Text

Responds to 961022 RAI Re Revised Emergency Action Levels
	ML18102A560
Person / Time
Site:	Salem
Issue date:	11/19/1996
From:	Dawn Powell; Public Service Enterprise Group
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	LR-N96324, NUDOCS 9611210115
	Download: ML18102A560 (72)
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e Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit NOV 19 1996 LR-N96324 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION HOPE CREEK.AND SALEM GENERATING STATIONS REVISED EMERGENCY ACTION LEVELS SALEM GENERATING STATION UNIT NOS. 1.AND 2 DOCKET NOS. 50-272.AND 50-311 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Gentlemen:

The attachments to this submittal contain PSE&G's response to the NRC questions on the Hope Creek and Salem Generating Stations Revised Emergency Action Levels (EALs).

The request for this information was.contained in NRC letter dated October 22, 1996.

The states of New Jersey and Delaware are in agreement with the EAL revisions contained in the attachment to this submittal.

If there are any questions regarding this submittal, please contact us.

Sincerely, j). R. pd<<,d(

D. R. Powell Manager -

Licensing and Regulation

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l 9611210115 961119 PDR ADOCK 05000272 f

PDR The power is in your hands.

95-2168 REV. 6/94

Document Control Desk LR-N96324 Attachmens C Mr. Hubert J. Miller, Administrator -

Region I U. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olshan, Licensing Project Manager -

Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. D. Jafee, Licensing Project Manager -

Hope Creek U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. R. Summers USNRC Senior Resident Inspector X24 Mr. C. Marschall USNRC Senior Resident Inspector X24 Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625

l Document Control Desk LR-N96324 DVH BC Senior Vice President - Nuclear Operations (X04)

Senior Vice President - Nuclear Engineering (N19)

Director -

QA/NSR (XOl)

General Manager -

Salem Operations (SOS)

Manager - Nuclear Fuels (N20)

Onsite Safety Review Engineer -

Salem (S15)

Station Licensing Engineer -

Salem (X09)

Station Licensing Engineer -

Hope Creek (X09)

General Solicitor, R. Fryling, Jr. (Newark, 5G)

Mark J. Wetterhahn, Esq.

Records Management (N21)

Microfilm Copy File Nos.

1. 2, 5. 2 8

(, '

LR-N96324 ATTACHMENT 1 Salem Generating Station (SNGS)

ISSUE lA &lC:

A. The licensee exceeds the NUMARC guidance for deferring the classification in favor of a dose assessment classification by 100% (30 minutes vs. 15 minutes).

This deviation is the same one that exists for the Alert level classification (SNGS) EAL 6.1.2.d).

The licensee's justification for the deviation in EAL 6.1.2.d is that their EAL is based on a limit that is five times lower than the limit referenced in the NUMARC guidance.

The licensee does not want to declare the Alert due to a monitor reading based on the lower limit if an accurate dose assessment can be performed to verify if this EAL is valid.

The limit upon which SNGS EAL 6.1.3.d is based is the same as that in the NUMARC guidance.

The basis for both EALs is the Environmental Protection Agency Protective Action Guidelines (EPA PAGs).

The licensee's justification for the increase of time by 15 minutes is to avoid misclassification of the event by allowing time to obtain dose assessment projections from a second onsite computer should the primary computer fail.

When considering EALs at the higher classifications that are related to radiological releases, it is especially important to classify the event promptly so that notifications can be made and protective actions considered in a timely manner.

The licensee's basis for this deviation does not adequately justify the prolonged duration of the release before a classification can be made based on the monitor reading.

Provide additional information that justifies the departure from the NUMARC guidance.

Also, provide a comparison of derived release rate thresholds for assumed ODCM source term, the FSAR source term, and/or any other reasonable source terms that approximate most probable core damage situations.

C. The same issues described in A. and B. above exist in the wording of SNGS EAL 6.1.4.d, which is the General Emergency gaseous radiological effluent EAL.

PSE&G RESPONSE:

The request for deviation concerning SNGS EAL 6.1.3.d &

6.1.4.d is withdrawn.

The EALs and their associated bases documents have been revised to 15 minutes which matches the NUMARC criteria.

Revised EAL and bases are attached.

1

LR-N96324 ATTACHMENT 1 Salem Generating Station (SNGS)

ISSUE #lB &lC:

The NUMARC basis for EAL ASl.1 states that the FSAR source term assumptions should be used in determining the indications for the monitors, but the Salem Generating Station Event Classification Guide Technical Basis (SNGSECGTB) states that SNGS EAL 6.1.3.d is based on the default isotopic mixture assumption contained in the Offsite Dose Calculation Manual (ODCM).

The use of ODCM source term is valid for lower level classifications (Unusual Event and Alert) where no core damage is assumed and any radiological releases are likely to be from a source term derived from normal plant operation.

The releases associated with the higher level classifications (Site Area Emergency and General Emergency) however, are more likely to be associated with core damage events and the isotopic mixture will be more radiologically adverse.

While the FSAR source is probably over-conservative for releases resulting from sequences involving a small amount of core damage, some realistic source term should be assumed.

The ODCM source term may be acceptable if a conservative mixture of radioisotopes, closely approximating that expected from the most probable core damage sequences, is assumed.

There is insufficient information to explain why the ODCM source term assumed for this EAL is more valid than accident source term data derived from the FSAR or assumed from some other guidance.

Provide additional information that justifies the departure from the NUMARC guidance.

Also, provide a comparison of derived release rate thresholds for assumed ODCM source term, the FSAR source term, and/or any other reasonable source terms that approximate most probable core damage situations.

C. The same issues described in A. and B. above exist in the wording of SNGS EAL 6.1.4.d, which is the General Emergency gaseous radiological effluent EAL.

PSE&G RESPONSE:

EALs 6.1.3.d and 6.1.4.d for Salem were reviewed and adjusted to more accurately define an accident source term.

The source terms were back calculated from a Total Effective Dose Equivalent dose of 100 mR and 1000 mR at the Minimum Exclusion Area using the assumptions listed below which are also included in the revised bases for each EAL.

2

LR-N96324 ATTACHMENT 1 Salem Generating Station (SNGS)

Assumptions for Salem:

release point was the plant vent stack release flow rate: 80,000 cfm ODCM X/Q: 2.2E-06 Sec/m3 isotopic mixture: FSAR mixture for DBLOCA Dose Rate Conversion Factors:

from EPA 400-R-92-001 Salem revised EAL values for Site Area Emergency and General Emergency respectively are, 1.7E+09 uCi/Sec and 1.7E+10 uCi/Sec.

The unmodified FSAR Dose Rate Conversion Factor results in a NUMARC Site Area Emergency value of 9.15E+12 uCi/Sec and a General Emergency NUMARC value of 9.15E+13 uCi/sec. These values are higher than the Salem revised EAL values and could result in an unconservative classification decision.

The method of back calculation using an ODCM X/Q and UFSAR accident isotopic mix provides a realistic source term value on which to base classification decisions.

Revised EAL and bases are attached.

3

LR-N96324 ATTACHMENT 1 Salem Generating Station (SNGS)

ISSUE #2:

A. The dose rate threshold stated in the EAL is for a value "above normal" for a given area and implies that different values exist for different areas.

The basis for this EAL, however, appears to base the threshold on the prevention of a specific dose of 2000 mRem in a year's time.

This logic would indicate that a uniform dose rate value for all of the areas to be considered would be more appropriate than an increase above the normal value by 2000 mRem/hr.

B. It is unclear how the statement "This value is low enough to allow any increase in normal radiation level, by a factor of 1000, to be classified as an Unusual Event... "

does in fact accomplish this, since keeping the Alert threshold lower would lead to overlap between the Unusual Event and Alert thresholds.

It is also unclear how this overlap is prevented for areas with normal radiation levels > 2 mR/hr.

Provide additional information to clarify the basis of this EAL, particularly whether the threshold should be expressed as a uniform value or a margin above normal dose rate levels.

Also provide additional information to describe how the value chosen for the threshold provides a margin between the Unusual Event and Alert conditions.

PSE&G RESPONSE:

EAL 6.3.2.a has been revised to be expressed as a uniform value of 2000 mR/hr.

This EAL has been split from EAL 6.3.1.a so it is no longer dependent on background radiation.

A statement has been added to the bases of EAL 6.3.2.a which says that the 2000 mR/hr includes any pre-existing background radiation.

The EAL threshold value of 2000 mR/hr was selected because of the PSE&G annual administrative limit of 2000 mR/yr.

If inplant dose rates approached or exceeded 2000 mR/hr, personnel would take steps to obtain a dose extension to ensure the 2000 mR/yr administrative limit was not exceeded without proper authorization.

The administrative requirement to obtain a dose extension could slow down or impede operations of systems required to maintain safe operations of the plant and therefore meets NUMARC IC AA3.

Dose rate increases by a factor of 1000 in areas of the plant that have a normal background radiation level of < 2 mR/hr would result in dose rates of < 2000 mR/hr and thus provides a threshold margin between the Unusual Event and Alert condition.

For example: for areas that have a normal dose 4

LR-N96324 ATTACHMENT 1 Salem Generating Station (SNGS) rate of.5 mR/hr and 1.5 mR/hr a 1000 fold increase would result in dose rates of 500 mR/hr and 1500 mR/hr and an Unusual Event would be declared.

Further degradation that caused dose rates to exceed 2000 mR/hr would then result in an Alert declaration if in the areas of the plant which require access to maintain plant safety functions.

This change was not addressed by the NRC for the Hope Creek Generating Station.

However, this change was also made in Hope Creek EALs.

The Salem and Hope Creek revised EALs and bases are attached.

5

~R-N96324 ATTACHMENT 1 Salem Generating Station (SNGS)

ISSUE #3:

NUMARC EALs HUl.7 and HAl.7 provide for including site-specific conditions such as flooding in the group of natural phenomena that warrant emergency classification.

The licensee, in the original NUMARC EAL submittal, included low and high river water level as examples of these types of events.

Low and high river water levels are also included in the currently approved EAL scheme.

In the latest submittal (dated July 3, 1996,) the licensee has deleted these EALs.

In the comments accompanying the submittal, the licensee stated that these EALs were redundant to other EALs and served no useful purpose.

The licensee further stated that since the only way for river level to become excessively high or low would be as a result of a severe hurricane or storm which would be anticipated well in advance by precautionary staffing of emergency response facilities, the licensee felt that the purpose of any Unusual Event or Alert declarations would already be accomplished.

The lack of any lower level classifications related to the river level removes the anticipatory notification of more serious consequences arising from these conditions.

For low river level, the appearance of a storm that would drastically lower the river level would be anticipated and tracked.

The licensee also most probably would staff its emergency response facilities in advance of the storm's arrival under an established storm plan or procedure.

Under the licensee's latest EAL submittal, however, the offsite authorities would not be notified of a lowering river condition until the condition had caused a loss of the plant's heat sink and began threatening fission product barrier integrity.

Conversely, for a rising river level, the licensee would not make any notifications to the offsite authorities until the storm yielded hurricane force winds onsite or the flooding conditions caused actual damage to safety systems.

If an Alert condition were not declared until flooding conditions were allowed to reach a level such that plant safety systems were damaged, the site by that time may be inaccessible to emergency personnel who would be called in to respond to or mitigate the flooding consequences.

Also, no notification of a high river water level event would be made until the flooding was of such a nature that offsite authorities, considering any protective actions, may not be able to initiate those protective actions due to the flooding conditions.

Please provide additional information that justifies the removal of these EALs from the latest submittal.

6

L'R-N96324 ATTACHMENT 1 Salem Generating Station (SNGS)

PSE&G RESPONSE:

The deletion of all EALs dealing with Low and High River level has been reassessed.

The EALs have been revised to now include both a high and low river level EAL resulting in a "Common Site",

Unusual Event condition.

These new EALs address the concern expressed related to "anticipatory notification" of offsite authorities and PSE&G management personnel.

Decisions related to staffing or activation of Emergency facilities will be made based on plant conditions, weather conditions and station accessibility.

The PSE&G Severe Weather Guide will guide planning actions and staffing decisions prior to exceeding EAL thresholds that require implementation of the Emergency Plan.

Revised EAL and bases are attached.

7

LR-N96324 ATTACHMENT 1 Salem Generating Station (SNGS)

ISSUE #4:

A. While damage to the turbine casing from turbine blades can only realistically occur when there is substantial steam pressure to add energy to the turbine rotors, the potential for damage from seal oil, lube oil or hydrogen exists any time these systems are pressurized and operating.

These conditions are independent of secondary plant steam pressure and could occur in any mode.

Provide additional information that justifies the departure from the NUMARC guidance.

PSE&G RESPONSE:

The subject EAL was revised to be applicable in ALL modes of operations as per NUMARC. The PSE&G deviation is deleted.

Revised EAL and bases are attached.

8

LR-N96324 ATTACHMENT 2 Hope Creek Generating Station (HCGS)

ISSUE #lA &lB:

A. While HCGS EAL 6.1.1.d references an Iodine release rate, it includes neither an instrument value nor an alarm condition for the plant vent Iodine monitors.

Since the intent of this EAL is to classify an emergency condition based on monitor readings, such readings/alarm conditions are necessary parts of the EAL.

B. This issue also applies to HCGS EAL 6.1.2.d, which is equivalent to NUMARC EAL AAl.1.

Provide additional information that justifies the departure from the NUMARC guidance.

PSE&G RESPONSE:

Alarm indications for the North Plant Vent and South Plant Vent Iodine have been added to EALs 6.1.1.d & 6.1.2.d.

There are no iodine monitors installed for the Filtration, Recirculation, & Ventilation System or Hardened Torus Vent, vent pathways and therefore, no values are included in the EALs.

Revised EAL and bases are attached.

1

LR-N96324 ATTACHMENT 2 Hope Creek Generating Station (HCGS)

ISSUE #2A &2D:

The licensee exceeds the NUMARC guidance for def erring the classification in favor of a dose assessment classification by 100% (30 minutes vs. 15 minutes).

This deviation is the same one that exists for the Alert level classification (HCGS EAL 6.1.2.d).

The licensee's justification for the deviation in EAL 6.1.2.d is that their EAL is based on a limit that is five times lower than the limit referenced in the NUMARC guidance.

The licensee does not want to declare the Alert due to a monitor reading based on the lower limit if an accurate dose assessment can be performed to verify if this EAL is valid.

The limit upon which HCGS EAL 6.1.3.d is based is the same as that in the NUMARC guidance. The basis for both EALs is the Environmental Protection Agency Protective Action Guidelines (EPA PAGs).

The licensee's justification for the increase of time by 15 minutes is to avoid misclassification of the event by allowing time to obtain dose assessment projections from a second onsite computer should the primary computer fail.

When considering EALs at the higher classifications that are related to radiological releases, it is especially important to classify the event promptly so that notifications can be made and protective actions considered in a timely manner.

The licensee's basis for this deviation does not adequately justify the prolonged duration of the release before a classification can be made based on the monitor reading.

D. The same issues described in A. through C. above exist in the wording of HCGS EAL 6.1.4.d, which is the General Emergency gaseous radiological effluent EAL.

Provide additional information that justifies the departure from the NUMARC guidance.

PSE&G RESPONSE:

The request for deviation concerning HCGS EAL 6.1.3.d &

6.1.4.d is withdrawn.

The EALs and their associated bases documents have been revised to 15 minutes which matches the NUMARC criteria.

Revised EAL and bases are attached.

2

LR-N96324 ATTACHMENT 2 Hope Creek Generating Station (HCGS)

ISSUE #2A & 2D:

B. The NUMARC basis for EAL ASl.1 states that the FSAR source term assumptions should be used in determining the indications for the monitors, but the Hope Creek Generating Station Event Classification Guide Technical Basis (HCGSECGTB) states that HCGS EAL 6.1.3.d is based on the default isotopic mixture assumption contained in the Offsite Dose Calculation Manual (ODCM).

The use of ODCM source term is valid for lower level classifications (Unusual Event and Alert) where no core damage is assumed and any radiological releases are likely to be from a source term derived from normal plant operation.

The releases associated with the higher level classifications (Site Area Emergency and General Emergency); however, are more likely to be associated with core damage events and the isotopic mixture will be more radiologically adverse.

There is insufficient information to explain why the licensee has elected to use ODCM source term data over accident source term data derived from the FSAR or some other source for EAL 6.1.3.d.

D.

The same issues described in A. through c. above exist in the wording of HCGS EAL 6.1.4.d, which is the General Emergency gaseous radiological effluent EAL.

Provide additional information that justifies the departure from the NUMARC guidance.

PSE&G RESPONSE:

EALs 6.1.3.d and 6.1.4.d for Hope Creek were reviewed and adjusted to more accurately define an accident source term.

The source terms were back calculated from a Total Effective Dose Equivalent dose of 100 mR and 1000 mR at the Minimum Exclusion Area using the assumptions listed below which are also included in the revised bases for each EAL.

Assumptions for Hope Creek:

release point was from Filtration, Recirculation, &

Ventilation System (FRVS) release flow rate: 9,000 cfm ODCM X/Q: 2.67E-06 Sec/m3 isotopic mixture: FSAR mixture for DBLOCA Dose Rate Conversion Factors:

from EPA 400-R-92-001 3

LR-N96324 ATTACHMENT 2 Hope Creek Generating Station (HCGS)

Hope Creek revised EAL values for Site Area Emergency and General Emergency respectively are, 7.6E+07 uCi/Sec and 7.6E+08 uCi/Sec.

The unmodified FSAR Dose Rate Conversion Factor results in a NUMARC Site Area Emergency value of 6.05E+12 uCi/Sec and a General Emergency NUMARC value of 6.05E+13 uCi/sec. These values are higher than the Hope Creek revised EAL values and could result in an unconservative classification decision.

The method of back calculation using an ODCM X/Q and FSAR accident isotopic mix provides a realistic source term value on which to base classification decisions.

Revised EAL and bases are attached.

4

L~-N96324 ATTACHMENT 2 Hope Creek Generating Station (HCGS)

ISSUE #2C &2D:

C. While HCGS EALs 6.1.1.d and 6.1.2.d contain a threshold for an Iodine release rate, EAL 6.1.3.d does not.

This may be due to the fact that the threshold for the EAL is above the indicating range for the Iodine detectors.

A release rate based on monitor readings would not be obtainable in this case.

However, the HCGSECGTB does not state this in the basis for this EAL.

This fact was stated in the basis for EAL 6.1.2.d in the original, August 24, 1995 submittal, but it was deleted from the basis in the July 3, 1996 re-submittal.

D. The same issues described in A. through C. above exist in the wording of HCGS EAL 6.1.4.d, which is the General Emergency gaseous radiological effluent EAL.

Provide additional information that justifies the departure from the NUMARC guidance.

PSE&G RESPONSE:

The threshold for EALs 6.1.3.d and 6.1.4.d for Iodine release is above the indicating range for the South Plant Vent and North Plant Vent Iodine monitoring channels.

This has been added to the discussion section of the HCGSECGTB for these two EALs.

Revised EAL and bases are attached.

5

L'R-N96324 ATTACHMENT 2 Hope Creek Generating Station (HCGS)

ISSUE #3:

A. HCGS EAL 3.3.2.b does not include the indication where drywell pressure response is not consistent with LOCA conditions.

This precludes the recognition and consideration of containment leak rates that result in lower than expected drywell pressures for severe LOCAs.

In these cases the containment energy loss rate is less than the RCS energy loss rate such that the containment pressure may not decrease, but will peak at a value that is much lower than expected.

Provide additional information that justifies the departure from the NUMARC guidance.

PSE&G RESPONSE:

A new EAL #3.3.2.d was added to the Fission Product Barrier table in Section 3 of the ECG to address drywell pressure response not consistent with LOCA conditions.

In addition, readability enhancements have been incorporated into the table.

Revised EAL (Fission Product Barrier Table) and bases are attached.

6

L~-N96324 ATTACHMENT 2 Hope Creek Generating Station (HCGS)

ISSUE #4:

NUMARC EALs HUl.7 and HAl.7 provide for including site-specific conditions such as flooding in the group of natural phenomena that warrant emergency classification.

The licensee, in the original NUMARC EAL submittal, included low and high river water level as examples of these types of events.

Low and high river water levels are also included in the currently approved EAL scheme.

In the latest submittal (dated July 3, 1996,) the licensee has deleted these EALs.

In the comments accompanying the submittal, the licensee stated that these EALs were redundant to other EALs and served no useful purpose.

The licensee further stated that since the only way for river level to become excessively high or low would be as a result of a severe hurricane or storm which would be anticipated well in advance by precautionary staffing of emergency response facilities, the licensee felt that the purpose of any Unusual Event or Alert declarations would already be accomplished.

The lack of any lower level classifications related to river level removes the anticipatory notification of more serious consequences arising from these conditions.

For low river level, the appearance of a storm that would drastically lower river level would be anticipated and tracked.

The licensee also most probably would staff its emergency response facilities in advance of the storm's arrival under an established storm plan or procedure.

Under the licensee's latest EAL submittal, however, the offsite authorities would not be notified of a lowering river condition until the condition had caused a loss of the plant's heat sink and began threatening fission product barrier integrity.

Conversely, for a rising river level, the licensee would not make any notifications to the offsite authorities until the storm yielded hurricane force winds onsite or the flooding conditions caused actual damage to safety systems.

If an Alert condition were not declared until flooding conditions were allowed to reach a level such that plant safety systems were damaged, the site by that time may be inaccessible to emergency personnel who would be called in to respond to or mitigate the flooding consequences.

Also, no notification of a high river water level event would be made until the flooding was of such a nature that offsite authorities, considering any protective actions, may not be able to initiate those protective actions due to the flooding conditions.

Please provide additional information that justifies the removal of these EALs from the latest EAL submittal.

7

LR-N96324 ATTACHMENT 2 Hope Creek Generating Station (HCGS)

PSE&G RESPONSE The deletion of all EALs dealing with Low and High River level has been reassessed.

We have revised our EALs to now include both a high and low river level EAL resulting in a "Common Site",

Unusual Event condition.

These new EALs address the concern expressed related to "anticipatory notification" of offsite authorities and PSE&G management personnel.

Decisions related to staffing or activation of Emergency facilities will be made based on plant conditions, weather conditions and station accessibility.

The PSE&G Severe Weather Guide will guide planning actions and staffing decisions prior to exceeding EAL thresholds that require implementation of the Emergency Plan.

Revised EAL and bases are attached.

8

~R-N96324 ATTACHMENT 2 Hope Creek Generating Station (HCGS)

Issue 5:

A. While damage to the turbine casing from turbine blades can only realistically occur when there is substantial steam pressure to add energy to the turbine rotors, the potential for damage from seal oil, lube oil or hydrogen exists any time these systems are pressurized and operating.

These conditions are independent of secondary plant steam pressure and could occur in any mode.

Provide additional information that justifies the departure from the NUMARC guidance.

PSE&G RESPONSE The subject EAL was revised to be applicable in ALL Operational Conditions as per NUMARC.

The PSE&G deviation is deleted.

Revised EAL and bases are attached.

9

Initiating Condition MODE EAL#

E M

E R

G E

N c

y A

c T

I 0

N L

E v

E L

s Action Required 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release

.SGSa:

Rev. oo-Page 3 of4 Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds I 00 mRem Total Effective Dose Equivalent (TEDE) or 500 mRem Thyroid-CDE Dose for the Actual or Projected Duration of the Release Dose Assessment

(

All

)

6.1.3.a IF Dose Assessment indicates EITHER one of the following at the MEA or beyond as calculated on the SSCL:

TEDE 4-Day Dose

l.OE+02 mRem

Thyroid-CDE Dose

5.0E+02 mRem based on Plant Vent effluent sample analysis and NOT on a default Noble Gas to Iodine Ratio Field

(

All

)

6.1.3.b IF Measured Dose Rate Dose Rate measured at the Protected Area Boundary or beyond EXCEEDS 100 mRem/hr AND Release is expected to continue for

=:::: 15 minutes

(

All

)

6.1.3.c Field Survey Analysis IF Analysis of field survey samples at the Protected Area Boundary indicates EITHER one of the following:

::::: 4.36E+02 CCPM

=:::: 3.85E-07 11Ci/cc 1-131 THEN Refer to Attachment 3 SITE AREA EMERGENCY Alarm Indications

(

All

)

6.1.3.d IF Valid Plant Vent Effiuent Alarm AND Total Plant Vent release rate EXCEEDS

1. 7E+o9 JLCl/sec Total Noble Gas AND Dose Assessment results NOT available.

AND I Release is ongoing for=:::: 15 minutes

SGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release SITE AREA EMERGENCY - 6.1.3.d IC Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mRem Total Effective Dose Equivalent (TEDE) or 500 mRem Thyroid-COE Dose for the actual or projected duration of the release EAL Valid Plant Vent Effluent Alarm Total Plant Vent release rate EXCEEDS 1.7E+09 µCi/sec Total Noble Gas Dose Assessment results NOT available Release is ongoing for.L 15 minutes MODE-AU BASIS Valid High alarm and effluent release rate values exceeding the EAL threshold, indicates a substantial Gaseous Radiological Release which could exceed the 10CFR20 average annual population exposure limit of 100 mRem TEDE, using the assumption of a one hour release duration.

The EAL value for Total Plant Vent release rate was determined using default X/Q values from the ODCM which provides a less accurate method of evaluation release magnitude then using dose assessment with real time meteorological data. For that reason, this EAL should not be utilized if Dose Assessment is available. Dose Assessment will take into account actual meteorological conditions, plant vent flows and plant vent effluent concentrations to provide a more accurate assessment of a radiological release. If Dose Assessment is available then Refer to EAL 6.1.3.a for classification.

Page 1 of 3 EAL - 6.1.3.d Rev. 00

SGS EAL/RAL Technical Basis The Total Noble Gas monitored Release Rate can be obtained from SPDS or in accordance with Sl.OP-AB.RAD-OOl(Q) or S2.0P-AB.RAD-00l(Q), Abnormal Radiation.

It is not intended that the release be averaged over 15 minutes, but that the Release Rate exceed the EAL value for > 15 minutes.

Barrier Analysis NIA ESCALATION CRITERIA Emergency Classification will escalate to a General Emergency when effluent release concentration increases to a level that would cause a 1000 mRem dose at the Protected Area Boundary DISCUSSION To obtain a site specific value to trigger the performance of dose assessment is not necessary, since this will be done when the UE value is reached. This value will supply a set point to classify a Site Area Emergency (SAE), if dose assessment has not been performed within 15 minutes. Iodine Release Rates for this EAL are excluded since the Plant Vent Radiation Monitoring System does not include an Iodine detector.

A release rate of 1.7E+09 µCi/sec was backcalculated from a TEDE Dose of 100 mRem/hour at the Site MEA. The assumptions that went into this calculation were as follows:

Release Point: Plant Vent Release Rate: 80,000cfm ODCM X/Q = 2.20E-06 sec/m3 Isotopic mixture: FSAR isotopic mixture for a design basis LOCA Dose Rate Conversion Factors: EPA 400-R-92-001 (Manual of Protective Actions for Nuclear Incidents) Dose Rate Conversion Factors.

Page 2 of 3 EAL - 6.1.3.d Rev. 00

SGS EAL/RALTechnical Basis DEVIATION The NUMARC basis states that the FSAR source term assumptions should be used in determining the indications for monitors. The NUMARC Draft White Paper states the FSAR source term should not be used unmodified.

This NUMARC EAL is calculated using the FSAR Isotopic Mixture for a Design Basis LOCA and the Dose Rate Conversion Factors found in EPA 400-R-001. The combination of using the FSAR Isotopic mixture and the EPA 400 dose Rate Conversion Factors calculate an accurate accident source term.

REFERENCES NUMARC NESP-007, AS 1.1, AS 1.4 Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94; 9-10-94.

Technical Specification 3.11.2.1 FSAR Section 15 EPA 400-R-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents Page 3 of 3 EAL - 6.1.3.d

Rev. 00

Initiating Condition MODE EAL#

E M

E R

G E

N c

y A

c T

I 0

N L

E v

E L

s Action Required 6.0 Radiological Re eases/Occurrences 6.1 Gaseous Effluent Release SGS ECG Rev. 00 Page4 of4 Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 1000 mRem Total Effective Dose Equivalent (TEDE) or 5000 mRem Thyroid~CDE Dose for the Actual or Projected Duration of the Release

( All )

6.1.4.a Dose IF Assessment Dose Assessment indicates EITHER one of the following at the MEA or beyond as calculated on the SSCL:

TEDE 4-Day Dose

=::: 1.0E+03 mRem

Thyroid-CDE Dose

=::: 5.0E+03 mRem based on Plant Vent effluent sample analysis and NOT on a default Noble Gas to Iodine Ratio Field c All

)

6.1.4.b Measured Dose Rate IF Dose Rate measured at the Protected Area Boundary or beyond EXCEEDS 1000 mRem/hr AND Release is expected to continue for

=::: 15 minutes c All

)

Field Survey 6.1.4.c IF Analvsis Analysis of field survey samples at the Protected Area Boundary indicates EITHER one of the following:

::::: 4.36E+03 CCPM

::::: 3.85E-06 µCi/cc 1-131 THEN Refer to Attachment 4 GENERAL EMERGENCY Alarm Indications

(

All

)

6.1.4.d IF Valid Plant Vent Effiuent Alarm AND Total Plant Vent release rate EXCEEDS 1.7E+1011Ci/sec Total Noble Gas AND Dose Assessment results NOT available.

AND I Release is ongoing for~ 15 minutes I

,]

SGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release GENERAL EMERGENCY - 6.1.4.d IC Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 1000 mRem Total Effective Dose Equivalent (TEDE) or 5000 mRem Thyroid-CDE Dose for the actual or projected duration of the release EAL Valid Plant Vent Effluent Alarm Total Plant Vent release rate EXCEEDS 1.7E+10 µCi/sec Total Noble Gas Dose Assessment results NOT available Release is ongoing for L 15 minutes MODE-All BASIS Valid High alarm and effluent release rate values exceeding the EAL threshold, indicates a substantial Gaseous Radiological Release which could exceed the EPA Protective Action Guide exposure of 1000 mRem TEDE, using the assumption of a one hour release duration.

The EAL value for Total Plant Vent release rate was determined using default X/Q values from the ODCM which provides a less accurate method of evaluation release magnitude then using dose assessment with real time meteorological data. For that reason, this EAL should not be utilized if Dose Assessment is available. Dose Assessment will take in account actual meteorological conditions, plant vent flows and plant vent effluent concentrations to provide a more accurate assessment of a radiological release. If Dose Assessment is available then refer to EAL 6.1.4.a for classification. The Total Noble Gas monitor Release Rate can be obtained from SPDS or in accordance with Sl.OP-AB.RAD-OOl(Q) or S2.0P-AB.RAD-000l(Q),

Page 1 of 3 EAL - 6.1.4.d Rev. 00

SGS EAL/RALTechnical Basis Abnormal Radiation. It is not intended that the release be averaged over 15 minutes, but that the Release Rate exceed the EAL value for L.15 minutes.

Barrier Analysis NIA ESCALATION CRITERIA None DISCUSSION To obtain a site specific value to trigger the performance of dose assessment is not necessary, since this will be done when the UE value is reached. This value will supply a set point to classify a General Emergency (GE), if dose assessment has not been performed within 15 minutes. Iodine Release Rates for this EAL are excluded since the Plant Vent Radiation Monitoring System does not include an Iodine detector.

A release rate of 1. 7E+ 10 µCi/ sec was backcalculated from a TEDE Dose of 1 OOOmRem/hour at the Site MBA. The assumptions that went into this calculation were as follows:

Release Point: Plant Vent Release Rate: 80,000cfm ODCM X/Q = 2.20E-06 sec/m3 Isotopic mixture: FSAR isotopic mixture for a design basis LOCA Dose Rate Conversion Factors: EPA 400-R-92-001 (Manual of Protective Actions for Nuclear Incidents) Dose Rate Conversion Factors.

DEVIATION The NUMARC basis states that the FSAR source term assumptions should be used in determining the indications for monitors. The NUMARC Draft White Paper states the FSAR source term should not be used unmodified.

This NUMARC EAL is calculated using the FSAR Isotopic Mixture for a Design Basis LOCA and the Dose Rate Conversion Factors found in EPA 400-R-001. The combination of using the FSAR Isotopic mixture and the EPA 400 dose Rate Conversion Factors calculate an accurate accident source term.

Page 2 of 3 EAL - 6.1.4.d Rev. 00

SGS EAL/RALTechnical Basis REFERENCES NUMARC NESP-007, AS 1.1, AS 1.4 Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94; 9-10-94.

Technical Specification 3.11.2.1 FSAR Ssection 15 EPA 400-'R-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents Page 3 of 3 EAL - 6.1.4.d Rev. 00

Initiating Condition MODE EAL#

E M

E R

G E

N c

y A

c T

I 0

N L

E v

E L

s Action Required 6.0 Radiological Releases/Occurrences 6.3 In-Plant Radiation Occurrences SGS ECG-Rev. 00 ~

Page I of3 Unplanned Increase in Plant Radiation

(

All

)

6.3.1.a IF Unplanned rise in radiatior~ levels inside the Protected Area _2: 1000 times normal as indicated by EITHER one of the following:

Permanent or portable Area Radiation Monitors

General Area Radiological Survey Refer to Attachment 1 UNUSUAL EVENT Release of Radioactive Material or Increases in Radiation Levels Within the Facility that Impedes Operation of Systems Required to Maintain Safe 0 erations or to Establish or Maintain Cold Shutdown

(

All

)

6.3.2.a IF Unplanned Dose Rate

> 2000 mRem/hr in any area of the plant which requires ACCESS to maintain plant safety functions (excluding the Control Room or CAS) as indicated by EITHER one of the following:

Permanent or portable Area Radiation Monitors

General Area Radiation Survey THEN

(

All

)

6.3.2.b IF Unplanned radiation levels

> 15 mRem/hr in EITHER one of the following:

The Control Room

The Security Central Alarm Station (CAS)

Refer to Attachment 2 ALERT

SGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.3 In-Plant Radiation Occurrences ALERT - 6.3.2.a IC Release of Radioactive Material or increases in Radiation Levels within the facility that impedes operation of systems required to maintain safe operations or to establish or maintain cold shutdown EAL Unplanned Dose Rate > 2000 mRem/hr in any area of the plant which requires access to maintain plant safety functions (excluding the Control Room or CAS) as indicated by EITHER one of the following:

Permanent or portable Area Radiation Monitors General Area Radiological Survey MODE-All BASIS The term "unplanned" is defined as those events which are not associated with pre-planned evolutions such that radiation levels are increasing for reasons which cannot be immediately explained. The EAL addresses radiation levels which would impede operation of systems required to maintain safe operations or to establish or maintain Cold Shutdown. Radiation levels could be indicated by ARM or radiological survey.

It is the impaired ability to operate the plant that results in the actual or potential substantial degradation of the level of safety of the plant. The 2000 mRem/hr is not intended to be above the pre-existing background, but includes the pre-existing background. The Dose Rate of 2000 mRem/hr was chosen as a threshold based upon NAP-24 Administrative Dose Limits and Extension criteria which has Senior Radiation Protection Supervisor approval required prior to exceeding 2000 mRem/yr.

Barrier Analysis NIA Page 1 of 2 EAL - 6.3.2.a Rev. 00

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

DISCUSSION Emergency Coordinator judgement must be used to determine areas that contain systems that must be operated manually, or require local surveillances to assure reliable support of safe plant operation for the conditions that exist. Areas having equipment that must be operated locally during an accident and areas along associated access routes require HP coverage and continuous update of changing radiological conditions.

Areas of the plant which require access following an accident to maintain plant safety functions include but are not limited to:

Areas for Remote Shutdown CCW Pump Room CCWHxRoom 4kv Switchgear Room Diesel Generator Compartment Diesel Generator Control Room Diesel Oil Supply Tank Compartment Electrical Relay and Switchgear Room DEVIATION None REFERENCES Core Residual Heat Removal system areas Corridor next to the Spent Fuel Pit Hx Room Electrical Control Center Boric Acid Evaporator Room Unit 1 Boric Acid Evaporator Room Unit 2 Aux Feedwater Pump & Valve Area Radwaste Control Center 100 ft Chiller Area NUMARC NESP-007, AA3.2 NC.NA-AP.ZZ-0024(Q)- Radiation Protection Program S-C-VAR-MDC-1518 Rev 0, Draft Page 2 of 2 EAL - 6.3.2.a Rev. 00

Initiating Condition OPCON EAL#

E M

E R

G E

N c

y A

c T

I 0

N L

E v

E L

s Action Required 6.0 Radiological Releases/Occurrences HCGSECG Rev. 00 -

Page I of3 Unplanned Increase in Plant Radiation c All

)

6.3.1.a IF Unplanned increase in radiation levels inside the Protected Area

~ 1000 times normal as indicated by EITHER one of the following:

Permanent or portable Area Radiation Monitors

General Area Radiological Survey Refer to Attachment 1 UNUSUAL EVENT 6.3 In-Plant Radiation Occurrences Release of Radioactive Material or increases in Radiation Levels within the facility that impedes operation of systems required to maintain safe operations or to establish or maintain Cold Shutdown c All

)

6.3.2.a IF Unplanned Dose Rates

~ 2000 mRem/hr in ANY area of the plant which requires ACCESS to maintain plant safety functions (EXCLUDING the Main Control Room and CAS) as indicated by EITHER one of the following:

Permanent or portable Area Radiation Monitors

General Area Radiation Survey

(

All

)

6.3.2.b IF Unplanned Dose Rates

~ 15 mRem/hr in EITHER one of the following:

Main Control Room

Security Central Alarm Station (CAS)

THEN Refer to Attachment 2 ALERT

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.3 In-Plant Radiation Occurrences ALERT - 6.3.2.a IC Release of Radioactive Material or increases in Radiation Levels within the facility that impedes operation of systems required to maintain safe operations or to establish or maintain Cold Shutdown EAL Unplanned Dose Rates L 2000 mRem/hr in ANY area of the plant which requires ACCESS to maintain plant safety functions (EXCLUDING the Main Control Room and CAS) as indicated by EITHER one of the following:

Permanent or portable Area Radiation Monitors General Area Radiological Survey OPERATIONAL CONDITION - All BASIS An Unplanned Dose Rate of 2000 mRem/hr or greater in ANY area of the plant which requires ACCESS to maintain plant safety functions, warrants declaration of an Alert, due to the impaired ability to operate the required plant equipment. The 2000 mRem/hr is not intended to be above the pre-existing background, but includes the pre-existing background.

Unplanned is defined as those events or conditions which are not associated with a planned evolution, such that radiation levels are increasing in an uncontrolled manner. The Dose Rate threshold of 2000 mRem/hr was chosen based upon NC.NA-AP.ZZ-0024, Radiation Protection Program Administrative Dose Limits and Extension criteria which requires Senior Radiation Protection Supervisor approval prior to exceeding 2000 mRem/yr TEDE. Radiation levels could be indicated by either ARM or radiological survey.

Barrier Analysis NIA Page 1 of 2 EAL - 6.3.2.a Rev. 00

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

DISCUSSION Emergency Coordinator judgment must be used, based on existing plant co_nditions, to determine areas that contain systems that are required to be operated manually, or require local surveillances to assure reliable support of safe plant operation for the conditions that exist.

Areas having equipment that must be operated locally during an accident and areas along associated access routes that require HP coverage and continuous update of changing radiological conditions satisfy the definition of this condition.

Areas of the Plant which require access following an accident to maintain plant safety functions include, but are not limited to:

Reactor Core Isolation Cooling (RCIC) system areas Standby Liquid Control (SLC) system areas Residual Heat Removal (RHR) system areas Emergency Diesel Generators (EDGs) and adjacent Areas Service Water System (SWS) areas Station Auxiliary Cooling (SACS) system areas Areas covered in the HC.OP-EO.ZZ-300's (300 series EOPs)

DEVIATION None REFERENCES NUMARC NESP-007, AA3.2 NC.NA-AP.ZZ-0024(Q), Radiation Protection Program Page 2 of 2 EAL - 6.3.2.a Rev. 00

Initiating Condition MODE EAL#

E M

E R

G E

N c

y A

c T

I 0

N L

E v

E L

s Action Required 9.0 Hazards - Internal/External 9.9 River Level Natural and Destructive Phenomena Affecting the Protected Area

(

All

)

9.9.1.a IF River Level > 99.5'

(

All

)

9.9.1.b IF River Level < 76.0' THEN Refer to Attachment 24 UNUSUAL EVENT (Common Site)

SGS ECG -

Rev. 00 -

Page I of I

SGS EAL/RALTechnical Basis 9.0 Hazards - Internal/External 9.9 River Level UNUSUAL EVENT - 9.9.1.a IC Natural and Destructive Phenomena Affecting the Plant Vital Area EAL River Level >99.5' MODE-All BASIS This EAL indicates river level conditions that can threaten the level of safety of the plant due to flooding.

Barrier Analysis NIA ESCALATION CRITERIA This event will be escalated based on damage to plant safety systems, loss of fission product barriers, or abnormal radiological releases in other EAL sections.

DISCUSSION River level greater than 99.5' is indication of impending site flood conditions. Flood protection measures are required by Salem Technical Specifications and procedure at 99.5'(10.5MSL). At this river level precautionary actions are taken, including; filling outside tanks, and ensuring that perimeter flood doors are closed. These actions ensure that the facility flood protection features are in place prior to a river level which would necessitate their use. Hope Creek performs these actions at 95.0' (6.0MSL).

The High river level threshold is below the river level that would require a plant shutdown.

Technical Specification actions required by a river Level of > 100.5' includes placing the plant in at least Hot Standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in Cold Shutdown within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . This is based on the river level at which facility flood protection features provide protection to safety related equipment. Hope Creek Required actions are at 99.5' (10.5MSL).

Page 1 of 2 EAL - 9.9.1.a Rev. 00

SGS EAL/RALTechnical Basis The grade level at the Salem station is lower than that for Hope Creek (Salem = 99.5', Hope Creek = 101.5').

The National Weather Service can be contacted for further information about existing or projected Adverse Weather Conditions:

Mount Holly Mount Holly (609) 261-6604

( 609) 261-6602 DEVIATION None REFERENCES NUMARC NESP-007, HUl.7 OP-AB.CW-OOOl(Q)

OP-AB.ZZ-0001 (Q)

SGS UFSAR, Section 2.4.11.2, Figure 3.4-1 HCGS UFSAR, Section 2.4, Figure 2.4-3 Page 2 of 2 EAL - 9.9.1.a Rev. 00

SGS EAL/RALTechnical Basis 9.0 Hazards - Internal/External 9.9 River Level UNUSUAL EVENT - 9.9.1.b IC Natural and Destructive Phenomena Affecting the Plant Vital Area EAL River Level < 76.0' MODE-All BASIS This EAL indicates river level conditions that can threaten the level of safety of the plant due to loss of Service Water Intake (Ultimate Heat Sink). The Service Water pumps are designed to operate to a low river level of 76.0'.

Barrier Analysis NIA ESCALATION CRITERIA This event will be escalated based on damage to plant safety systems, loss of fission product barriers, or abnormal radiological releases in other EAL sections.

DISCUSSION River level less than 76.0' is indication of impending loss of the Ultimate Heat Sink, the Service Water System. The Service Water pumps can operate to a low river water level of 76.0'. The historical low river level for the Delaware river is 81.0'. Hope Creek Technical Specifications for low river level is 76'.

The National Weather Service can be contacted for further information about existing or projected Adverse Weather Conditions:

Mount Holly Mount Holly (609) 261-6604 (609) 261-6602 Page 1 of 2 EAL - 9.9.1.b Rev. 00

DEVIATION None REFERENCES NUMARC NESP-007, HUl.7 OP-AB.CW-OOOl(Q)

OP-AB.ZZ-0001 (Q)

SGS UFSAR, Section 2.4.11.2, Figure 3.4-1 HCGS UFSAR, Section 2.4, Figure 2.4-3 Page 2 of 2 SGS EAL/RALTechnical Basis EAL - 9.9.1.b Rev. 00

Initiating Condition MODE EAL#

E M

E R

G E

N c

y A

c T

I 0

N L

E v

E L

s Action Required 9.0 Hazards - Internal/External 9.8 Turbine Failure I Vehicle Crash I Missile Impact SGS ECG Rev. 00 Page I of I Natural and Destructive Phenomena Affecting Certain Structures Within the Protected Area c All

)

9.8.1.a IF Catastrophic damage to the Main Turbine as evidenced by EITHER one of the following:

Main Turbine casing penetration

Main Turbine/Generator Damage potentially releasing Lube Oil or Hydrogen Gas to the Turbine Building

(

All

)

9.8.1.b IF Vehicle Crash I Missile Impact with or within ANY one of the following Plant Vital Structures:

Auxiliary Building

Service Water Intake Structure

Inner/Outer Penetration Areas

Containment

Fuel Handling Building

Service Building

RWST, PWST, and AFWST Area

(

All

)

9.8.2 IF The Vehicle Crash I Missile Impact is of a magnitude that it SPECIFICALLY results in Damage to ANY one of the following:

AND

TWO OR MORE Trains of a Safety System

>---~~~~~~~

THEN Refer to Attachment 1 UNUSUAL EVENT

MORE THAN ONE Safety System

Any of the above Plant Vital Structures which renders the structure incapable of performing its Design Function

]AND Damaged Safety System(s) or Plant Vital Structure is required for the present MODE of operation

~THEN Refer to Attachment 2 ALERT

SGS EAL/RALTechnical Basis 9.0 Hazards - Internal/External 9.8 Turbine Failure I Vehicle Crash I Missile Impact UNUSUAL EVENT - 9.8.1.a IC Natural and Destructive Phenomena Affecting Certain Structures Within the Protected Area EAL Catastrophic damage to the Main Turbine as evidenced by EITHER one of the following:

Main Turbine casing penetration Main Turbine/Generator Damage potentially releasing Lube Oil or Hydrogen Gas to the Turbine Building MODE-All BASIS Turbine failure of sufficient magnitude to cause damage to the turbine casing or generator seals increases the potential for leakage of combustible/explosive gases and of combustible liquids to the Turbine Building or damage to plant systems due to missiles. The presence of Hz gas in sufficient quantities may present a flammable/explosive hazard. Oil may also be present which may contribute to the flammability hazard.

Barrier Analysis NIA ESCALATION CRITERIA This event will be escalated to an Alert based upon damage done by missiles generated by the failure.

DISCUSSION Turbine rotating component failures may also result in other direct damage to plant systems*

and components. Damage may rupture the turbine lubricating oil system, which would release flammable liquids to the Turbine Building. Potential rupture of the condenser and condenser tubes may cause flooding in the lower levels of the Turbine Building. This damage should be readily observable.

Page 1 of 2 EAL - 9.8.1.a Rev. 00

SGS EAL/RAL Technical Basis Escape of hydrogen gas from the generator due to a loss of seal oil pumps or turbine lube oil without a turbine rotating component failure should not be classified under this event.

DEVIATION None REFERENCES NUMARC NESP-007, HUl.6 EOP-TRIP-1 Page 2 of 2 EAL - 9.8.1.a Rev. 00

Initiating Condition OPCON EAL#

E M

E R

G E

N c y

A c

T I

0 N

L E

v E

L s

Action Required 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release HCGSECG-Rev. 00 -

Page I of4 Any Un1>lanned Release of Gaseous Radioactivity to Environment that Exceeds 2 Times the Radiological Technical Specifications for 60 minutes or longer Any Unplanned Release of Gaseous Radioactivity to the Environment that Exceeds 2 times the 10CFR20, Appendix B limits for 60 minutes or longer

(

All )

6.1.1.a

Dose IF Assessment Dose Assessment indicates EITHER one of the following at the MEA or beyond as calculated on the SSCL:

TEDE 4-Day Dose

~ 2.0E-01 mRem

Thyroid-CDE Dose

~ 6.SE-01 mRem based on Plant Vent effluent sample analysis and NOT on a default Noble Gas to Iodine Ratio Field

(

All

)

6.1.1.b Measured IF Dose Rate Dose Rate measured at the Protected Area Boundary or beyond EXCEEDS

.05 mRem/hr above normal background Sample Analvsis

(

All

)

6.1.1.c IF Gaseous effiuent release sample analysis for ANY one of the following indicates a concentration of:

FRVS:

~ 1.13E-03 µCi/cc Total Noble Gas

~ 2.71E-07µCi/cc1-131

NPV:

~ 2.43E-04 µCi/cc Total Noble Gas

~ 5.81E-08 µCi/cc 1-131

SPV:

~ 2.27E-05 µCi/cc Total Noble Gas

~ 5.44E-09 µCi/cc 1-131 I

Alarm Indications

(

All

)

6.1.1.d IF Valid High Alarm received from ANY one of the following Plant Effiuent RMS Channels:

FRVS Noble Gas (Grid 1/3; 9RX680)

NPV Noble Gas (Grid 1/3; 9RX590)

NPV Iodine (Grid 3; 9RX601)

SPV Noble Gas (Grid 1/3; 9RX580)

SPV Iodine (Grid 3; 9RX605)

HTV Noble Gas (Grid 3; 9RX516)

I AND Total Plant Vent release rate EXCEEDS EITHER one of the following limits:

4.80E-+-03 µCi/sec Total Noble Gas

LlSE-+-00 µCi/sec l-13l(NPV & SPY ONLY)

I I AND I Dose Assessment results NQI available I I

I AND I Release is ongoing for,2:: 60 minutes I

~THEN Refer to Attachment I UNUSUAL EVENT

Initiating Condition OPCON EAL#

E M

E R

G E

N c

y A

c T

I 0

N L

E v

E L

s Action Required 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release HCGS Eco-.

Any Un1>lanned Release of Gaseous Radioactivity to Environment that Exceeds 200 Times the Radiological Technical Specifications for 15 minutes or longer

(

All )

6.1.2.a Dose IF Assessment Dose Assessment indicates EITHER one of the following at the l'vIBA or beyond as calculated on the SSCL:

TEDE 4-Day Dose

~ 2.0E-+-01 mRem

Thyroid-COE Dose

_:::: 6.SE-+-01 mRem based on Plant Vent effiuent sample analysis and NOTon a default Noble Gas to Iodine Ratio

(

All

)

6.1.2.b Field Measured IF Dose Rate Dose Rate measured at the Protected Area Boundary or beyond EXCEEDS 5 mRem/hr Rev.00 -

Page 2 of4 Any Unplanned Release of Gaseous Radioactivity to the Environment that Exceeds 200 times the IOCFR20, Appendix B limits for 30 minutes or longer

(

All )

6.1.2.c Sample IF Analvsis Gaseous effiuent release sample analysis for ANY one of the following indicates a concentration of:

FRVS:

_:::: 1.13E-01 µCi/cc Total Noble Gas

_:::: 2.71E-05µCi/cc1-131

NPV:

_:::: 2.43E-02 µCi/cc Total Noble Gas

_:::: 5.81E-06 µCi/cc 1-131

SPV:

_:::: 2.27E-03 µCi/cc Total Noble Gas

_:::: 5.44E-07 µCi/cc 1-131 I

(

All )

6.1.2.d Alarm IF Indications Valid High Alarm received from ANY one of the following Plant Effiuent RMS Channels:

FRVS Noble Gas (Grid 1/3; 9RX680)

NPV Noble Gas (Grid 1/3; 9RX590)

NPV Iodine (Grid 3; 9RX601)

SPV Noble Gas (Grid 1/3; 9RX580)

SPV Iodine (Grid 3; 9RX605)

HTV Noble Gas (Grid 3; 9RX516)

I AND Total Plant Vent release rate EXCEEDS EITHERone of the following limits:

4.SOE-+-05 µCi/sec Total Noble Gas

1.15E-+-02 µCi/sec I-131 (NPV & SPV ONLY)

I I AND I

AND r

Dose Assessment results NQI available.

I I AND I

Release is ongoing for~ 15 minutes I

I Release is ongoing for~ 30 minutes I

ILT.:...:.H_E_N:__ _________,--______

__,I THEN i

Refer to Attachment 2 ALERT

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release UNUSUAL EVENT - 6.1.1.d IC Any Unplanned Release of Gaseous Radioactivity to the Environment that Exceeds 2 times the 10CFR20, Appendix B limits for 60 minutes or longer EAL Valid High Alarm received from ANY one of the following Plant Effluent RMS Channels:

FRVS Noble Gas (Grid 1/3; 9RX680)

NPV Noble Gas (Grid 113; 9RX590)

NPV Iodine (Grid 3; 9RX601)

SPV Noble Gas (Grid 1/3; 9RX580)

SPV Iodine (Grid 3; 9RX605)

HTV Noble Gas (Grid 3; 9RX516)

AND Total Plant Vent release rate EXCEEDS EITHER one of the following limits:

4.80E+03 1tCi/sec Total Noble Gas 1.15E+OO 1tCi/sec 1-131 (NPV & SPV ONLY)

Dose Assessment results NOT available Release is ongoing for L.. 60 minutes OPERATIONAL CONDITION - All BASIS Valid High alarm and effluent release rate values exceeding the EAL threshold, can result from a Gaseous Radiological Release in excess of 2 times 10CFR20, Appendix B limits. This condition results from an uncontrolled release of radioactivity to the environment, resulting in Page 1 of 4 EAL - 6.1.1.d Rev. 00

HCGS EAL/RALTechnical Basis elevated offsite dose rates. The threshold for this EAL is NOT based on a specific offsite dose rate, but rather on the loss of plant control implied by a radiological release of this magnitude that was not isolated within 60 minutes. The final integrated dose is very low and is not the primary concern. Valid is defined as the High alarm actuating specifically due to a Gaseous Release exceeding 10 CFR 20, Appendix B limits, thus precluding unwarranted event declaration as the result of spurious actuation. Classification is based on an ongoing release that does not comply with a license condition. Unplanned is defined as any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions on the applicable permit.

The EAL value for Total Plant Vent release rate was determined using default X/Q values from the ODCM which provides a less accurate method of evaluation release magnitude than using dose assessment with real time meteorological data. For that reason, this EAL should not be utilized if Dose Assessment is available. Dose Assessment will take in account actual meteorological conditions, plant vent flows and plant vent effluent concentrations to provide a more accurate assessment of a radiological release. If Dose Assessment is available then refer to EAL 6.1.1.a for classification.

It is not intended that the release be averaged over 60 minutes, but exceed 2 times 10 CFR20, Appendix B limits for 60 minutes or longer. In addition, it is intended that the event be declared as soon as it is determined that the release will exceed 2 times the limit for 60 minutes or longer.

Barrier Analysis NIA ESCALATION CRITERIA Emergency Classification will be escalated to an Alert when the effluent release concentration increases to 200 times the 10CFR20, Appendix B limits.

DISCUSSION The release rate thresholds for this EAL are obtained by multiplying the Technical Specification release rates of 2.4E+03 µCi/sec and 5. 78E-01 µCi/sec, for Noble Gases and Iodine-131 respectively, times 2. Total Noble Gas release rate is the summation of all plant vent release rates.

This EAL includes Iodine Release Rates for the NPV and SPV, since these vents have an Iodine monitor. Determination of the Iodine Release Rate from the Iodine monitor is accomplished by multiplying the Iodine reading (in uCi/cc) by the applicable vent flow rate, and 472 (Conversation factor). Iodine Release rates for FRVS and the HTV are excluded since these vents do not include an Iodine detector. The SPDS Total Iodine Offsite Release Page 2 of 4 EAL - 6.1.1.d Rev. 00

HCGS EAL/RALTechnical Basis Rate does not provide useful information because this is based on a default value of 1000 times less than the Total Noble Gas Offsite Release Rate, which could be grossly inaccurate.

Release rates for FRVS and the HTV are not included since these vents do not have an Iodine detector. A gaseous effluent sample is needed to accurately quantify the Iodine Release rate.

The SPDS Total Iodine Offsite Release Rate should not be used, as this is based on a default value of 1000 times less than the Total Noble Gas Offsite Release Rate. The 10CFR20, Appendix B limits are based on ODCM calculations.

10CFR20, Appendix B Calculation for Noble Gas uCi/Second = (100 mRem I year)* (Allocation Factor)

( ODCM XI Q) * (ODCM DRCF)

WHERE:

uCi/Second = Total Noble Gas Release Rate from Salem (Unit 1 & Unit 2) or Hope Creek (all Vents; NPV, SPV, FRVS, and HTV) which would result in a TEDE Dose Rate of 50 mRem/year.

ODCM X/Q = Site Specific (Salem or Hope Creek) dispersion factor at the Site Boundary in sec/m3.

ODCM DRCF = Site Specific (Salem or Hope Creek) dose rate conversion factor in mRem/year/uCi/m3.

ODCM X/Q = 2.67E-06 sec/m3 ODCM DRCF = 7. 80E+03 mRem/yr/uCi/m3 Allocation Factor = 5. OOE-01 2.40E+03 uCi/Second =

(100 mRem I yr)* (5.00E - 01)

(2.67£- 06 sec/ m 3

) * (7.80£ + 03mRem I yr I µCi I m 3

)

2.40E+03 µCi/sec *2 = EAL value.

4.SOE+ 03 µCi/sec is the EAL value.

10CFR20, Appendix B Calculation for Thyroid Committed Dose

uCi/Second = 50 mRem/year * (Allocation Factor)

(ODCM X/Q) * (ODCM THY DRCF)

WHERE:

uCi/Second = Total Iodine 131 release rate from Salem (Unit 1 or 2) or Hope Creek (all Vents; NPV, SPV, FRVS and HTV).

ODCM X/Q = Site Specific (Salem or Hope Creek) dispersion factor at the Site Boundary in sec/m3.

Page 3 of 4 EAL - 6.1.1.d Rev. 00

HCGS EAL/RALTechnical Basis ODCM THY DRCF = is the most limiting potential pathway (inhalation, child, thyroid 1-131) dose rate conversion factor in mRem/year/uCi/m3.

ODCM X/Q = 2.67E-06 sec/m3 ODCM THY DRCF = 1.62E+07 mRem/yr/uCi/m3 Allocation Factor = 5.00E-01 5.78E-01 uCi/Second = (50 mRem/year) * ~.OOE-01)

(2.67E-06 sec/m )* (1.62E+07 mRem/yr/uCi/m3) 5.78E-01 µCi/sec* 2 = EAL value.

1.15E+OO µCi/sec is the EAL value.

DEVIATION The value for EAL 6.1.1.d is based on one meteorological case and one isotopic mixture found in the ODCM. A radiological release based on this specific release rate could produce a TEDE Dose which would require an Alert classification or.not meet the Unusual Event classification, depending on the meteorological conditions and the isotopic mixture. EAL 6.1.1.d would not be used unless EAL 6.1.1.a (Dose Assessment) can not be used to determine the classification, if any, due to the potential uncertainty of this "default" EAL.

Two times the 10CFR20, Appendix B limits for noble gas and Iodine 131 are being used for this EAL, due to concerns that the State of New Jersey have pertaining to this EAL and based on the above mentioned uncertainties.

REFERENCES NUMARC NESP-007, AUl.1, AUl.4 HC.OP-AB.ZZ-126(Q), Abnormal Releases of Gaseous Radioactivity HC.RP-AR.SP-OOOl(Q), Radiation Monitoring System Alarm Response Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3. 11. 2.1 Page 4 of 4 EAL - 6.1.1.d Rev. 00

HCGS EAL/RAL Technical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release ALERT - 6.1.2.d IC Any Unplanned Release of Gaseous Radioactivity to the Environment that exceeds 200 Times 10 CFR20, Appendix B Limits for 30 minutes or longer EAL Valid High Alarm received from ANY one of the following Effluent RMS Channels:

FRVS Noble Gas (Grid 1/3; 9RX680)

NPV Noble Gas (Grid 1/3; 9RX590)

NPV Iodine (Grid 3; 9RX601)

SPV Noble Gas (Grid 1/3; 9RX580)

SPV Iodine (Grid 3; 9RX605)

HTV Noble Gas (Grid 3; 9RX516)

AND Total Plant Vent release rate EXCEEDS EITHER one of the following limits:

4.80E+05 JLCi/sec Total Noble Gas 1.15E+02 JLCi/sec I-131 (NPV & SPV ONLY)

Dose Assessment results NOT available Release is ongoing for L 30 minutes OPERATIONAL CONDITION - All BASIS Valid High alarm and effluent release rate values exceeding the EAL threshold, can result from a Gaseous Radiological Release in excess of 200 times 10CFR20, Appendix B limits.

This condition results from an uncontrolled release of radioactivity to the environment, Page 1 of 4 EAL - 6.1.2.d Rev. 00

HCGS EAL/RALTechnical Basis resulting in elevated offsite dose rates. The threshold for this EAL is NOT based on a specific off site dose rate, but rather on the loss of plant control implied by a radiological release of this magnitude that was not isolated within 30 minutes. The final integrated dose is very low and is not the primary concern. Valid is defined as the High alarm actuating specifically due to a Gaseous Release exceeding Technical Specification limits, thus precluding unwarranted event declaration as the result of spurious actuation. Classification is based on an ongoing release that does not comply with a license condition. Unplanned is defined as any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions on the applicable permit.

The EAL value for Total Plant Vent release rate was determined using default X/Q values from the ODCM which provides a less accurate method of evaluation release magnitude then using dose assessment with real time meteorological data. For that reason, this EAL should not be utilized if Dose Assessment is available. Dose Assessment will take in account actual meteorological conditions, plant vent flows and plant vent effluent concentrations to provide a more accurate assessment of a radiological release. If _Dose Assessment is available than refer to EAL 6.1.2.a for classification.

The Total Plant Vent release rate can be obtained from SPDS or by adding up NPV, SPY, FRVS and HTV noble gas readings.

It is not intended that the release be averaged over 30 minutes, but exceed 200 times 10CFR20, Appendix B limits for 30 minutes or longer. In addition, it is intended that the event be declared as soon as it is determined that the release will exceed 200 times the limit for 30 minutes or longer.

Barrier Analysis NIA ESCALATION CRITERIA Emergency Classification will escalate to a Site Area Emergency when effluent release concentration increases to a level that would cause a 100 mRem dose at the Protected Area Boundary DISCUSSION The release rate thresholds for this EAL are obtained by multiplying the 10CFR20, Appendix B Limit release rates of 2.4E+03 µCi/sec and 5.78E-01 µCi/sec for Noble Gases and 1-131 respectively, times 200. Total Noble Gas release rate is the summation of all plant vent release rates.

This EAL includes an Iodine Release rate for NPV & SPY since these vents have Iodine monitors. Determination of the Iodine Release Rate from the Iodine monitor is accomplished EAL - 6.1.2.d Rev. 00 Page 2 of 4

HCGS EAL/RALTechnical Basis by multiplying the Iodine reading (in µCi/cc) by the applicable vent flow rate and 472 (conversion factor). Iodine Release Rates for FRVS and HTV are excluded since these vents do not include an Iodine detector. The SPDS Total Iodine offsite Release Rate does not provide useful information, since this based on a default valve of 1000 times less than the Total Noble Gas offsite Release Rate, which could be grossly inaccurate. A gaseous effluent sample is needed to accurately quantify the Iodine Release Rate.

10CFR20, Appendix B Limit Calculation for Noble Gas uCi/Second = 100 mRem/year * (Allocation Factor)

(ODCM X/Q) * (ODCM DRCF)

WHERE:

uCi/Second = Total Noble Gas Release Rate from Salem (Unit 1 & Unit 2) or Hope Creek (all Vents; NPV, SPV, FRVS, and HTV) which would result in a TEDE Dose Rate of 50 mRem/year.

ODCM X/Q = Site Specific (Salem or Hope Creek) dispersion factor at the Site Boundary in sec/m3.

ODCM DRCF = Site Specific (Salem or Hope Creek) dose rate conversion factor in mRem/year/uCi/m3.

ODCM X/Q = 2.67E-06 sec/m3 ODCM DRCF = 7.80E+03 mRem/yr/uCi/m3 Allocation Factor = 5.00E-01 2.40E+03 uCi/Second = (100 mRem/year) * (5.00E-01)

(2.67E-06 sec/m3) * (7.80E+03 mRem/yr/uCi/m3) 2.40E+03 µCi/sec

200 = EAL value.

4.80E+05 µCi/sec = EAL value 10CFR20, Appendix B Limit Calculation for Thyroid Committed Dose

µCi/Second = 50 mRem/year * (Allocation Factor)

(ODCM X/Q) * (ODCM THY DRCF)

WHERE:

µCi/Second = Total Iodine 131 release rate from Salem (Unit 1 or 2) or Hope Creek (all Vents; NPV, SPV, FRVS, and HTV).

ODCM X/Q = Site Specific (Salem or Hope Creek) dispersion factor at the Site Boundary in sec/m3

Page 3 of 4 EAL - 6.1.2.d Rev. 00

HCGS EAL/RALTechnical Basis ODCM THY DRCF = is the most limiting potential pathway (inhalation, child thyroid I-131) dose rate conversion factor in mRem/year/µCi/m3*

ODCM XIQ = 2.67E-06 sec/m3 ODCM THY DRCF = l.62E+07 mRem/yr/µCi/m 3 Allocation Factor = 5.00E-01

5. 78E-O 1 µCi/Second = (50 mRem/year) * (5. OOE-01)

(2.67E-06 sec/m3) * (l.62E+07 mRem/yr/µCi/m3) 5.78E-01 µCi/sec* 200 = EAL value.

1.15E+02 µCi/sec =EAL value.

DEVIATION The value for EAL 6.1.2.d is based on one meteorological case and one isotopic mixture found in the ODCM. A radiological release based on this specific release rate could produce a TEDE Dose which would require a General Emergency classification or not meet the Alert classification, depending on the meteorological conditions and the isotopic mixture. EAL 6.1.2.d would not be used unless EAL 6.1.2.a (Dose Assessment) can not be used to determine the classification, if any, due to the potential uncertainty of this "default" EAL.

Two hundred times the IOCFR20, Appendix B limits of noble gas and Iodine 131 are being used for this EAL, due to concerns that the State of New Jersey had pertaining to this EAL and based on the above mentioned uncertainties.

The time limit has been increased from 15 minutes to 30 minutes, to allow additional time to perform dose assessment, since the threshold for this EAL is only 20 % of the value allowed per NESP-007 and we do not wish to use this "default" EAL, unless absolutely necessary.

REFERENCES NUMARC NESP-007, AAl.1, AAl.4 OP-AB.ZZ-126(Q), Abnormal Releases 'of Gaseous Radioactivity Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3. 11. 2.1 Page 4 of 4 EAL - 6.1.2.d Rev. 00

Initiating Condition OPCON EAL#

E M

E R

G E

N c

y A

c T

I 0

N L

E v

E L

s Action Required 6.0 Radiologic eleases/Occurrences 6.1 Gaseous Effluent Release HCGSECG Rev. 00 -

Page 3 of 4 Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mrem Total Effective Dose Equivalent (TEDE) or 500 mRem Thyroid CDE Dose for the actual or projected duration of the release

(

All

)

6.1.3.a Dose IF Assessment Dose Assessment indicates EITHER one of the following at the MEA or beyond as calculated on the SSCL:

TEDE 4-Day Dose

.=:: 1.0E+-02 mRem

Thyroid-CDE Dose 2: 5.0E+-02 mRem based on Plant Vent effiuent sample analysis and NOT on a default Noble Gas to Iodine Ratio

(

All )

6.1.3.b Field Measured IF Dose R"'te Dose Rate measured at the Protected Area Boundary or beyond EXCEEDS 100 mRem/hr AND Release is expected to continue for 2: 15 minutes

(

All )

6.1.3.c Field Survey IF Analvsis Analysis of field survey samples at the Protected Area Boundary indicates EITHER one of the following:

2: 4.36E+-02 CCPM

.'.'.: 3.85E-07µCi/cc1-131 l THEN Refer to Attachment 3 SITE AREA EMERGENCY Alarm Indications

(

All

)

6.1.3.d IF Valid High Alarm received from ANY one of the following Plant Effiuent RMS Channels:

FRVS Noble Gas (Grid 1/3; 9RX680)

NPV Noble Gas (Grid 1/3; 9RX590)

SPV Noble Gas (Grid 1/3; 9RX580)

HTV Noble Gas (Grid 3; 9RX516)

I AND Total Plant Vent release rate EXCEEDS 7.6E+-07 µCi/sec Total Noble Gas I AND Dose Assessment results NOT available.

I AND J

Release is ongoing for~ 15 minutes J

I

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release SITE AREA EMERGENCY - 6.1.3.d IC Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mRem Total Effective Dose Equivalent (TEDE) or 500 mRem Thyroid CDE Dose for the actual or projected duration of the release EAL Valid High Alarm received from ANY of the following Effluent RMS Channels:

FRVS Noble Gas (Grid 1/3; 9RX680)

NPV Noble Gas (Grid 1/3; 9RX590)

SPV Noble Gas (Grid 1/3; 9RX580)

HTV Noble Gas (Grid 3; 9RX516)

Total Plant Vent release rate EXCEEDS 7.6E+07 µCi/sec Total Noble Gas Dose Assessment results NOT available Release is ongoing for L 15 minutes OPERATIONAL CONDITION - All BASIS Valid High alarm and effluent release rate values exceeding the EAL threshold, indicates a substantial Gaseous Radiological Release which could exceed the 10CFR20 average annual population exposure limit of 100 mRem TEDE, using the assumption of a one hour release duration.

The EAL value for Total Plant Vent release rate was determined using default X/Q values from the ODCM which provides a less accurate method of evaluation release magnitude then EAL - 6.1.3.d Rev. 00 Page 1 of 3

HCGS EAL/RALTechnical Basis using dose assessment with real time meteorological data. For that reason, this EAL should not be utilized if Dose Assessment is available. Dose Assessment will take in account actual meteorological conditions, plant vent flows and plant vent effluent concentrations to provide a more accurate assessment of a radiological release. If Dose Assessment is available then refer to EAL 6.1.3.a for classification.

The Total Plant Vent release rate can be obtained from SPDS or by adding up NPV, SPV, FRVS and HTV noble gas readings.

It is not intended that the release be averaged over 15 minutes, but that the Release Rate exceed the EAL value for > 15 minutes.

Barrier Analysis NIA ESCALATION CRITERIA Emergency Classification will escalate to a General Emergency when effluent release concentration increases to a level that would cause a 1000 mRem dose at the Protected Area Boundary.

DISCUSSION This EAL does not utilize an Iodine Release rate because the corresponding Site Area threshold for Iodine is above the upper range of the NPV and SPV Iodine monitoring channels. Iodine Release rates for FRVS and the HTV are excluded since these do not include an Iodine detector.

To obtain a site specific value to trigger the performance of dose assessment is not necessary, since this will be done when the UE value is reached. This value will supply a set point to classify a Site Area Emergency (SAE), if dose assessment has not been performed within 15 minutes.

A release rate of 7.6E+07 µCi/sec was backcalculated from a TEDE Dose of 100 mRem/hour at the Site MEA. The assumptions that went into this calculation were as follows:

Release Point: FRVS Release Rate: 9000cfm ODCM X/Q = 2.67E-06 sec/m3 Page 2 of 3 EAL - 6.1.3.d Rev. 00

HCGS EAL/RALTechnical Basis Isotopic mixture: FSAR isotopic mixture for a design basis LOCA Dose Rate Conversion Factors: EPA 400-R-92-001 (Manual of Protective Actions for Nuclear Incidents) Dose Rate Conversion Factors.

DEVIATION The NUMARC basis states that the FSAR source term assumptions should be used in determining the indications for monitors. The NUMARC Draft White Paper states the FSAR source term should not be used unmodified.

This NUMARC EAL is calculated using the FSAR Isotopic Mixture for a Design Basis LOCA and the Dose Rate Conversion Factors found in EPA 400-R-001. The combination of using the FSAR Isotopic mixture and the EPA 400 dose Rate Conversion Factors calculate an accurate accident source term.

REFERENCES NUMARC NESP-007, AS I. I, AS I.4 OP-AB.ZZ-I26(Q), Abnormal Releases of Gaseous Radioactivity Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3. I I. 2. I FSAR Section I5 EPA 400-R-OOI, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents Page 3 of 3 EAL - 6.1.3.d Rev. 00

Initiating Condition OPCON EAL#

E M

E R

G E

N c

y A

c T

I 0

N L

E v

E L

s Action Required 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release HCGSECG Rev.00 Page 4 of 4 Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 1000 mrem Total Effective Dose Equivalent (TEDE) or 5000 mRem Thyroid CDE Dose for the actual or projected duration of the release

(

All

)

6.1.4.a Dose IF Assess men Dose Assessment indicates EITHER one of the following at the MEA or beyond as calculated on the SSCL:

TEDE 4-Day Dose

~ 1.0E+-03 mRem

Thyroid-CDE Dose

~ 5.0E+-03 mRem based on Plant Vent effiuent Sample Analysis and NOT on a default Noble Gas to Iodine Ratio Field

(

All

)

6.1.4.b Measured IF Dose Rate Dose Rate measured at the Protected Area Boundary or beyond EXCEEDS 1000 mRem/hr AND Release is expected to continue for~ 15 minutes

(

All

)

6.1.4.c Field Survey IF Analvsis Analysis of field survey samples at the Protected Area Boundary indicates EITHER one of the following:

~4.36E+-03 CCPM

~ 3.85E-06 µ.Ci/cc 1-131 l

THEN Refer to Attachment 4 GENERAL EMERGENCY Alarm Indications

(

All

)

6.1.4.d IF Valid High Alarm received from ANY one of the following Plant Effluent RMS Channels:

FRVS Noble Gas (Grid 1/3; 9RX680)

NPV Noble Gas (Grid 1/3; 9RX590)

SPV Noble Gas (Grid 1/3; 9RX580)

HTV Noble Gas (Grid 3; 9RX516)

I AND Total Plant Vent release rate EXCEEDS 7.6E+-08 µCi/sec Total Noble Gas I AND Dose Assessment results NOT available.

I AND

\\ Release is ongoing for~ 15 minutes I

I

.. I HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release GENERAL EMERGENCY - 6.1.4.d IC Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 1000 mRem Total Effective Dose Equivalent (TEDE) or 5000 mRem Thyroid CDE Dose for the actual or projected duration of the release EAL Valid High Alarm received from ANY one of the following Plant Effluent RMS Channels:

FRVS Noble Gas (Grid 1/3; 9RX680)

NPV Noble Gas (Grid 1/3; 9RX590)

SPV Noble Gas (Grid 1/3; 9RX580)

HTV Noble Gas (Grid 3; 9RX516)

Total Plant Vent release rate EXCEEDS 7.6E+08 µCi/sec Total Noble Gas Dose Assessment results NOT available Release is ongoing for L 15 minutes OPERATIONAL CONDITION - All BASIS Valid High alarm and effluent release rate values exceeding the EAL threshold, indicates a substantial Gaseous Radiological Release which could exceed the EPA Protective Action Guide exposure of 1000 mRem TEDE, using the assumption of a one hour release duration.

The EAL value for Total Plant Vent release rate was determined using default X/Q values from the ODCM which provides a less accurate method of evaluation release magnitude then EAL - 6.1.4.d Rev. 00 Page 1 of 3

HCGS EAL/RALTechnical Basis using dose assessment with real time meteorological data. For that reason, this EAL should not be utilized if Dose Assessment is available. Dose Assessment will take into account actual meteorological conditions, plant vent flows and plant vent effluent concentrations to provide a more accurate assessment of a radiological release. If Dose Assessment is available then refer to EAL 6.1.4.a for classification.

The Total Plant Vent release rate can be obtained from SPDS or by adding up NPV, SPV, FRVS and HTV noble gas readings.

It is not intended that the release be averaged over 15 minutes, but that the Release Rate exceed the EAL value for > 15 minutes.

Barrier Analysis NIA ESCALATION CRITERIA None DISCUSSION This EAL does not utilize an Iodine Release rate because the corresponding General threshold for Iodine is above the upper range of the NPV and SPV Iodine monitoring channels. Iodine Release rates for FRVS and the HTV are excluded since these do not include an Iodine detector.

To obtain a site specific value to trigger the performance of dose assessment is not necessary, since this will be done when the UE value is reached. This value will supply a set point to classify a General Emergency (GE), if dose assessment has not been performed within 15 minutes.

A release rate of 7.6E+08 µCi/sec was backcalculated from a TEDE Dose of lOOOmRem/hour at the Site MBA. The assumptions that went into this calculation were as follows:

Release Point: FRVS Release Rate: 9000cfm ODCM X/Q = 2.67E-06 sec/m3 Isotopic mixture: FSAR isotopic mixture for a design basis LOCA Dose Rate Conversion Factors: EPA 400-R-92-001 (Manual of Protective Actions for Nuclear Incidents) Dose Rate Conversion Factors.

Page 2 of 3 EAL - 6.1.4.d Rev. 00

HCGS EAL/RALTechnical Basis DEVIATION The NUMARC basis states that the FSAR source term assumptions should be used in determining the indications for monitors. The NUMARC Draft White Paper states the FSAR source term should not be used unmodified.

This NUMARC EAL is calculated using the FSAR Isotopic Mixture for a Design Basis LOCA and the Dose Rate Conversion Factors found in EPA 400-R-001. The combination of using the FSAR Isotopic mixture and the EPA 400 dose Rate Conversion Factors calculate an accurate accident source term.

REFERENCES NUMARC NESP-007, AGl.l, AGl.4 OP-AB.ZZ-126(Q), Abnormal Releases of Gaseous Radioactivity Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3.11.2.1 FSAR Section 15 EPA 400-R-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents Page 3 of 3 EAL - 6.1.4.d Rev. 00

TABLE3.0

!FISSION PRODUCT 1

BARRIERS APPLICABLE OPERATIONAL CONDITIONS ARE 1,2,3 ONLY Non<

u the I.om or Potential u:;t;""

C01l.-l.d.ered IMMINENT (may occur within 2 houn), UM jndgm.e:nt nnd c1aoelfy BB If the threshold fa ezceeded.

Instructions:

1. In the table review the Emergency Action Levels of ell columns end Identify wblch need furiher review.

2. For each of the three barrlel'B, determine the EAL with the blghest point value, end circle the corresponding EAL # and point value.

No more the one EAL should be selected for each barrier.

3. Add the point values circled for the three barriers end enter the sum below:

4. Classify based on the point value sum as I follows:

a U t~-* T Classify as:

I &r..;..-;;,,--* 1*

!~

eumls: I

\\

--l~=l ~~~~ ~

l-Al!:-~b:~ ~ 1 i 3,4 ALEl.T

' AllachmenU i j t~~:ti:li;:~I

___ L ________ _J I

' II. Implement the appropriate ECG Attachment per above chart.

6. Continue to review the EALs on this Table for changes that could result In emergency eecalatlon or deeecalatlon.

I I i I a

ij

--*-------*---*-~"- -* -...... ------*-"-** --~

3.1 Fuel Clad Barrier POTENl'L\\L LOSS.. 3Pl'o EALlll.1.1.a Beador Waler Level B.EACBEB-16r (Top of

~Fusl)EXCUJDING lolenilouallowmngoflle.etor Water Level dnrlng o.n ATWS LOSS= 4Pl'a EAL Al.1.b Bemdor Will.er Level CANNOf BE REmmt!D AND MAINTAINID above* 200" (M1nlmum Zero lnJeeilon BPV Waler Level) al.2 DBYWEIL ATMOSPHERE POST ACCIDENT IDAPA)

RADIATION LEVEL POTENTIAL L088 c OP'.1'11 Not AppH.coh1e EAL*S.1.2 DAPA Radla1iou Monitor ren.dlng 2: 5000 R/hr S.1.8 BCB IODINE CONCENTRATION POTENTIAL LOSS "' O PI'a Not Applicable EALtS.1.3 Reactor Coolant. Sample Actlvtly z 300 uCL'gm Dose Equlvelenl.1-191 8.L.fi EMERGENCY COORDINATOR JUDGMENT POTENTIAL L088 "' 9 Pl'a EALt8.L4.a EALl8.1.4.b AMI" condlUon In lhe opinion of AHi condlllon ln the opinion I.be EC, lho.1. lndlcal.ell a Poleo.tlal of lbe EC, lb&i lndlcet.ea e lam Loe9 ol. lhe Fuel Clad Barrier of lhe Fuel Clad Barrier 3.2 RCS Barrier 3.11 REACTOB WATER lEVEL POrENl'IAL L088. 3Ph EALIS.2.1.a Beador Water Level BEACHES-129" El!lWllJllli lntenllonal lowering ol. Beador Water Level during an ATWB LOSS =.(pf*

EALt3.l!.1.b Be.et.or Waler Lovet REACHES-161" (Top of Active Fuel)~

lnlen1looal Jowerlng ol. Beacsor W*ter Level during an A1W8

~RCS LEAK BATEIDBYWELLPBE88UD.E PO'IENT1AL L088 "' 8PTa LOSS= 4PT*

EAL t 3.2.2.a Unleolable RCS Leolr. Bato

,,. GO GPM INSIDE Primary CoDlalnmeol EAL t 3.2.2.b Valid Wgh DryweU preanu.re Coo.dltlon ( ~ 1.68 paig) 9.2.S RCS LINE BREAJt{::ONTAINMENT BYPASS POrENl'IAL LOSS 1:1 3Pl'a LOSS e4.PI'*

EAL* 3.2.S.a Main Steam Une Break OUTSIDE Primary Contalnmem.

r-altlng ln an AUI'OMATIC MSIV lsolaUon SJgnel Mm

.&!14 Malo Steam Lines hove been suCCllll!lully laolaled ooof AFn'..R valve closure from lho Malo Control Boom baa been eUempted EAL ti SJ!.3.b RCS Lino Break Q!!lfil!lll Prlmary Contalnm.enL, resultlnglna Valldlaolatlon Signal for ANY one of the following ayistems::

NBSSS

HPCI

RCIC Indication of~

ll,QW 11 fjAKAGE

.!ll!llilDE. THE PRIMARY Containment through the effected system &:rfil!

valve closure from lhe Malo Control Room hes been alt.empted 8.2.4 EMERGENCY COORDINATOR JUDGMENT POTENTIAL LOSS.. 8PTa EAL

3.2.4.a

.AHi" condlUon lo the opinion of I.be EC, lbal. lndlcetee a Po&aollal LoM ~the RCS BarrLr EALl3.2.4.b AI!X condition. In the opinion of lbe EC, thal. lndlcale8 a Lou of I.be RCS Barrler ffl<

~r

.l.lO 3.3 CNTMT Barrier, KAI.13.8.1.

Be.ctor Water Left!]

CANN or BE llE8I'OBED AND MAIITTAINED above -200" OOnlmum Zero Injection BPV Waler levol) 3.S.2 DRYWELL PRESSURE I 8 1 PO'l'ENTIAL LOBS* 1 PI' LOSS :OPfa Not Applicahle LOSS:2PT11 1 EAL'S.9.2.a EALIS.3.2.b Supp Chamber P"8l'8 CANN<YJ' Coatalmqcot Faillln:l.. indioaied BEMAINI'AINEDbclow

=d!':'.!~~

1-..

_.;;"--*11, ____..,_,_... _.. _.. _

EAL1SJl.2.e Prlmnry Contalnmen&

H,conoentratton. > 4.% and 0 1 concentrutlon > 6%

EALIS.3.2.d

~p--=e n-p....ot

-un.-1 wlill LOCA-dlilca.

EALfSJl.2.e Con1ab:un~t la Vwted by tho Em.~

OpqoatlJla~

(EOP9) 3.S.S DBYWELL ATMOSPllEBE PO!fi' ACCIDENT CDAPAJ RADIATION LEVEL PCfI'ENTIAL 1.0SS. 1 Pr EAL I 3.3.S Not AppllcAlJle DAPA BadlnUon Monitor readlng 2: 28000 RJhr S.S.4. RCS LINE BREAHJCONl'AINMENT BYPASS P01'ENI'IAL LOBS.. 1 Pl' LOSS= 2 PJ's EALtS.S.-Lo RCS Line Break !1lllllllll;;

Prlmmy Conlabuaeut, 1'e6111.Uo,g In a Valid holattou.

BllPJa] for AJ:ri one of the ro-.,..,...,...,

NSSSS c... 1adlnCMa1u BleamU....)

HPCI

RCIC HQ lndlcaUon of CONl'INUING FLOW I l.RAKWE OUl'8IPE the Primary Coniaimaent.

tbri::in"'1 the elfect.ed. system tY:IEB valve closure from the Main Control room bu been *it.empted EALtS.S.4-b holotlon SlgnnJ for ANY mi.e ol lbe follow!Dg eya&emat

NSSSS

PCIS

BPCI

BCIC Indication of

~

FLOW /LEAKAGE

~l.bePrlm.ary Conl.nlnmant through lbe effected syslem.u:rt;R valve closure from Main Control Room baa been at.tempted 9..8.G EMERGENCY COORDINATOR JUDGMENT POrENTIAL LOSS. 1Pf EAL*8.8.4.a M:!X condlUon In lho opinion ol. lho EC. lhlll lndlcat.es a Pot.enllal Locm ~the Conl.nlnmenl Battler

. - 'l EALf s.ruLb

~

coodlUou In lho oplnloo of lbe EC, lb.al. lndlcalee e Lomi ot the Containment Barrier HCCJ:IEOO RtwOO

TABLE3.0 ISSION PRODUCT BARRIERS APPLICABLE OPERATIONAL CONDITIONS ARE 1,2,3 ONLY

~

11 the Lo. or Potential 1-is CODSidered IMMINENT (may occur within 2 boon), 111111e judp.ent and classify as if the tbrmhold is euieed.ed.

Instructions:

1. In the table review the Emergency Action Levels of all columns and identify which need fmther review.

For each of the three barriers, determine the EAL with the highest point value, and circle the corresponding EAL# and point value.

No more the one EAL should be selected for each barrier.

3. Add the point values circled for the three barriers and enter the sum below:

4. Classify based on the point value sum as follows:

Hthe Classify as:

Refer to:

sum ls:

1,2 UNUSUAL EVENT 3,4 ALERT 5,8,7,8 SITE AREA EMERGENCY 9,10 GENERAL EMERGENCY

5. Implement the appropriate ECG Attachment per above chart.

Continue to review the EALs on this Table for changes that could result in emergency escalation or deescalation.

S.Ll REACTOR WA'l'EB LEVEL EAL.S.1.1.a 8-dor Water Level REACHES -161" (Top of Active Fuel) EXCLUDING lnteotional lowering ol Reactor Water Level during an ATWS LOSS= 4PTs EAL *3..1.1.b Reactor Water Level C,\\NNQJ' BE BEIIDlRIID AND MAINTAINED above - 200" (Mlnlmnm Zero IDJectlon RPV Water Level)

S.L2 DRYWELL ATMOSPHERE POST ACCIDENT ())APA)

RADIATION LEVEL PO'nlNTIAL LOSS= OPIW LOSS :4Pfs Not Applicable EAL

3.1.2 DAPA Radiation Monitor reading oo 5000 R/hr S.L3 RCS IODINE CONCENTRATION POTENTIALLOSS: OPI'a Not Applicable LOSS:4Pfs EAL*S.1.3 Reactor Coolant Sample Actlvlty :. 300 uCl/gm Dose Equivalent 1-lSl 3.L4 EMERGENCY COORDINATOR JUDGMENT POTENTIAL LOSS = S PIW LOSS:4PTs EALIS.L4.a EAL I 8.1..4.b

.4il!IJ: condltlon In the oplnlon of ~

condltlon In the opinion the EC, that lndlcatea a P-ttal ol the EC, that lndlca&ea a Lo.

Lo. cl. the Fuel Clad Barrier ol the Fuel Clad Barrier 3.2.1 REACl'OR WATER UVEL EAL *3.2.1.a Reactor Water Level REACHES -129" EJCI.lJDING lntenilooal lowering cl. Reactor Water Level during an ATWS LOSS= 4PTs EAL *3.2.1.b Reactor Water Level REACHES -161" (Top of Active Fuel) EJCLUDING lnienilonal lowering cl. Reactor Water Level during an ATWS 8.2.2 RCS LEAK RATE/DRYWELL PRESSURE EAL

3..2.2.a Unisolable RCS Leak Rate

. l!O GPM INSIDE Primary Conialnmeni LOSS :4PTs EAL

3.2.2.b Valid ffigh Drywell p.-ue Condltlon ( oo 1.68 psig )

3.2-3 RCS LINE BREAKJCONTAINMENT BYPASS POl'ENTIAL LOSS " SPI'a EAL

3.2.3.a Main Steam Line Break OUTSIDE Primary Conialnmeni, re9Ult.lng In an AUTOMATIC MSIV holatlon Slgnal Atlll All 4 Main Steam Linea have been auCCe811fully laolated ba-1 on NO lndlcatlon ol CONTINliiNG FLOW I LEAKAGE OUTSIDE the Primary Conialnment AFTER valve closure from the Main Conirol Room baa been attempted LOSS:4Pfs EAL

3.2.S.b RCS Line Break OUfSIDE Primary Containment, rMUlt.lng ln a Valid lllolatlon Slgnal for ANY one cl. the following aywtema:

NSSSS

HPCI

RCIC lndlcatlon ol CONTINUING n.ow / LEAKAGE OUTSIDE THE PRIMARY Containment through the effected system~

valve closure from the Main Conirol ROCMll baa been attempted 8.2..4 EMERGENCY COORDINATOR JUDGMENT POTENTIAL LOSS= 8PTa EAL

3.2.4-a

,AJ:ll' condltlon In the opinion of the EC, that lndlca&ea a Potential Lo. al. the RCS Barria-LOSS: 4PTs EAL

3.2.4-b Af!!.X coodltlon, In the oplnlon ol the EC, that lndlca&ea al..-

ol the RCS Barrier 3.U REACTOR WATER LEVEL PQl'ENTIAL LOSS... lP1'.

EAL..Ul.

Reactor Water Lewd CANNOTBEBFBl'OBED AND MAINI'AINED above -200" (Minimum Zero Injeetlon RPV Water level) s.3.2 DRYWELL PRESSURE I H,

.POTENTIAL LOSS., l Pr EALl3.IU.c Primary Containment H, coneentradon ;> 4%. and O,coneentrailon > 11%.

LOSS= OPTs Not Applicable LOSS= 2 PTs EALl&.Ud: :

. Drywell~a..-- **ot

-.w-twlili LOCA~

.... -------o*---------t EAL I 8.8.2.e 3.3.S DRYWELL ATMOSPHERE POST ACCIDENT <DAPA>

RADIATION LEVEL P<Yl'ENTIAL LOSS : l Pr EAL* 3.S.S Not Applicable

DAPA Radiation MonltOr.

reading 00 28000 R/hr 3.8-4.. RCSLINE BRE:AKJCONl'AINMENT BYPASS P01ENrIAL LOSS= 1 Pr*

LOSS= 0 PTs LOSS =2 PTs EAL I U4.a EAL* S.S.4.b RCS Llne Break OUTSIDE

laolatlon Signal for ANY PriJllary Con*-1maent,.

one cl. the* followlng sya-

..--Itlng ID a Valid J.olailon.

Sipal for 4HJ.' one of the

.followine syidelali:

.

NSSSS (exclndlngMabl Steam LinM)

HPCI

.*RCIC

NSSSS

PCIS

HPCI

RCIC

?m IDdiCationof

lndlcatlon cl.

CONl'INUING

. CoNTnroING FWW FJ.EAKAGE.OUTSIDE. FLOW /LEAKAGE the Prilaary Containment.

OUTSIDE thePrimuy tbJ'oaP. the effected system : Containment 1hrough the

At'l'.EB valve closure &om effected system 4rlD

the Mabl Control roo111: i..

valve clOSlll'efrom Main bee.,_ at&em>>4ed

Control Room.baa been

.. at&em~

8.3.6 EMERGENCY ct>oRDINATOR JUDGMENT P<Jl'ENTIAL LOSS " lP1' LOSS= 2PTs EALt8.SJLa M!! 0<1ildhlon In.the. oplnfun:,.

o1tb8 ~:th~ :Indicates a:*:::*

Po&eoil~ tQ. d the Contahi:mem* Barrier*

EAL I.s.a.4.&

ANY condit!.~ ln. the opinion qt the EO; that lDdlcil&ea a *i-*. **

oUlieCoirtahain.ent~

HO<l! ECG Rev oo*

l oll

HCGS EAL/RALTechnical Basis 3.0 Fission Product Barriers 3.3 Containment Barrier 3.3.2.b/d/e IC Loss of Containment EAL Containment Failure as indicated by a rapid drop in Drywell pressure following an rise in pressure above 1.68 psig Drywell pressure response not consistent with LOCA conditions Containment is Vented by the Emergency Operating Procedures (EOPs)

OPERATIONAL CONDITION - 1, 2, 3 BASIS Containment failure indicated by a rapid decrease in Drywell pressure following a significant increase in Drywell pressure is indicative of a Loss of the Containment barrier. This EAL specifically represents a Loss of Containment, whereby a unisolable breach of the containment structure has occurred. Conditions that result in a decrease in Drywell pressure following a pressure rise that are not the direct result of a Containment failure do not warrant classification under this EAL. These events include the initiation of Drywell Sprays, the re-establishment of Drywell Cooling, Containment Venting as required by the EOPs, and anticipated Drywell pressure decrease due to ambient losses.

Containment Venting is a controlled loss of containment. This venting is performed for the purpose of preventing an unisolable, unmonitored radiological release of containment gases.

A Downcomer failure, by itself, does not represent a Loss of the Primary Containment Barrier. This failure does, however, render the Primary Containment inoperable per the Technical Specification, as Primary Containment integrity has been compromised. A Downcomer failure combined with a large break LOCA will likely result in a Potential Loss of Page 1 of 2 EAL - 3.3.2.b Rev. 00

HCGS EAL/RALTechnical Basis Primary Containment under EAL 3.3.2.a if Containment pressure can not be maintained below 65 PSIG and Containment Venting is required.

Barrier Analysis Primary Containment Barrier has been lost.

ESCALATION CRITERIA Emergency Classification will escalate based on the Potential Loss or Loss of additional Fission Product Barriers per EAL Section 3.0.

DISCUSSION Appropriate classification under this EAL occurs as the result of a Containment failure.

Drywell pressure reaching 1. 68 psig indicates that there is a significant release of reactor coolant to the containment. Unless this source of leakage is isolated or the Reactor is depressurized, Drywell pressure would not be expected to decrease in a rapid manner.

Other indications such as Reactor Building Area Radiation Monitors (ARMs) radiation levels, Reactor Building area temperatures, Reactor Building floor and sump levels, Plant Effluent radiation levels, and containment isolation status should be used to confirm the loss of containment integrity if possible. Reactor Building to Torus vacuum breaker status should be monitored to ensure that this pathway does not result in a loss of containment integrity.

DEVIATION None REFERENCES NUMARC NESP-0007, PC 1 HC.OP-AB.ZZ-0114 (Q), Loss of Primary Containment Integrity HC.OP-AB.ZZ-0116 (Q), Containment Isolations and Recovery from an Isolation HC.OP-AB.ZZ-0201 (Q), Drywell High Pressure/Loss of Drywell Cooling HC.OP-EO.ZZ-0100 (Q)-FC, Reactor Scram HC.OP-EO.ZZ-0101 (Q)-FC, Reactor Pressure Vessel (RPV) Control HC.OP-EO.ZZ-0102 (Q)-FC, Primary Containment Control HC.OP-EO.ZZ-0103 (Q)-FC, Reactor Building Control BWR Owners Group Emergency Procedure Guidelines, Revision 4 Page 2 of 2 EAL - 3.3.2.b Rev. 00

Initiating Condition OPCON EAL#

E M

E R

G E

N c

y A

c T

I 0

N L

E v

E L

s Action Required 9.0 Hazards - Internal/External 9.9 River Level Natural and Destructive Phenomena Affecting the Protected Area

(

All

)

9.9.1.a IF River Level> 99.5'

(

All

)

9.9.1.b IF River Level < 76.0' THEN Refer to Attachment 24 UNUSUAL EVENT (Common Site)

HCGSECG Rev. 00-Page I of I

HCGS EAL/RALTechnical Basis 9.0 Hazards - Internal/External 9.9 River Level UNUSUAL EVENT - 9.9.1.a IC Natural and Destructive Phenomena Affecting the Plant Vital Area EAL River Level > 99.5' OPERATIONAL CONDITION - All BASIS This EAL indicates river level conditions that can threaten the level of safety at the plant due to flooding.

Barrier Analysis NIA ESCALATION CRITERIA Emergency Classification will escalate based on damage to plant safety systems, loss of fission product barriers, or abnormal radiological releases in other EAL sections.

DISCUSSION River level greater than 99.5' is indication of impending site flood conditions. Flood protection measures are required by Hope Creek Technical Specifications and procedure at 95.0'. At this river level precautionary actions are taken, including; filling outside tanks, and ensuring that perimeter flood doors are closed. These actions ensure that the facility flood protection features are in place prior to a river level which would necessitate their use.

The High river level threshold is at the river level that would require a plant shutdown. Hope Creek Technical Specification actions required by a river Level of > 99.5' includes placing the plant in at least Hot Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in Cold Shutdown within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Salem Technical Specifications actions require that perimeter flood doors are closed. This is based on the river level at which facility flood protection features provide protection to safety related equipment Page 1 of 2 EAL - 9.9.1.a Rev. 00

/

HCGS EAL/RALTechnical Basis The National Weather Service can be contacted for further information about existing or projected Adverse Weather Conditions:

Mount Holly Mount Holly DEVIATION None REFERENCES (609) 261-6604

( 609) 261-6602 NUMARC NESP-007, HUI. 7 HC.OP-AB.ZZ-0139 (Q), Acts of Nature HCGS Technical Specification Section 3/4, 3. 7.3, 3/4. 7.1.3, 3/5. 7.3 HCGS UFSAR, Section 2.4, Figure 2.4-3 SGS UFSAR, Section 2.4.11.2, Figure 3.4-1 Page 2 of 2 EAL - 9.9.1.a Rev. 00

HCGS EAL/RALTechnical Basis 9.0 Hazards - Internal/External 9.9 River Level UNUSUAL EVENT - 9.9.1.b IC Natural and Destructive Phenomena Affecting the Plant Vital Area EAL River Level < 76.0' OPERATIONAL CONDITION - All BASIS The Service Water pumps are designed to operate to a low river level of 76.0'. This EAL threshold is set to correspond to river level conditions that jeopardizes the level of safety of the plant due to a loss of the Ultimate Heat Sink. The low level threshold is based on the Minimum River Level required for operability of the Ultimate Heat Sink, as defined in the Hope Creek Technical Specifications and UFSAR.

Barrier Analysis NIA ESCALATION CRITERIA Emergency Classification will escalate based on damage to plant safety systems, loss of fission product barriers, or abnormal radiological releases in other EAL sections.

DISCUSSION The grade level at the Salem station is lower than that for Hope Creek (Salem = 99.5'( 10.5'MSL), Hope Creek = 101.5' (12.5'MSL)).

The National Weather Service can be contacted for further information about existing or projected Adverse Weather Conditions:

Mount Holly Mount Holly (609) 261-6604 (609) 261-6602 Page 1 of 2 EAL-9.9.1.b Rev. 00

HCGS EAL/RALTechnical Basis DEVIATION None REFERENCES NUMARC NESP-007, HU 1. 7 HC.OP-AB.ZZ-0139 (Q), Acts of Nature HCGS Technical Specification Section 3/4, 3.7.3, 3/4.7.1.3, 3/5.7.3 HCGS UFSAR, Section 2.4, Figure 2.4-3 SGS UFSAR, Section 2.4.11.2, Figure 3.4-1 Page 2 of 2 EAL - 9.9.1.b Rev. 00

Initiating Condition OPCON EAL#

E M

E R

G E

N c

y A

c T

I 0

N L

E v

E L

s Action Required 9.0 Hazards - Internal/External HCGSECG Rev. 00 Page I of I 9.8 Turbine Failure I Vehicle Crash I Missile Impact Natural and Destructive Phenomena Affecting Certain Structures Within the Protected Area

(

All

)

9.8.1.a IF Catastrophic damage to the Main Turbine as evidenced by EITHER one of the following:

Main Turbine casing penetration

Main Turbine/Generator Damage potentially releasing Lube Oil or Hydrogen Gas to the Turbine Building

(

All

)

9.8.1.b IF Vehicle Crash I Missile Impact with or within ANY one of the following Plant Structures:

Reactor Building

Turbine Building

Control/ Aux Building

Service Water Intake Structure

Service/Rad Waste Building THEN Refer to Attachment 1 UNUSUAL EVENT Natural and Destructive Phenomena Affecting Certain Structures Within the Plant Vital Area

(

All

)

9.8.2 IF Vehicle Crash I Missile Impact with or within ANY one of the following Plant Vital Structures:

Reactor Building

Control/ Aux Building

Service Water Intake Structure

Service/Rad Waste Building I AND The Vehicle Crash I Missile Impact is of a magnitude that it SPECIFICALLY results in Damage to ANY one of the following:

TWO OR MORE subsystems of a Safety System

MORE THAN ONE Safety System

Any of the above Plant Vital Structures which renders the structure incapable of performing its Design Function I AND Damaged Safety System(s) or Plant Vital Structure is required for the present Operational Condition

~THEN Refer to Attachment 2 ALERT

L HCGS EAL/RALTechnical Basis 9.0 Hazards - Internal/External 9.8 Turbine Failure I Vehicle Crash I Missile Impact UNUSUAL EVENT - 9.8.1.a IC Natural and Destructive Phenomena Affecting Certain Structures Within the Protected Area EAL Catastrophic damage to the Main Turbine as evidenced by EITHER one of the following:

Main Turbine casing penetration Main Turbine/Generator Damage potentially releasing Lube Oil or Hydrogen Gas to the Turbine Building OPERATIONAL CONDITION - All BASIS Main Turbine failure of sufficient magnitude to cause damage to the turbine casing or generator seals increases the potential for leakage of combustible/explosive gases and of combustible liquids to the Turbine Building, warrants declaration 6f an Unusual Event. The presence of H2 gas in sufficient quantities Jllay present a flammable/explosive hazard. Turbine Lube Oil may also be present which may contribute to the flammability hazard.

Barrier Analysis NIA ESCALATION CRITERIA Emergency Classification will escalate to an Alert based upon damage done by missiles generated by the failure.

DISCUSSION Turbine rotating component failures may also result in other direct damage to plant systems and components. Damage may rupture the Turbine Lubricating Oil System, which would release flammable liquids to the Turbine Building. Potential rupture of the Main Condenser Page 1 of 2 EAL - 9.8.1.a Rev. 00

_y*

HCGS EAL/RALTechnical Basis and condenser tubes may cause flooding in the lower levels of the Turbine Building. This damage should be readily observable.

Escape of hydrogen gas from the generator due to a loss of seal oil pumps or turbine lube oil without a turbine rotating component failure should not be classified under this event.

DEVIATION None REFERENCES NUMARC NESP-007, HUl.6 Page 2 of 2 EAL - 9.8.1.a Rev. 00

ML18102A560

Text

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