above 757.0 ft. -;
- 8. The Max Normal operating water level exceeding and EOP 3 limits.
- 9. River water level below 725 ft. 6 in.
EAL Threshold Value 1 addresses earthquakes that are detected in accordance with AOP 901. For DAEC, a minimum detectable earthquake that is indicated on panel IC35.is an acceleration greater than'.
0.01 Gravity..-
DAEC EAL Threshold Value 2 addresses report of a tornado striking within the protected area or within the plant switchyard.
DAEC EAL Threshold Value 3 allows for the control room to determine that and event has occurred and take appropriate action based on personal assessment as opposed to verification. No attempt is made to assess the actual magnitude of the damage. Such damage can be due to collision, tornadoes, missiles, or any other cause. Damage can be indicated by report to the control room, physical observation, or by Control Room/local control station instrumentation. Such items.as scorching, cracks, dents, or discoloration of equipment or structures required for safe shutdown are addressed by this EAL.
HU1
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EBD-'H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 4 of 30 I
KJ DAEC EAL Threshold Value 4 addresses a vehicle (automobile, aircraft, forklift, truck or train) brash that may potentially damage plant structures containing functions and systems required for safe shutdown of the plant. This does not include vehicle crashes with each other or damage to office or warehouse structures.
Escalation to Alert under HAl would occur if damage was sufficient to affect the ability to achieve or maintain safe shutdown, e.g., damage made required equipment inoperable or structural damage was observed such as bent supports or pressure boundary leakage.
Safe Shutdown Areas Category Area Electrical Switchyard, 1G31 DG and Day Tank Rooms, 1G21 DG and Day Tank Power
- Rooms, Battery Rooms, Essential Switchgear Rooms, Cable Spreading Room Heat Sink/
Torus Room, Intake Structure, Pumphouse Coolant Supply Containment Drywell, Torus, Emergency NE, NW, SE Corner Rooms, HPCI Room, RCIC Room, RHR Valve Systems Room, North CRD Area, South'CRD Area' Other Control Building, Remote Shutdown Panel 1C388 Area, Panel 1C56 Area, SBGT Room DAEC EAL Threshold Value 5 addresses explosions within the protected area. As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment,, that potentially imparts significant energy to'near-by structures or equipment.
Damage can be indicated by report to the control room, physical observation, or by Control Room/local control station instrumentation.-
Such items as scorching, cracks, dents, or discoloration of equipment or structures required for s e shutdown are addressed by this EAL. The EC/OSM needs to consider the security aspects of the explosion, if applicable.
DAEC EAL Threshold Value 6 addresses turbine failure causing observable damage to the turbine casing or damage to turbine or generator seals.
DAEC EAL Threshold Value 7 addresses the' observed effects of flooding in accordance with' AOP 902.'
Plant site finished grade is at elevation 757.0 ft. Personnel doors and railroad and truck openings at or near grade would require protection in ihe event of a flood above elevation 757.0 ft' Therefore, EAL 7 uses 'a threshold of flood water levels above 757.0 ft.
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DAEC EAL Threshold Value 8 addresses internal flooding can be due to system malfunctions, component failures, or repair activity mishaps (such as failed freeze seal) that can threaten safe operation of the-plant.
Therefore, this EAL is based on' 'a valid indication that the water level is higher than the maximum normal operating limits. The Maximum Normal Operating Limits are defined as the highest values of the identified parameter expected to occur during normal plant operating conditions with all directly associated support and control systems functioning properly.
Exceeding these limits is an entry condition into :EOP 3, Secondary Containment Control and may be an indication that water from a primary system is discharging into secondary containment. Exceeding the maximum normal operating limit is interpreted as a potential degradation in the level of the safety of the plant and is appropriately treated as an Unusual Event emergency classification. The maximum normal operating water level limits are taken from AOP 902 and EOP 3 and are shown in the table below:
Maximum Operating Limits - Water Levels Affected Location Indicator Maximum
'Maximum Safe Normal OL OL HPCI Room Area LI 3768 2 inches 6 inches RCIC Room Area LI 3769 3 inches 6 inches A RHR Corner Room SE Area LI 3770 1
2 inches 10 inches'
..,. -ii.
l RHR Comer Room NW Area L13771
.2inches,
-1O inches
< Torus Area
- L3772 2inches.; '
2inches EAL Threshold Yalue 9 addresses the effects of low river water level. The intake structure for the safety-related water supply systems (river water, RHR service water,;and emergency service water) is located on' :
the west bank of the Cedar River. An overflow-type barrier across the river was designed and constructed in accordance with Seismic Category I criteria to intercept the stream bed flow and divert it to the' intake structure. This makes the entire flow of the river available to the safety-related water supply systems.:'A minimum flow of-13 cubic feet per second (cfs) from a minimum 1 000-year river flow of 60 cfs 'must be diverted. The top of the barrier wall is at elevation 725 ft. '6 in. River water level below this level represents a potential degradation in the level of safety of the plant and is addressed by EAL Threshold Value 9.
In this EAL, "Vital Area" is defined as plant structures or areas containing equipment necessary for a safe shutdown.
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REFERENCES:
- 1. Abnormal Operating Procedure (AOP) 901, Earthquake
- 2. Abnormal Operating Procedure (AOP) 902, Flood
- 3. Abnormal Operating Procedure (AOP) 903, Tornado
- 4. Emergency Operating Procedure (EOP)-3, Secondary Containment Control'
- 5. EOP Basis Document, EOP-3, Secondary Containment Control'
' -; i-
- 6. UFSAR Chapter 3, Design of Structures, Components, Equipment, and Systems
- 7. Bechtel Drawing BECH-MO 17, Equipment Location - Intake Structure Plans at Elevations, Rev. 6 HUI
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EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 6 of 30 I
HU2 Fire Within Protected Area Not Extinguished Within 15 Minutes of Detection EVENT TYPE: Fire OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:'
- 1. Fire in buildings or areas contiguous to any of the following areas not extinguished within 15 minutes of control room notification or verification of a control room alarm:
Reactor, turbine, control, admrin/security
- Intake structure
The purpose of this EAL is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. This includes such items as fires within the administration building, V
and security building (buildings contiguous to the reactor building, turbine building and conitrol building),.
yet, excludes fires in the warehouse or construction support center, waste-basket fires, and other small fires of no safety consequence. As used here, Detection is visual observation and report by plant personnel' or sensor alarm indication. 'The 15' minute time period begins with a credible notification that a FIRE is';
occurring, or notification of a YALID fire detection system alarm. Verification of a fire detection system alarm includes actions that can be taken within the control room or other nearby location to ensure that the alarm is not spurious. A verified alarm is assumed to be an indication of a FIRE unless it is disproved within the'l15-minute period by personnel dispatched to the scene. In other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm.
Per AOP 913, the location of a fire can be determined by observing lC40B alarm messages, Zone Indicating Unit (ZIU) alarms, or fire annunciators on panels IC40 and lC40A. The location of a fire can also be determined by verbal report of the person discovering the fire. Verification of the alarm in this' contexti-'
means those actions taken to determine that the control room alarm is not spurious.
REFERENCES:
- 1. Abnormal Operating Procedure (AOP) 913, Fire
- 2. Abnormal Operating Procedure (AOP) 914, Security HU2
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-. EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY 30 2 ;
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~~Page 7 of 30l HU3 Release of Toxic or Flammable Gases Deemed Detrimental to Safe Operation of the Plant: -
EVENT TYPE: Other Hazards and Failures OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
Safe operation of the plant is jeopardized by one of the following:
- 1. Report or detection of toxic or flanmnable gases that could enter within the site area boundary in amounts that can affect normal operation of the plant.
- 2. Report by Local, County or State Officials for potential evacuation of site personnel based on offsite event.
Q Jhis Threshold Value is based on releases in concentrations within the site boundary that will affect the health of plant personnel or affecting the safe operation of the plant with the plant being within the evacuation area of an offsite event (i.e., tanker truck accident releasing toxic gases, etc.) The evacuation area is as determined from the DOT Evacuation Tables for Selected Hazardous Materials,-in the DOT Emergency Response Guide for Hazardous Materials.
For the purposes of this' EAL, CO2 (such as is discharged by the fire suppression system) is not toxic. CO2 can be lethal if it reduces oxygen to low concentrations that are imimiediately dangerous to life and health (IDLH). C02 discharge into an area is not basis for emergency classification under this IC unless: (1)
Access to the affected area is required, and (2) CO2 concentration results in conditions that make the area uninhabitable or inaccessible (i.e., IDLII).
REFERENCES:
- 1. UFSAR Section 2.2, Nearby Industrial, Transportation, and Military Facilities
- 2. UFSAR Section 6.4, Habitability Systems Io x
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EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 8 of 30 HU4 Confirmed Security Event Which Indicates a Potential Degradation in the Level of Safety of the Plant EVENT TYPE: Security OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
- 1. Suspected sabotage device discovered within plant Protected Area.
- 2. Suspected sabotage device discovered outside the Protected Area in the plant switchyard or ISFSI.
- 3. Confirmed tampering with safety related equipment.
- 4. A hostage situation that disrupts normal plant or ISFSI operations.
- 6. Internal disturbance that is not short lived of that is not a harmless outburst involving one or more individuals within the Protected Area or ISFSI.
Security events which do not represent at least a potential degradation in the level of safety of the plant are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72. The term "suspected sabotage device" is used in place of "bomb device" for consistency with the DAEC Safeguards Contingency Plan.
Consultation with Security supervision' is required to determine these Threshold Values.
EAL I describes a suspected sabotage device discovered within the Protected Area but outside an area that contains safety functions or systems. It is a potential degradation of the level of safety of the plant and is an UNUSUAL EVENT.
EAL 2 describes a suspected sabotage device discovered in the plant switchyard or ISFSI representing a' potential degradation of the level of safety of the plant.
EAL 3 is for confirmed tampering and is adapted from the list of security plan contingencies.
EAL 4 identifies a hostage situation that disrupts normal plant or ISFSI operations. A hostage situation is considered to disrupt normal operations if it results in the inability to perform surveillance activities, alters unit operations, or as described in the security plan.
HU4
..-.EAL BASES DOCUMENT
.. EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 9 of 30 EAL 5 describes a civil disturbance or strike is considered to be a spontaneous activity that disrupts normal plant or ISFSI operations. A civil disturbance or strike is considered to disrupt normal plant operations if it initially disrupts normal ingress or egress to the owner controlled or protected area, or if it requires assistance from the Local Law Enforcement Agencies (LLEA) to control.
EAL 6 deals with suspicious internal disturbances that may have been planned by unauthorized personnel as a diversion to gain entry to the site property.
EAL 7 ensures that appropriate notifications for the security threat are made in a timely manner.. The determination of a Credible Security Threat of "LO" or "HI" Severity is based on information found in NMC SE-0018, "Security Threat Assessment". Theeemergency'response toa Credible Security Threat of "LO" Severity is initiated through AOP 914, "Security Events" and EPIP 2.8, "Security Threat". A Credible Security Threat of "HI" Severity would escalate this classification to the ALERT status as an HA4. Only the plant to which the specific threat is made need declare the Notification of Unusual Event.
Suspected sabotage devices discovered within the plant Vital Area would result in escalation via other Security EALs.
REFERENCES:
- 1. Abnormal Operating Procedure (AOP) 914, Security Events
- 2. NMCSE-0018,"SecurityThreatAssessment"
- 3. EPIP 2.8, "Security Threat"
- 4. NEI Methodologyfor Development ofEmergency Action Levels NUMARC/NESP-007 NEI 99-O01 Revision 4, May 1999/September 2002
- 5. NEI MethodologyforDevelopment of EmergencyAction Levels NUMARC/NESP-007NEI97-03 August 1997 (r,,,
';,*e' HU4
--'EAL BASESDOCUMENT 2).23/4X0 EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 10 of 30 K2 115 Other Conditions Existing Which in the Judgment of the EC/OSM Warrant Declaration of an Unusual Event EVENT TYPE: EC/OSM Judgment OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
- 1. Other conditions exist which in the judgment of the Emergency Director indicate a potential degradation of the level of safety of the plant.
The EAL addresses conditions that fall under the Notification of Unusual Event emergency classification description contained in NUREG-0654, Appendix 1, that is retained under the generic methodology.
Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.
Per EPIP 2.5, the Emergency Coordinator/Operations Shift Manager (EC/OSM) is the title for the emergency director function at DAEC.
REFERENCES:
- 1. Emergency Plan Implementing Procedure (EPIP) 2.5, Control Room Emergency Response Operation
- 2. NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, October 1980, Appendix 1 HU5
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ALBASES DOCUMENT.,
EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY
,-. 1' Page 11 of 30 HAl Natural and-Destructive Phenomena Affecting the Plant Vital Area EVENT TYPE: Natural Disasters, Other Hazards and Failures OPERATING MODE APPLICABILITY: All :
EAL THRESHOLD VALUE:
Any one of the following phenomena affecting the Protected Area:
- 1. Valid Amber Operating Basis Earthquake (OBE) light and the wailing seismic alarm on Panel 1C35 are both activated indicating an acceleration greater than + 0.06 gravity
- 2. Tornado striking plant vital areas.
- 3. Assessment by the control room that damage has affected Safe Shutdown Areas.
- 4. Vehicle crash affecting plant vital areas.
- 5. Sustained high wind speed of 95 miles per hour or above affecting plant vital areas.
Missiles affecting safe shutdown areas.
7.. River flood water levels above 767.0 ft.
- 8. The Max Safe operating water level exceeding and EOP 3 limits in two or more areas AND reactor shutdown is required.
- 9. River water level below 724ft' 6 in.
There are no significant deviations from the generic EALs. For the events of concern here, 'the key issue is not the wind speed, earth quake inteiity,' etc., 'but'vhether there:'.is rresultant damage toi: equipment or structures required to achieve or maintain safe shutdown, regardless of the cause. Determination of damage affecting the ability to achieve or maintain safe shutdown can be indicated by reports to the control room, physical observation or by Control Roomnlocal control station instriuffiitatio-;i.
EAL Threshold Value 1 addresses OBE events that are detected in accordance with AOP 901. For DAEC, the OBE is associated with a peak horizontal acceleration of 0.06 Gravity.'
DAEC EAL Threshold Value 2 addresses report of a tornado striking a plant vital area.--- '-'
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Rev. 6-A HAZARDS & OTHER CONbITIONS AFFECTING PLANT SAFETY CATEGORY Page 12 of 30 DAEC EAL Threshold Value'3 addresses a report to the control room of damage affecting safe shutdown areas. The reported damage can be from tornadoes, high winds, flooding, missiles, collisions, or any other cause.
DAEC EAL Threshold Value 4 addresses vehicle (automobile, aircraft, forklift, truck or train) confirmed crashes affecting plant vital areas. This does not include vehicle crashes with each other or damage to office or warehouse structures.
DAEC EAL Threshold Value 5 addresses sustained high wind speeds as measured by the 33-Foot or 156-Foot elevations on the Meteorological Tower.
Sustained wind speed means the baseline wind speed measured by meteorological tower that does not include gusts. The design basis wind speed is 105 miles per hour. However, the meteorological initrumentation is only capable of measuring wind speeds up to 100 miles per hour. Thus the alert level for sustained high wind speed, 95 miles per' hour, is selected to be on-scale for the meteorological instrumentation and to conservatively account for potential measurement errors.
DAEC EAL Threshold Value 6 addresses missiles affecting'safe shutdown areas. Such missiles can be from any cause, e.g., tornado-generated; turbine, pump or other rotating machinery catastrophic failure; or generated from an explosion.
Per A OPs 913 and 914, the following areas are identified as safe shutdown areas and are shown on the EAL v
tables. This table is displayed as an aid to the Emergency Coordinator in determining appropriate areas of concern.
Safe. Shutdown Areas Category Area Electrical Switchyard, 1G31 DG and Day Tank Rooms, 1G21 DG and Day Power Tank Rooms, Battery Rooms, Essential Switchgear Rooms, Cable Spreading Room Heat Sink/
Torus Room, Intake Structure, Pumphouse Coolant Supply Containment Drywell, Torus Emergency NE, NW, SE Comer Rooms, HPCI Room, RCIC Room, RHR Systems' Valve Room, North CRD Area; South CRD Area Other Control Building, Remote Shutdown Panel 1 C388 Area, Panel 1 C56 Area, SBGT Room DAEC EAL Threshold Value 7 addresses river water levels exceeding design flood water levels. All Seismic Category I structures and non-seismic structures housing Seismic Category I equipment are designed to withstand the hydraulic head resulting from the "maximum probable flood" to which the site HAI
.EAL BASES-DOCUMENT i EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY g 13
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~~~~~~~~~~Page 13 of 30l could be subjected. The design flood water is at elevation 767.0 ft.. Major equipment penetrations in the exterior walls are located above elevation 767.0 ft. Openings below the flood level are either watertight or are provided with means to control the inflow of water in order to ensure that a safe shutdown can be achieved and maintained. Consideration has also been given to providing temporary protection for openings in the exterior walls up to flood levels of 769.0 ft. All buildings were also checked for uplift (buoyancy) for a flood level at elevation 767.0 ft, and the minimum factor of safety used was 1.2. Therefore, DAEC EAL 7 uses as its threshold flood water levels above 767 feet.
DAEC EAL Threshold Value 8 addresses internal flooding consistent with the requirements of EOP 3, Secondary Containment Control. If RPV pressure reduction, will decrease leakage into, -secondary containment then this is due to leakage from the primary system, which is addressed by the Fission Barrier Table indicators and System Malfunction EALs, and is not addressed here. Therefore, EAL 8 addresses conditions in which water level in thvo or more areas is above Maximum Safe Operating Limits and reactor shutdown is required. Required means that the reactor shutdown was procedurally mandated by EOP 3 and is not merely performed as a precaution or inadvertently. Maximum Safe Operating Limits are defined as the highest parameter value at which neither (1) equipment necessary for safe shutdown of the plant will fail nor (2) personnel access necessary for the safe shutdown of the plant will be precluded. The internal flooding can be due to system malfunctions, component failures, or repair activity mishaps (such as failed freeze seal) that can threaten safe operation of the plant. This includes water intrusion on equipment that is Iot designed to be submerged (e.g., motor control centers).
The maximum safe operating water level limits are taken from EOP 3 and are shown on the table below:
Maximum Operating Limits - Water Levels Affected Location Indicator Maximum Maximum Safe Normal OL OL HPCI Room Area LI 3768 2 inches 6 inches RCIC Room Area LI 3769 3 inches 6 inches A RHR Corner Room SE Area LI 3770 2 inches 10 inches B RHR Corner Room NW Area LI 3771 2 inches 10 inches Torus Area LI 3772 2 inches 12 inches DAEC EAL Threshold Value 9 addresses the effects of low river water level. The intake structure for the safety-related water supply systems (river water, RHR service water, and emergency service water) is located on the west bank of the Cedar River. The overflow weir is at elevation 724 feet 6 inches. River level at or below this elevation will result in all river flow being diverted to the safety related water supply systems. The top of the intake structure around the pump wells is at elevation 724 feet. If the river water level dropped to this level, the pump suction would have no continuous supply. Therefore, this EAL uses a threshold of water level below 724 feet 6 inches as a potential substantial degradation of the ultimate heat sink capability.
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-I In this EAL, "Vital Area" is defined as plant structures or areas containing equipment necessary for a safe shutdown.
REFERENCES:
- 1. Abnormal Operating Procedure (AOP) 901, Earthquake
- 2. Abnormal Operating Procedure (AOP) 902, Flood
- 3. Abnormal Operating Procedure (AOP) 903, Tornado
- 4. Abnoimal Operating Procedure (AOP) 913, Fire
- 5. Abnormal Operating Procedure (AOP) 914, Security Events
- 6. UFSAR Chapter 3, Design of Structures, Components, Equipment, and Systems
- 7. Bechtel Drawing BECH-MO 17, Equipment Location - Intake Structure Plans at Elevations, Rev. 6
- 8. EOP Basis Document, EOP 3 - Secondary Containment Control Emergency Operating Procedure (EOP) 3, Secondary Containment Control HAI K>
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- , I HA2 Fire or Explosion Affecting the Operability of Plant Safety Systems Required to Establish or Maintain Safe Shutdown EVENT TYPE: Fire OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
- 1. Fire or explosion affecting one of the following systems or areas of concern.
SYSTEMS Reactivity Control Containment (Drywelllrorus)
RHR/Core Spray/SRV's HPCI/RCIC RHRSW/River Water/ESW Onsite AC Power/EDG's Offsite ACPower Instrument AC DC Power Remote Shutdown Capability I 1 AREAS Reactor, Turbine, Control, Admin/Security
. Intake.Structure
.e. Pump House -,- -
AND-
- 2. Affected system parameter indications show degraded performance or plant personnel report VISIBLE DAMAGE to permanent structures or equipment within the specified area.'
There is no significant deviation from the generic EAL.
Of particular concern for this EAL are fires that may be detected in the reactor building, control building, turbine building, pumphouse, and intake structure as shown in Tabs 1 and 3 of AOP 913. Damage from fire or explosion can be indicated by physical HA2
E EAL BASES DOCUMENT EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 16 of 30 I
observation, or by Control Room/local control station instrumentation.. No attempt is made in this EAL to assess the actual magnitude of the dcimage.
Per AOP 913, the location of a fire can be determined by observing IC40B alarm messages, Zone Indicating Unit (ZRJ) alarms, or fire annunciators on panels 1 C40 and I C40A.
NOTE:
Scope of Systems and Equipment of concern established by review of Appendix R Safe Shutdown credited systems. Only those systems directly affecting safe shutdown or heat removal are listed for consideration, due to fire damage. Support.Systems and equipment such as HVAC and specific instrumentation, while included in Appendix R analysis is not considered an immediate threat to the ability to shutdown the plant and remove decay heat.
This EAL addresses a FIRE / EXPLOSION and not the degradation in performance of affected systems.
System degradation is addressed in the System Malfunction EALs. The reference to damage of systems is used to identify the magnitude of the FIRE / EXPLOSION and to discriminate against minor FIREs /
EXPLOSIONs. The reference to safety systems is included to discriminate against FIREs / EXPLOSIONs in areas having a low probability of affecting safe operation. The significance here is not that a safety m
system was degraded but the fact that the FIRE / EXPLOSION was large enough to cause damage to these systems. Thus, the designation of a single train was intentional and is appropriate when the FIRE I EXPLOSION is large enough to affect more than one component. Lagging fires, fires in waste containers or any miscellaneous fires that may be in the vicinity of safety systems, but do not cause damage to these systems, should NOT be considered for this EAL.
With regard to EXPLOSIONS, only those EXPLOSIONS of sufficientforce to damage permanent structures or identified equipment requiredfor safe operation, should be considered. As used here, an EXPLOSION is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to near-by structures and materials. The occurrence of the EXPLOSION with reports of evidence of damage (e.g., deformation, scorching) is sufficient for the declaration. The EC/OSM also needs to consider any security aspects of the EXPLOSIONS, if applicable.
REFERENCES:
- 1. Abnormal Operating Procedure (AOP) 913, Fire
- 2. Abnormal Operating Procedure (AOP) 914, Security Events
- 3. Abnormal Operating Procedure (AOP) 915, Shutdown Outside Control Room
- 4..UFSAR Section 6.4, Habitability Systems HA2
-:.i.-
iLBASESDOCUMENT
-:-;:.-EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 17 of 30 EIA3 Release of Toxic or Flammable Gases Within a Facility Structure Which Jeopardizes Operation of Systems Required to Maintain Safe Operations or to Establish or Maintain Cold Shutdown EVENT TYPE: Other Hazards and Failures OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
One of the following:;
- 1. Report or detection of toxic gases within a Safe Shutdown Area in concentrations that will be life threatening to plant personnel.
- 2. Report or detection of flammable gases within a Safe Shutdown Area in concentrations that will affect the KJ safe operation of the plant.
This EAL, in addition to EAL HAS, also addresses entry of toxic gases that may result in control room evacuation in accordance with AOP 915.
For the purposes of this EAL, CO2 (such as is discharged by the fire suppression system) is not toxic. CO2 can be lethal if it reduces oxygen to low concentrations that are immediately dangerous to life and health (IDLH). CO2 discharge into an area is not basis for emergency classification under this IC unless: (1)
Access to the affected area is required, and (2) CO2 concentration results in conditions that make the area uninhabitable or inaccessible (i.e., IDLH).
TOXIC - Exposure to the worker in excess of the limits specified in 29 CFR 1910.1000. In practice, this should be considered for concentrations which are capable of producing incapacitation of the worker.
The source of the release is NOT of immediate concern for these threshold values. The concern is for the health and safety of plant personnel and their ability to maintain the plant in a safe operating condition.
This EAL is based on gases that have entered plant structures that will affect the safe operation of the plant. These structures include buildings and areas contiguous to plant vital areas and other significant I'~
HA3
,>.-EI
.':AL BASES DOC EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 18 of 30 l,
buildings or areas. The intent of this EAL is NOT to include buildings or other areas that are NOT contiguous or immediately adjacent to plant vital areas.
Per AOPs 913 and 914, the following areas are identified as safe shutdown areas. This table an aid to the Emergency Coordinator in determining appropriate areas of concern.
is displayed as Safe Shutdown Areas Category Area Electrical Power Switchyard, 1G31 DG and Day Tank Rooms, 1G21 DG and Day Tank Rooms, Battery Rooms, Essential Switchgear Rooms, Cable Spreading Room Heat Sink/Coolant Supply Torus Room, Intake Structure, Pumphouse Containment Drywell, Torus Emergency Systems NE, NW, SE Corner Rooms, HPCI Room, RCIC Room, RHR Valve Room, North CRD Area, South CRD Area Other Control Building, Remote Shutdown Panel 1C388 Area, Panel 1C56 Area, SBGT Room I
REFERENCES:
- 1. Abnormal Operating Procedure (AOP) 913, Fire
- 2. Abnormal Operating Procedure (AOP) 914, Security Events
- 3. Abnormal Operating Procedure (AOP) 915, Shutdown Outside Control Room
- 4. UFSAR Section 6.4, Habitability Systems HA3
. TEAL BASES DOCUMENT : -.>.r.
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Page 19 of 30 HA4 Security Event in a Plant Protected Area EVENT TYPE: Security OPERATING MODE APPLICABILITY: All,,
EAL THRESHOLD VALUE
- 1.
Intrusion into plant Protected Area by a hostile force.
- 2.
Sabotage device discovered in the plant Protected Area.
- 3.
Any security event of increasing severity that persists for > 30 minutes:
- a.
Credible bomb threats
- b.
Extortion
- c.
Suspicious Fire or Explosion
- d.
Significant Security System Hardware Failure K>
- e.
Loss of Guard Post Contact
EAL 1 is an intrusion of a hostile force into the Protected Area representing a potential for a substantial degradation of the level of safety of the plant. A civil disturbance, which penetrates the Protected Area, can be considered a hostile force.
EAL 2 is the discovery of a sabotage device in the Plant Protected area.
EAL 3 security events represent an escalated threat to plant safety above that contained in the Unusual Event.
Under this EAL, adversaries within the Protected Area are not yet affecting nuclear safety systems, engineered safety features, or reactor shutdown capability that are located within the vital area. A security event is considered to be "of increasing severity" if events are NOT under control of the security force within 30 minutes. Intrusion into a vital area by a hostile force will escalate this event to a Site Area Emergency.
EAL 4 is the determination of "Credible Security Threat of HI Severity" based on information found in NMC SE-00 18, "Security Threat Assessment". The emergency response to a "Credible Security Threat of HI Severity" is initiated through AOP 914, "Security Events" and EPIP 2.8, "Security Threat".
HA4 A.
.-,-;:i EAL BASES DOCUMENT..i-EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 20 of 30 I
REFERENCES:
- 2. Abnormal Operating Procedure (AOP) 914, Security Events
- 3. NEI Methodology for Development of Emergency Action Levels NUMARC/NESP-007NEI99-01 Revision 4, May 1999/September 2002
- 4. NEIMethodologyfor Development of EmergencyAction Levels NUMfARC/NESP-007NEI97-03 August 1997 HA4
- ~~~~~~~
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' E.'b.4 4...........
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2 30
{
~~~~~~~~~~~~Page 21 of 30l HA5 Control Room Evacuation Has Been Initiated EVENT TYPE: Control Room Evacuation OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
- 1. Entry into AOP 915 and initiation of control room evacuation.
The applicable procedure for control room evacuation at DAEC is AOP 915.
Evacuation of the Control Room represents a potential for substantial degradation of the level of safety of the plant and therefore requires aniALERT declaration. Additional support, monitoring and direction is required and accomplished by activation of the Technical Support Center-at the ALERT classification level.
REFERENCES:
- 1. Abnormal Operating Procedure (AOP) 915, Shutdown Outside Control Room
- 2. UFSAR Section 6.4, Habitability Systems
,4 K..
.4., *
~~~~~~~~~HA5
I X EAL BASES DOCUMENT> ;-,..-.:-,..i',
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HA6 Other Conditions Existing Which in the Judgment of the EC/OSM Warrant Declaration of an Alert EVENT TYPE: EC/OSM Judgment OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
- 1. Other conditions exist which in the Judgment of the Emergency Director indicate that plant safety systems may be degraded and that increased monitoring of plant functions is warranted.
Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant Any releases are expected to be limited to a small fraction of the EPA Protective Action Guideline exposure levels.
Per EPIP 2.5, the Emergency Coordinator/Operations Shift Manager (EC/OSM) is the title for the emergency director function at DAEC. The EAL addresses conditions that fall under the Alert emergency classification K
description contained in NUREG-0654, Appendix 1.
REFERENCES:
- 1. Emergency Plan Implementing Procedure (EPIP) 2.5, Control Room Emergency Response Operations
- 2. NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Powver Plants, Revision 1, October 1980, Appendix 1 HA6
~EALUBASES DOCUMENT EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 23 of 30 HSI Security Event in a Plant Vital Area EVENT TYPE: Security OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
One of the following:
- 1.
Intrusion into plant Vital Area by a hostile force.
- 2.
A security event which results in the loss of control of any Vital Area (other than the Control Room).
- 3.
IMMINENT loss of physical control of the facility (remote shutdown capability) due to a security event.
- 4.
A confirmed sabotage device discovered in a vital area.
KJAEC EAL INFORMATION:
IMMINENT - Mitigation actions have been ineffective and trended information indicates that the event or condition will occur within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
This threshold value escalates from the ALERT Protected Area intrusion to a Vital Area intrusion of a hostile force.
A security event is as defined in the Safeguards Contingency Plan.
Loss of physical control of the Control Room OR loss of physical control of the remote shutdown capability due to a security event, is to be classified as a GENERAL EMERGENCY per Initiating Condition HGl.
A "confirmed sabotage device" is a determination made by the security force through the Security Plan, Contingency procedures and other guidance documentation.
This class of security events represents an escalated threat to plant safety above that contained in HA4, Security Event in a Plant Protected Area, in that a hostile force has progressed from the Protected Area to the Vital Area. Under the condition of concern here, the adversaries are considered to be in a position to directly and negatively affect nuclear safety systems, engineered safety features, or reactor shutdown capability.
HSI
I EAL BASES DOCUMENT' EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY' Page 24 of 30 I
REFERENCES:
- 1. Abnormal Operating Procedure (AOP) 914, Security Events
- 2. NEI Methodology for Development of Emergency Action Levels NUMARC/NESP-007 Revision 4, May 1999 HSI
E..:
.: AL BASES DOCUMENT EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 25 of 30 I.
HS2 Control Room Evacuation.Has Been Initiated and Plant Control Cannot Be Established EVENT TYPE: Control Room Evacuation OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
i The following conditions exist:
- 1) Control room evacuation has been initiated.
AND
- 2) Control of the plant cannot be established per AOP 915 within 20 minutes.
W§here is no significant deviation from the generic EAL.
The applicable procedure for -control room evacuation at DAEC is AOP 915. Based on the results of the analysis described below, DAEC uses 20 minutes as the site-specific time limit for establishing control of the plant. DAEC has satellite panels associated with the remote shutdown panel at various locations through out the plant. Control of the plant from outside the control room is assumed when the controls are transferred to remote shutdown panel 1C388 in accordance with AOP 915.
The EC/OSM is expected to make a reasonable, informed judgment within the 20 minute time limit that control of the plant from the remote shutdown panel has been established. The intent of the EAL is that control of important plant equipment and knowledge of important plant parameters has been achieved in a timely manner. Primary emphasis should be placed on those components and instruments that provide protection of and information about safety functions. At a minimum, consistent with the Appendix R safe shutdown analysis described above, these safety functions include reactivity control, maintaining reactor water level, and decay heat removal.
General Electric performed analyses to demonstrate compliance with the requirements of 10 CFR 50 Appendix R for DAEC. The evaluation of Reactor Coolant Inventory was performed using the GE evaluation model (SAFE). The SAFE code determines if the reactor coolant inventory is above the TAF during the safe shutdown operation. If core uncovery occurs, the fuel clad integrity evaluation is performed by determining the duration of the core uncovery and the resulting peak cladding temperature (PCT). The PCT calculations were performed by incorporating the SAFE output into the Core Heatup Analysis code (CHASTE). The details of these calculations are provided in Section 4 of the final report for DAEC HS2
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HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 26 of 30 I
11
Appendix R analyses ("Safe Shutdown Appendix R Analyses for Duane Arnold Energy Center", MDE 036).
The required analyses include evaluation of the safe shutdown capability of the remote shutdown system for various control room fire events assuming: (1) no spurious operation of equipment, (2) spurious operation of a safety-relief valve (SRV) for 20 minutes, (3) spurious operation of a SRV for 10 minutes, and (4) spurious leakage from a one-inch line. The analyses show that the worst case spurious operation of SRV or isolation valves on a one-inch liquid line (high-low pressure interface) will not affect the safe shutdown ability of the remote shutdown system for DAEC in case of a fire requiring control room evacuation before the identified time limit for the necessary operator actions at the auxiliary shutdown panels. For the limiting cases of worst case spurious leakage from a one-inch line and spurious operation of a SRV, operator control within 20 minutes would not impact the integrity of the fuel clad, the reactor pressure vessel, and the primary containment.
REFERENCES:
- 1. Abnormal Operating Procedure (AOP) 915, Shutdown Outside Control Room
- 2. General Electric Report MDE-44-0386, Safe ShutdoivnAppendix RAnalysisfor DAEC, March 1986
- 3. UFSAR Section 6.4, Habitability Systems
- 4. NEI Methodology for Development of Emergency Action Levels NUMARC/NESP-007 Revision 4, May U
1999 HS2
- .;,
- ',:EAL BASES'DOCUMENT EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY P
2 o 3.
~~~~~~~~Page 27 of 30l HS3 Other Conditions Existing Which in the Judgment of the <EC/OSM> Warrant Declaration of Site Area Emergency EVENT TYPE: EC/OSM Judgment OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
- 1. Other conditions exist which in the Judgment of the Emergency Director indicate actual or likely major failures of plant functions needed for protection of the public.
There is no significant deviation from the generic EAL.
Per EPIP 2.5, the Emergency Coordinator/Operations Shift Manager (EC/OSM) is the title for the emergency director function at DAEC.
The EAL addresses conditions that fall under the Site Area, Emergency classification description contained in NUREG-0654, Appendix 1.
Events ar'e in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public.,Any releases are not expected to exceed EPA -Protective. Action Guidelines beyond the site boundary but could be exceeded onsite.'
REFERENCES:
- 1. Emergency Plan Implementing Procedure (EPIP) 2.5, Control Room Emergency Response Operation
- 2. NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, October 1980, Appendix 1 HS3
i-d
- . EAL BASES DOCUMENT EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 28 of 30 HG1 Security Event Resulting in Loss Of Ability to Reach and Maintain Cold Shutdown EVENT TYPE
- Security OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
One of the following:
- 1. Loss of physical control of the control room due to security event.
- 2. Loss of physical control of the remote shutdown capability due to security event.
This EAL is an escalation of the SITE AREA EMERGENCY, HSI declaration for a hostile force S intrusion of a Vital Area taking physical control of either the Control Room OR taking over the remote shutdown capabilities which results in the loss of physical control of the facility. This also includes areas where any switches that transfer control of safe shutdown equipment to outside the control room are located.
REFERENCES:
- 1. Abnormal Operating Procedure (AOP) 914, Security Events
- 2. UFSAR Section 6.4, Habitability Systems HG1
.EAL BASES DOCUMENT.
EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 29 of 30 HG2 Other Conditions Existing Which in the Judgment of the EC/OSM Warrant Declaration of General Emergency EVENT TYPE: EC/OSM Judgment OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE:
Other conditions exist which in the Judgment of the Emergency Director indicate:
- 1) Actual or imminent substantial core degradation with potential for loss of containment OR
- 2) There is a potential for uncontrolled radionuclide releases. These releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the site boundary.
Per EPIP 2.5, the Emergency Coordinator/Operations Shift Manager (EC/OSM) is the title for the emergency director function at DAEC GENERAL EMERGENCY - Events are in process or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.
IMMINENT - Mitigation actions have been ineffective and trended information indicates that the event or condition will occur within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
POTENTIAL - Mitigation actions are not effective and trended information indicates that the parameters are outside desirable bands and not stable or improving.
This Emergency Action Level allows for classification of events which in the judgment of the Emergency Director warrant the GENERAL EMERGENCY classification but do not fit into any other GENERAL EMERGENCY criteria. Emergency Director judgment is to be based on known conditions and the expected response to mitigating activities within a short time period arbitrarily set at 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Classification of a GENERAL EMERGENCY is not to be delayed pending an extended evaluation of possibilities and probabilities. If time allows and the offsite response organizations are active, consultation with the effected state and the NRC is prudent prior to classification.
HG2
EAL' BASES
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- EBD-H Rev. 6-A HAZARDS & OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY Page 30 of 30 IK
REFERENCES:
- 1. Emergency Plan Implementing Procedure (EPIP) 2.5, Control Room Emergency Response Operation
- 2. NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, October 1980, Appendix I
- 3. NEI Methodology for Development of Emergency Action Levels NUMARC/NESP-007 Revision 4, May 1999 K>
HG2