ML17334B602

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Responds to Questions Re Proposed Emergency Plan Rev to Incorporate NUMARC EAL Methodology
ML17334B602
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 08/30/1996
From: Fitzpatrick E
INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17333A553 List:
References
AEP:NRC:1192C, NUDOCS 9609110081
Download: ML17334B602 (23)


Text

CATEGORY 1 REGULAT'NFORMATION DISTRIBUTIOISTEM (RIDS)

ACCESSION NBR:9609110081 DOC.DATE: 96/08/30 NOTARIZED: .NO . DOCKET )P, FAC'IL!50-3lg Donald C..Cook Nuclear Power Plant, Unit 1, indiana'M ,050003l5 50-318'Donald C. Cook Nuclear Power Plant, Unit 2, Indiana M 0500031."6 AUTH. NAME AUTHOR AFFILIATION FITZPATRICK,E. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT. AFFILIATION

. ~I/~

Document Control Branch (Document Control Desk) w'

SUBJECT:

Responds to questions re proposed emergency plan rev to incorporate- NUMARC EAL methodology.

DISTRIBUTION CODE: A045D COPIES RECEIVED:LTR J ENCL TITLE: OR Submittal: Emergency Preparedness Plans, Impl ment'g Procedures,ggC T SIZE: Z8 k NOTES: E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME, LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 PD 1 1 HICKMANFJ 1 1 "INTERNAL. R 01 2 2 NRR/DRPM/PERB 1 1 UDOCS-ABSTRACT 1 1 EXTERNAL: NOAC .1 1 NRC PDR 1 1 D

U NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE CONTACT THE DOCUMENT CONTROL SD-5(EXT. 415-2083) TO ELIMINATE YOUR NAME DESKr,'OOM OWFN FROM DISTRIBUTION IglISTS FOR DOCUMENTS YOU DON'T NEED!

Indiana Michigan Power Company P.O. Box 16631 Columbus, OH 43216 R

August 30, 1996 AEP:NRC:1192C

~

Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:

--Donald C. Cook Nuclear Plant Units 1 and 2 PROPOSED EMERGENCY ACTION LEVELS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (TAC NOs. M89878 and M89879)

This letter is in response to questions concerning our proposed emergency plan revision to incorporate the NUMARC emergency action level (EAL) methodology. The questions were first raised during a conference call between NRC staff and AEP personnel on July 23, 1996, and discussed more completely during a meeting at NRC headquarters on August 6, 1996.

Attachment 1 to this letter contains a list of questions received from our proj ect manager, John Hickman, and our responses.

Attachment 2 contains our proposed Emergency Plan, Section 12.3.5, Emergency Classification System. Attachment 3 contains our implementing procedure PMP 2080 EPP.101, Emergency Classification (EALs). Attachment 4 contains the EAL Basis Document. Attachment 5 contains the Core Cooling and Heat Sink Critical Safety Function Status Trees requested during the August 6, 1996, meeting.

includes a copy of the loss of residual heat removal (RHR) cooling It also procedure.

PMP 208 EPP.101 and the basis document have been modified as necessary to respond to the issues raised during the above mentioned conference call and meeting. We have also made minor editorial changes to these documents.

9b09ii0081 960830 05000S15 PDR ADOCK P I DR

U. S. Nuclear Regulatory Commission AEP: NRC: 1192C Page 2 We remain available to answer any additional questions that the NRC staff might have.

Sincerely, E. E. Fitzpatrick Vice President jen Attachments CC A. A. Blind A. B. Beach NFEM Section Chief NRC Resident Inspector - Bridgman J. R. Padgett

P I

i'!

....960911008 Attachment 1 to AEP:NRC:1192C Questions and Answers

Fission Product Barrier EALs 1.Q. Is the containment radiation EAL for Fuel Clad Carrier 1.2 conservatives How was it calculated and is it consistent with your current core damage assessment procedure?

1.A. The number is conservative (only noble gases considered) but is consistent with our procedure (PMP 2081 EPP.105). An apparent inconsistency between the graph (Appendix A.2) and table (Appendix A.3) will be clarified in the next revision to the procedure. The region of the graph where our containment radiation EALS would be located is off scale (low) from the graph.

2.Q. Why are core exit thermocouples not used as an EAL for potential loss of fuel clad?

2.Q. The Fuel Clad Barrier 1.1 (potential loss) has been modified to include "Core Exit Thermocouples >700'."

3.Q. In RCS Barrier 2.3, what is a prolonged releaseV 3.A. Prolonged is defined in this loss EAL as 30 minutes, which is the assumed break flow termination time period in our steam generator tube rupture analysis.

4.Q. Why isn't a threshold value for "valves not closed and downstream pathway to the environment exists" included as a containment potential loss threshold valueV 4.A. A discussion of "valves not closed..." is included in the basis discussion for loss under Containment Barrier 3.3: Containment Breach/Bypass. The wording of the threshold value has been modified to more closely resemble the NUMARC wording.

G.Q. Why was an EAL added for hydrogen concentration >0.5% and key equipment inoperable' G.A. Discussion of rationale for this EAL is in basis for Containment Barrier 3.2- Containment Pressure. A deviation statement was added to the basis for this added EAL.

6.Q. Why doesn't the EAL for hydrogen >4% include an oxygen concentration'?

r 6.A. We do not monitor oxygen concentration in containment. A statement has been added to the basis document explaining that an explosive mixture in containment is determined by hydrogen concentration only.

Hazards EALs 7.Q. Why do the security EALs contain the same wording for UE, Alert and SAE (i.e. "Other security events as determined by the Modified Amended Security Plan" )?

7.A. Specific security events have been added to the EALs, including confirmed bomb discovery in a vital area for SAE.

8.Q. Why is "significant visible damage" specified in H-1, Alert rather than just "visible damage" ?

8.A. The word significant was removed from the EAL.

9.Q. Why does H-3, Alert specify initiation of control room evacuation and initiation of the evacuation procedure both'?

9.A. The reference to the procedure has been removed form the EAL. A discussion of the procedure is contained in the basis document.

10.Q. Why are values for operating basis and design basis earthquakes not included in the EAL for an operating basis earthquake, 'Alert?

10.A. Cook Nuclear Plant does not have real time seismic instrumentation, so numerical values for earthquake intensity are not included in this EAL. The operator assessment method specified in NUMARC is Used.

11.Q. Why isn't the NUMARC EAL for "unanticipated explosion within protected area" included in any EAL?

11.A. That EAL has been added. under the Initiating Condition "Natural or destructive phenomena inside protected area".

Radiation EALs Do the eNuent monitor readings for Alert (200 x ODCM release limits) overlap with the monitor readings calculated for SAE'?

No.

Why is the new fuel storage vault (NFSV) monitor alarm used as an EAL for an Alert' The function of the NFSV monitor is considered similar to that of the spent fuel pool monitor R-5. An alarm on that monitor is currently an EAL for an Alert. A statement has been added to the basis reflecting this.

Why does EAL 41 For R-3, Unusual Event, contain the words "with irradiated fuel in containment" ?

Those words have been deleted from the R-3 table.

Why isn't the water level for the reactor cavity included in EAL 43 for R-3: Alert?

The reactor cavity water level was added to the EAL.

Systems EALs Should a definition of Anticipated Transient without Scram (ATWS) be included in the S-1 EAL table?

Yes, a definition based on wording in 10CFR 50.62 has been added to the tables and basis documents.

What are your definitions of Heat Sink Red and Subcriticality Red?

The Heat Sink and Subcriticality Critical Safety Function Status Trees are attached to this letter (Attachment 5).

Will loss of offsite power with just one diesel generator available result in both a UE and an Alert?

Yes. The EAL for UE has been changed to loss of all off site power with two diesel generators supplying power.

19.Q. Is proper allowance given for protective action in the EAL for S-2A, General Emergency?

19.A. The four hour restoration period is appropriate, as that time period was assumed in station blackout analysis (AEP:NRC:05730). A statement will be added to the basis with this information.

Events that could theoretically occur after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> have not been analyzed; therefore, it is difficult to estimate the amount of time available to implement protective actions. It should be noted however, that about 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> prior to declaration of the GE, all site emergency facilities would have been activated. The state emergency organization should also be operational, so the mechanism should be in place for making immediate protective action recommendations to the public.

20.Q. Why isn't mode applicability given in the S-3 tables?

20.A. A note will be added in the left-hand column saying that the modes will be indicated with appropriate initiating conditions (IC's).

21.Q. Why is there no EAL given for fuel clad degradation based on radiation monitor readings?

21.A. Cook Nuclear Plant does not have a failed fuel monitor. A statement reflecting that fact will be added to the basis.

22.Q. Request information on OHP 4022.017.001, "Loss of RHR Cooling".

22.A. A copy of the procedure is provided in Attachment 5.

23.Q. Regarding S-5 EALs, what is the definition of not successful?

23.A. "Objectives of the procedure could not be accomplished". The definition will be added to the basis.

Attachment 2 to AEP:NRC:1192C Emergency Classification System

12.3.5 EMERGENCY CLASSIFICATION SYSTEM 12.341 Revision xx

12.3.5.1 Initiatin Conditions ICs /Eme en Action Levels EALs The ICs/EALs that will be utilized in initiating specific emergency acfions described herein are not limited to one set of criteria or radiological parameters. The ICs/EALs were created following the methodology of NUMARC/NESP407, Rev. 2. The ICs for various emergency condition categories (ECCs) are indicated herein. The EALs are only included in the Emergency Plan Procedures.

The ICs/EALs will classify an event or condition into one of four Emergency Classification Levels (ECLs) if an emergency ctassification Is appropriate. The action to be taken by the operating shift depends upon the severity of the incident, its effects and type.

12.3.5.2 Protective Actions For incidents that fall under the Emergency Classification Levels as defined herein, the Michigan State Police, the Berrien County Sheriffs Department, and the NRC and AEP Emergency Response Organization, as required, will be notified by the Site Emergency Coordinator that such an incident has occurred.

It is the responsibility of the Governor of Michigan or his authorized representative to make protective action decisions such as sheltering, evacuation, administration of thyroid bkicking agents, etc. These decisions are based upon the protective action guides in Annex S of the Michigan Emergency Management Plan (MEMP). Since copies of the MEMP are maintained and readily available at the various Emergency Response Facilities, the protective action guides and their bases will not be reproduced here.

For incidents involving actual or imminent releases of radioactive material to the atmosphere, PMP 2081 EPP.305 "Protective Action Recommendations," will be used as the basis for recommendations for protective actions to the public. The procedure is based on the current issue of the "Manual for Protective Action Guides and Protection Action for Nuclear Incidents" (EPA 400-R-92-001). The EPA Gukle provides Protective Acfion Guides (PAGs) for whole body external gamma radiation and for inhalation of radioactive material in an airborne plume.

The most effective actions to be recommended to the public are: evacuation, sheltering, and access control. Evacuation potentially provides the greatest margin of protection. On the other hand, because sheltering may be implemented in less time than evacuation, it may be the protective action of choice if rapkt evacuation is impeded for any reason. Also, since sheltering is kss disruptive than evacuation, it may be the protective action of choice when the dose reduction factor associated with shelter is adequate to reduce the projected dose to less than PAG levels. Access control Is an effective action to avoid exposure of personnel who might otherwise enter areas of high exposure unnecessarily.

Emergency Plan Procedures have been established to provkle the mechanism and criteria for recommending protective actions to state and local governments.

12.3.5.3 Initiati Conditions/Eme en Action Levels Initiating Conditions (ICs) are those conditions, in general description, that require impiementafion of emergency actions based on the associated Emergency Classificafion Level. Emergency Action Levels are, where possible, specific descriptions of the ICs using predesignated, non-subjecUve criteria.

The Site Emergency Coordinator will exercise subjective judgement, based on the following criteria, to ensure all incidents are ciassified at the highest appropriate Emergency Classification Level.

~ Conditions which indicate a potenUal degradation of the level of safety of the plant warrant a dectarafion of an Unusual Event.

~ Conditions which indicate an actual or potential substantial degradation of plant safety systems AND that increased monitoring of plant functions is needed warrant a deciarafion of an Alert

~ Conditions which indicate likely or actual major failures of plant functions needed for the protection of the public warrant a declarafion of a Site Area Emergency.

~ Conditions which indicate an actual or imminent substantial core degradation with potential for loss of containment from EITHER unit warrant a dectarafion of a General Emergency.

The tables on pages 12.343 through 12.348 contain the ICs used for Emergency Classifications. The EALs are contained within PMP 2080 EPP.101. The table on page 12.3.69 provides ciassificafion guidance when addressing loss or potential loss of fission product barriers. Pages 12.3.70 through 12.3.72 contain the criteria to be used to determine whether or not a barrier is lost or potenUaily losL 12.342 Revision xx

INITIATINGCONDITIONS RECOGNITION CATEGORY: Hazards and Other Conditions Affecting Plant Safety MODES'LL ECC UNUSUAL EVENT ALERT SITE AREA GENERAI.

EMERGENCY EMERGENCY H-1: Fire within Protected Area Fire or explosion affecting the Not Applicable Not Applicable FIRE boundary not extinguished operability of plant safety within 15 minutes of systems required to establish detection. or maintain safe shutdown.

K-2: Release of toxic or Release of toxic or flammable Not Applicable Not Applicable TOXIC OR flammable gases deemed gases within a facility structure FLAMMABLE detrimental to safe which Jeopardizes operation of operation of the plant. systems required to maintain GASES'4: safe operations or to maintain cold shutdown.

Not Applicable Control Room evacuation has Control Room Not Applicable CONTROL been Initiated. evacuation has been ROOM initiated and plant EVACUATION control cannot be established.

H4: Confirmed security event Security event in a plant Security event in a Security event resulting SECURITY which indicates a potential protected area. plant vital area. in loss of ability to reach EVENTS degradation in the level of and maintain cold safety of the plant. shutdown.

H-5: Other conditions existing Other conditions existing Other conditions Other conditions SITE which in the judgement of which in the judgement of the existing in the existing which in the EMERGENCY the SEC warrant SEC warrant declaration of an judgement of the SEC judgement of the SEC COORDINATOR declaration of an unusual alert. warrant declaration of a warrant declaration of a (SEC) event. site area emergency. general emergency.

JUDGEMENT Asphyxiators such as carbon dioxide are not toxic, but it can be lethal if entry ls required into the area that is oxygen4eficient.

Thus, oxygen4eftclency is not a basis for classification unless access to the area is required for safe operation and access cannot be made because of the personnel hazard.

12.343 Revision xx

INITIATINGCONDITIONS RECOGNITiON CATEGORY: Natural / Destructive Phenomena MODES: ALL ECC UNUSUAL EVENT ALERT SITE AREA GENERAL EMERGENCY EMERGENCY NATURAL/ (NOT,:.'APPUCA'BLK",!.':.'i":;.. ~NOT'AP)LfCABLE!P)

DESTRUCTIVE i!DESTRUCTtVEi">'>>: ';,'!DESTRUCTtVB!PHENOWfEHA";:;:,

PHENOMENA MODES: ALL EAL CONFIRMED'eismic CONFIRMED'eismic event as Not Applicable Not Applicable N-1 event as indicated by:

indicated by:

SEISMIC Seismic instrument activation ACTMTY Seismic instrument or activation Ground motion at plant 4f recognized as an earthquake Ground motion at based on consensus of control plant recognized as room operators on duty an earthquake based on consensus of ~ and-control room

-OR- operators on duty.

Either:

Visible major damage to structures, systems, and components in vital areas 4f.

Plant trip EAL Report of a tornado Report of a TORNADO strike in Not Applicable Not Applicable N-2 strike within the a plant vital area.

protected area.

TORNADO/ -OR-HIGH WIND Sustained HIGH WIND a 90 Miles Per Hour

-OR-EAL Not Applicable Report of visible structural Not Applicable Not Applicable N4 damage to a structure containing systems required to VISIBLE establish and maintain cold STRUCTURAL shutdown.

DAMAGE

-OR-

'The National Earthquake Center (phone number (303) 273-8500 or 14%-525-7848) is the primary confirmation source.

12.344 Revision xx

INITIATINGCONDITIONS RECOGNITION CATEGORY: Natural I Destructive Ph enomena M D ECC UNUSUAL EVENT ALERT SITE AREA GENERAL NATURAL/

DESTRUCTIVE PHENOMENA L ', i'":,;;",";::;',:,":;;"j.:;"'i:;:i':,"'l,,:"

EMERGENCY EMERGENCY

,oJ!APpUCA'BLE<s,,','%NOT'APPLICABL'Ej 15 essential buses reduced to a loss of ALL onsite AC power offsite power and ALL onsite POWER'odes minutes. single power source for > to essential buses. AC power to essential 1R 15 minutes such that any buses.

additional single failure would result in a station blackout.

Loss of all offsite power to Loss of ALL offsite power Not Applicable Not Applicable LOSS OF AC essential buses for > 15 and loss of ALL onsite AC POWER'odes minutes. power to essential buses 6,6 during cold shutdown or refueling.

S-3: Unplanned loss of required Not Applicable Loss of all vital DC power for Not Applicable LOSS OF DC DC power during cold >>'15 minutes.

POWER shutdown or refueling mode Modes: 14 Modes: for > 15 minutes.

As Indicated Modes: 5,6 Under IC Not Applicable Inability to maintain plant in Loss of water level in the Not Applicable SQ'NABILITY TO cold shutdown. reactor vessel that has or will MAINTAINA UNIT uncover fuel in the reactor IN COLD vessel.

SHUTDOWN Mode 5,6 S-5: Not Applicable Not Applicable Complete loss of function Not Applicable LOSS OF needed to achieve or SYSTEMS maintain Hot Shutdown.

NEEDED TO ACHIEVE OR MAINTAINHOT SHUTDOWN

'valuate each unit's power supplies separately.

12.34T Revision xx

INITIATINGCONDmONS RECOGNITION CATEGORY: System Malfunctions MODES: As Shown ECC UNUSUAL EVENT ALERT SITE AREA EMERGENCY GENERAL EMERGENCY S4: Unplanned loss of safety Unplanned loss of most or all Inability to monitor a Not Applicable LOSS OF system annunciators and/or safety system annunciators significant transient'n ALARMS OR indications in the Control or indications in the Control progress.

INDICATION Room for > 15 minutes. Room with either (1) a significant transient'n Modes 1% progress, or (2) compensatory non-alarming indicators are unavailabh.

S-7: Indication of fuel clad Not Applicable Not Applicable Not Applicable FUEL CLAD degradation in active fuel.

DEGRADATION Modes: All S4: Reactor coolant system Not Applicable Not Applicable Not Applicable EXCESSIVE RCS leakage.

LEAKAGE Modes: 1Q S-g: Inability to reach required Not Applicable Not Applicable Not Applicable TECH SPEC shutdown within technical COMPLIANCE specification time limit.

Modes: 1Q S-10: Unplanned loss of all onsite Not Applicable Not Applicable Not Applicable SS OF or offsite communhations.

MUNICATION TEMS Modes: ALL

'xamphs of Significant Transhnt include: 1) reactor trip, 2) unanticipated power changes of a 10%, and 3) valid ESF actuations.

12.348 Revision xx

EMERGENCY CONDITION CATEGORIES (ECC)

INITIATINGCONDITION MATRIX FOR FISSION PRODUCT DEGRADATION BARRIER RECOGNITION BARRIER: FISSION PRODUCT BARRIER DEGRADATION UNUSUAL EVENT ALERT SITE AREA EMERGENCY GENERAL EMERGENCY ANY Loss or ANY Potential Loss of ANY Loss or ANY Potential Loss of Loss of BOTH Fuel Clad AND RCS Loss of any two barriers AND Containment barrier either Fuel Clad or Reactor Coolant barrier potential loss of third barrier System (RCS) barrier 4R-Potential Loss of BOTH Fuel Clad AND RCS barrier 4R-Potential Loss of EITHER Fuel Clad OR RCS barrier, and Loss of ANY additional banier (Note: Once a barrier has been declared lost, the symptoms of the loss may disappear. SEC judgement may be used to determine whether to carry the barrier as losL If the ability to monitor a barrier is degraded the SEC must use judgement to determine barrier status. If no turnaround in safety system performance is expected and escalation to Site Area Emergency or General Emergency is expected within two hours, then IMMINENTbamer degradation should be assumed and the SEC should make the appropriate ctassitication.)

12.3-69 Revision xx

FISSION PRODUCT BARRIER REFERENCE TABLE

1. FUEL CIAO BARRIER Applicable Modes: 1,2,3,4 LOSS POTENTIAL LOSS 1.1L Critical Safe Function Status Trees 1.1P Critical Safe Function Status Trees Core Cooling Critical Safety Function Status Tree - RED. Core Exit Thermocouples ) 7004 4R- 4R-1.2L Containment Radiation RVLIS Level ( 39%.

Containment area radiation greater than 200 R/hr. -OR-4R- Heat Sink Critical Safety Function Status Tree - RED.

1.3L Prima Coolant Activ 4R-Reactor Coolant System activity level greater than 300 microcuries per cc 1.4P S~EC Jud emsnl l-131 dose equivalenL 4R-Assessment of core damage greater than 5% clad failure.

4R-1.4L Site Eme en Coordinator SEC Jud ement 12.3-70 Revision xx

FISSION PRODUCT BARRIER REFERENCE TABLE

2. RCS BARRIER Applicable Modes: 1,2,3,4 LOSS POTENTIAL LOSS 2.1L RCS Leak Rate 2.1P Critical Safe Function Status Trees Unisolable RCS leak rate greater than avaihbh makeup capacity as RCS Integrity Critical Safety Function Status Tree - RED.

indicated by a complete loss of RCS subcooling.

4R-Meat Sink Critical Safety Function Status Tree - RED.

2.3L Steam Generator Leaka e 4R-Entry into OHP<023.E4, "Steam Generator Tube Rupture 2.2P RCS Leak Rate

-AND-UNISOtABLE RCS leakage greater than capacity of one centrifugal A non-isotable secondary line break or a prolonged release of charging pump in normal charging mode.

contaminated secondary coolant resulting in a radioactive release to the environment from the affected steam generator. 4R-4R- 2.3P Steam Generator Leaka e 2.4L Containment Radiation Alarm Ruptured steam generator with primary to secondary leak rate greater than capacity of one charging pump in normal charging lineup.

Containment Area Radiation > 10 R/hr.

-OR-4R-2.5P ~SEC Jud emenl 2.5L ~SEC Jud emenl 12.3-71 Revision xx

FISSION PRODU T BA FERENCE TABLE

3. CONTAINMENT BARRIER Applicable Modes: 1,2,3P LOSS POTENTIAL LOSS 3.1P Critical Safe Function Status Unisoiable breach of containment. Containment Crifical Safety Function Status Tree - RED.

4R-Containment pressure/sump level NOT performing 4R-consistent with expected condmons.

4R- 3.2P Containment Pressure Rapid unexphined containment pressure orsump level decrease following pressure increase caused by Hydrogen greater than 4%

LOCA. 4R-4R- Containment spray systems both inoperable OR fafi to auto start on Hl-Hl containment Entty into ECA-1.2, LOCA OUTSIDE CONTAINMENT. pressure.

4R-4R- Both containment air reclrcuhtlon fans inoperable OR fail to auto start on Hl-Hl containment pressure.

3.4L SG Seconda Side Release 4R-Containment pressure exceeds 12 psig.

Primaty to secondary leakage rate greater than 4R-technical specification limit. Containment hydrogen concentration greater than 0.5% AND key hydrogen control equipment (Containment air recircuhtion/hydrogen skimmer systems, electric hydrogen recombiners OR 4ND- igniters) inoperable.

Uncontrolled release of secondary coolant from the 4R-associated steam generator to the environment Is occurring. 3.5P Containment Radiation 4R- Containment area radiation greater than 1000 R/hr.

4R-37L ~SEC Jud ement Assessment of core damage greater than 20% clad failure.

4R-3.6P Core Exit Thermocou les Core Cooling Critical Safety Function Status Tree - RED.

-AND-Restoration procedures are not effective within 15 minutes.

4R-37P ~SEC Jud emenl 12.3-72 Revision xx