ML17334B602
| ML17334B602 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| 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 SIZE:
Z8 k gg TITLE: OR Submittal:
- Plans, Impl ment'g Procedures, C T NOTES:
E RECIPIENT ID CODE/NAME, PD3-1 PD COPIES LTTR ENCL 1
1 RECIPIENT
COPIES ID CODE/NAME LTTR ENCL HICKMANFJ 1
1 "INTERNAL.
EXTERNAL: NOAC R
01 UDOCS-ABSTRACT 2
2 1
1
.1 1
NRR/DRPM/PERB NRC PDR 1
1 1
1 D
U NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE CONTACT THE DOCUMENT CONTROL DESKr,'OOM OWFN SD-5(EXT. 415-2083)
TO ELIMINATE YOUR NAME 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 ADDITIONALINFORMATION (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). 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. It also includes a copy of the loss of residual heat removal (RHR) cooling 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 PDR ADOCK 05000S15 P
I DR
U. S. Nuclear Regulatory Commission Page 2
AEP: NRC: 1192C 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) willbe clarified in the next revision to the procedure.
The region ofthe 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.
6.A.
Why doesn't the EAL for hydrogen
>4%
include an oxygen concentration'?
r We do not monitor oxygen concentration in containment. Astatement 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 forAlert (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 EALfor 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 EAL43 for R-3: Alert?
The reactor cavity water level was added to the EAL.
Systems EALs Should a definition ofAnticipated 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.
20.A.
Why isn't mode applicability given in the S-3 tables?
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.
22.A.
Request information on OHP 4022.017.001, "Loss of RHR Cooling".
A copy of the procedure is provided in Attachment 5.
23.Q.
23.A.
Regarding S-5 EALs, what is the definition of not successful?
"Objectives of the procedure could not be accomplished".
The definition will be added to the basis.
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 forvarious 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 ofthe 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, willbe 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 ofthyroid bkicking agents, etc. These decisions are based upon the protective action guides in Annex S of the Michigan Emergency Management Plan (MEMP). Since copies ofthe 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 ofradioactive material to the atmosphere, PMP 2081 EPP.305 "Protective Action Recommendations,"
willbe used as the basis for recommendations for protective actions to the public. The procedure is based on the current issue ofthe "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 ofprotection.
On the other hand, because sheltering may be implemented in less time than evacuation, it may be the protective action of choice ifrapkt 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 ofthe 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 ofthe level of safety of the plant warrant a dectarafion of an Unusual Event.
~
Conditions which indicate an actual or potential substantial degradation ofplant safety systems ANDthat 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 ECC UNUSUAL EVENT ALERT SITE AREA EMERGENCY RECOGNITION CATEGORY: Hazards and Other Conditions Affecting Plant Safety MODES'LL GENERAI.
EMERGENCY H-1:
FIRE K-2:
TOXIC OR FLAMMABLE GASES'4:
CONTROL ROOM EVACUATION H4:
SECURITY EVENTS H-5:
SITE EMERGENCY COORDINATOR (SEC)
JUDGEMENT Fire within Protected Area boundary not extinguished within 15 minutes of detection.
Release of toxic or flammable gases deemed detrimental to safe operation of the plant.
Not Applicable Confirmed security event which indicates a potential degradation in the level of safety of the plant.
Other conditions existing which in the judgement of the SEC warrant declaration of an unusual event.
Fire or explosion affecting the operability of plant safety systems required to establish or maintain safe shutdown.
Release of toxic or flammable gases within a facility structure which Jeopardizes operation of systems required to maintain safe operations or to maintain cold shutdown.
Control Room evacuation has been Initiated.
Security event in a plant protected area.
Other conditions existing which in the judgement of the SEC warrant declaration of an alert.
Not Applicable Not Applicable Control Room evacuation has been initiated and plant control cannot be established.
Security event in a plant vital area.
Other conditions existing in the judgement of the SEC warrant declaration of a site area emergency.
Not Applicable Not Applicable Not Applicable Security event resulting in loss of ability to reach and maintain cold shutdown.
Other conditions existing which in the judgement of the SEC warrant declaration of a general emergency.
Asphyxiators such as carbon dioxide are not toxic, but itcan be lethal ifentry 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 EMERGENCY GENERAL EMERGENCY NATURAL/
DESTRUCTIVE PHENOMENA i!DESTRUCTtVEi">'>>: ';,'!DESTRUCTtVB!PHENOWfEHA";:;:,
(NOT,:.'APPUCA'BLK",!.':.'i":;.. ~NOT'AP)LfCABLE!P)
MODES: ALL EAL N-1 SEISMIC ACTMTY
-OR-EAL N-2 TORNADO/
HIGH WIND CONFIRMED'eismic event as indicated by:
Seismic instrument activation 4f Ground motion at plant recognized as an earthquake based on consensus of control room operators on duty.
Report of a tornado strike within the protected area.
CONFIRMED'eismic event as indicated by:
Seismic instrument activation or Ground motion at plant recognized as an earthquake based on consensus of control room operators on duty
~and-Either:
Visible major damage to structures, systems, and components in vital areas 4f.
Plant trip Report of a TORNADO strike in a plant vital area.
-OR-Sustained HIGH WIND a 90 Miles Per Hour Not Applicable Not Applicable Not Applicable Not Applicable EAL N4
-OR-VISIBLE STRUCTURAL DAMAGE Not Applicable Report of visible structural damage to a structure containing systems required to establish and maintain cold shutdown.
Not Applicable Not Applicable
-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:
enomena Natural I Destructive Ph M
D ECC UNUSUAL EVENT ALERT SITE AREA EMERGENCY GENERAL EMERGENCY NATURAL/
DESTRUCTIVE PHENOMENA L ',
i'":,;;",";::;',:,":;;"j.:;"'i:;:i':,"'l,,:",oJ!APpUCA'BLE<s,,','%NOT'APPLICABL'Ej 15 minutes.
Loss of all offsite power to essential buses for > 15 minutes.
Unplanned loss of required DC power during cold shutdown or refueling mode for > 15 minutes.
Modes: 5,6 Not Applicable Modes: 1-3 AC power capability to essential buses reduced to a single power source for >
15 minutes such that any additional single failure would result in a station blackout.
Loss of ALLoffsite power and loss of ALLonsite AC power to essential buses during cold shutdown or refueling.
Not Applicable Inability to maintain plant in cold shutdown.
Modes: 1,2 Loss of all offsite power and loss of ALLonsite AC power to essential buses.
Not Applicable Loss of all vital DC power for
>>'15 minutes.
Modes: 14 Loss of water level in the reactor vessel that has or will uncover fuel in the reactor vessel.
Modes: 1,2 Prolonged loss of ALL offsite power and ALLonsite AC power to essential buses.
Not Applicable Not Applicable Not Applicable Mode 5,6 S-5:
LOSS OF SYSTEMS NEEDED TO ACHIEVE OR MAINTAINHOT SHUTDOWN Not Applicable Not Applicable Complete loss of function needed to achieve or maintain Hot Shutdown.
Not Applicable
'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:
LOSS OF ALARMS OR INDICATION Modes 1%
S-7:
FUEL CLAD DEGRADATION Unplanned loss of safety system annunciators and/or indications in the Control Room for > 15 minutes.
Indication of fuel clad degradation in active fuel.
Unplanned loss of most or all safety system annunciators or indications in the Control Room with either (1) a significant transient'n
- progress, or (2) compensatory non-alarming indicators are unavailabh.
Not Applicable Inability to monitor a significant transient'n progress.
Not Applicable Not Applicable Not Applicable Modes: All S4:
EXCESSIVE RCS LEAKAGE Modes: 1Q S-g:
TECH SPEC COMPLIANCE Modes: 1Q S-10:
SS OF MUNICATION TEMS Reactor coolant system leakage.
Inability to reach required shutdown within technical specification time limit.
Unplanned loss of all onsite or offsite communhations.
Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable 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 MATRIXFOR FISSION PRODUCT DEGRADATION BARRIER RECOGNITION BARRIER: FISSION PRODUCT BARRIER DEGRADATION UNUSUAL EVENT ANYLoss or ANYPotential Loss of Containment barrier ALERT ANYLoss or ANYPotential Loss of either Fuel Clad or Reactor Coolant System (RCS) barrier SITE AREA EMERGENCY Loss of BOTH Fuel Clad AND 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 ANYadditional banier GENERAL EMERGENCY Loss of any two barriers AND potential loss of third barrier (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 Ifthe 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 LOSS 1.
FUEL CIAO BARRIER Applicable Modes: 1,2,3,4 POTENTIAL LOSS 1.1L Critical Safe Function Status Trees 1.1P Critical Safe Function Status Trees Core Cooling Critical Safety Function Status Tree - RED.
4R-Core Exit Thermocouples ) 7004 4R-1.2L Containment Radiation Containment area radiation greater than 200 R/hr.
RVLIS Level ( 39%.
-OR-1.3L Prima Coolant Activ 4R-Heat Sink Critical Safety Function Status Tree - RED.
4R-Reactor Coolant System activity level greater than 300 microcuries per cc l-131 dose equivalenL 4R-1.4P S~EC Jud emsnl 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 Unisolable RCS leak rate greater than avaihbh makeup capacity as indicated by a complete loss of RCS subcooling.
2.1P Critical Safe Function Status Trees RCS Integrity Critical Safety Function Status Tree - RED.
4R-2.3L Steam Generator Leaka e
Meat Sink Critical Safety Function Status Tree - RED.
Entry into OHP<023.E4, "Steam Generator Tube Rupture
-AND-2.2P RCS Leak Rate 4R-A non-isotable secondary line break or a prolonged release of contaminated secondary coolant resulting in a radioactive release to the environment from the affected steam generator.
UNISOtABLE RCS leakage greater than capacity of one centrifugal charging pump in normal charging mode.
4R-4R-2.3P Steam Generator Leaka e 2.4L Containment Radiation Alarm Containment Area Radiation > 10 R/hr.
4R-2.5L
~SEC Jud emenl Ruptured steam generator with primary to secondary leak rate greater than capacity of one charging pump in normal charging lineup.
-OR-2.5P
~SEC Jud emenl 12.3-71 Revision xx
FISSION PRODU T BA FERENCE TABLE
- 3. CONTAINMENTBARRIER Applicable Modes:
1,2,3P LOSS POTENTIAL LOSS 3.1P Critical Safe Function Status Unisoiable breach of containment.
4R-Containment pressure/sump level NOT performing consistent with expected condmons.
4R-Rapid unexphined containment pressure orsump level decrease following pressure increase caused by LOCA.
4R-Entty into ECA-1.2, LOCA OUTSIDE CONTAINMENT.
4R-3.4L SG Seconda Side Release Primaty to secondary leakage rate greater than technical specification limit.
4ND-Containment Crifical Safety Function Status Tree - RED.
4R-3.2P Containment Pressure Hydrogen greater than 4%
4R-Containment spray systems both inoperable OR fafi to auto start on Hl-Hl containment pressure.
4R-Both containment air reclrcuhtlon fans inoperable OR fail to auto start on Hl-Hl containment pressure.
4R-Containment pressure exceeds 12 psig.
4R-Containment hydrogen concentration greater than 0.5% AND key hydrogen control equipment (Containment air recircuhtion/hydrogen skimmer systems, electric hydrogen recombiners OR igniters) inoperable.
Uncontrolled release of secondary coolant from the associated steam generator to the environment Is occurring.
3.5P Containment Radiation 4R-37L
~SEC Jud ement 4R-Containment area radiation greater than 1000 R/hr.
4R-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.
~SEC Jud emenl 12.3-72 Revision xx