ML20069M110

Provides Revs to Proposed EALs Which Resulted from Comments Provided by NRC Following NRC Review of EALs Submitted for Review on 940422

ML20069M110
Person / Time
Site:	Beaver Valley
Issue date:	06/14/1994
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9406210152
Download: ML20069M110 (18)

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Beaver Valley Power StatK>n Shrppingport, PA 15077-0004 JOHN D SICBER (412) 393-5255 Senior Wce President and Fax (412) 643-8069 ct of Nuclear Officer Nuclear Power Dmston U.

S.

Nuclear Regulatory Commission Attn:

Document Control Desk Washington, DC 20555

Subject:

Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Proposed Emergency Action Levels This submittal provides revisions to the Beaver Valley Power Station (BVPS) proposed Emergency Action Levels (EALs) which resulted from comments provided by the Nuclear Regulatory Commission (NRC) following their review of the EALs submitted for review on April 22, 1994.

The changes were discussed during two conference calls between Duquesne Light Company Emergency Preparedness Department personnel and NRC personnel.

All but one of the revisions are editorial or for clarification.

EAL 4.1.G was changed to add a third criterion.for entering into a

General Emergency.

An uncontrolled reactor coolant system heatup for more than 15 minutes is now also necessary before a General Emergency is declared through EAL 4.1.G.

If you have any questions on this submittal, please contact Mr.

l R.

K.

Brosi, (412) 393-5767 Sincerely,

]

lI.

D.

Sieber

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Enclosures cc:

Mr.

L.

W.

Rossbach, Sr. Resident Inspector Mr.

T.

T.

Martin, NRC Region I Administrator Mr.

G.

E.

Edison, Project Manager Mr.

S.

A.

Boynton, NRR/PEPB I

YN0d7 lf$ Y ENERGV u

9406210152 940614 i

PDR ADOCK 05000334 l

F PDR

Be. aver

• Valley Power Station Emergency Action Levels Page 2 bec:

R.

K. Brosi (w/o enclosures)

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i ENCLOSURE Listing of Revised Proposed EAL Pages:

EAL 4.1 Unit 1 EAL 4.1 Unit 2 4.0-8 4.0-10 4.2-19 4.2-20 4.4-2 4.4-3 4.4-4 4.5-11 4.6-11 4.6-15 4.6-16 4.6-17 4.6-18 l

e

'.2 Explosiori-Mode CriterlOn / Indicator Mode CriterlOn / Indicator FIRE in 1he control room, cable tray mezzanine, y Refer to Tab 4.1 " Fire"or Tab 1 ' Fission Product process control room resulting in an evacuation of Barrier Matrix" the control room per 1.56C.4 " Alternate Safe Shut-down"gndloss of an re utred equipmentQsIn i

Cl an uncontrolled RCS eatu

'j!and W l

1 1.1.56C.4 'Allemate Safe Shutdown" entered l

e 2

2. Ops personnel report Inability to operate at least one 3

of each of the following components of the available 4

train:

Charging pump AFW pump Diesel generator RPR_W pump BIP Steam rehef path _

3. Uncontrolled RCS heatup lasting longer than 15 inutes FIRE In the control room, cable tray mezzanine, M Refer to Tab 4.1 " Fire"or Tab 1 ' Fission Product Barrier process control room resulting in an evacuation of Matrix" the control room per 1.56C.4 " Alternate Safe Shut-down" 1.1.56C.4 " Alternate Safe Shutdown

• entered I

e 2

I 3

4 FIRE in any of the areas listed in Table 4-1 that is EXPLOSION in any of the areas ilsted in Table 4-1 that affecting safety related equipment is affecting safety related equipment i

[1 and 2]

[1 and 2]

1. FIRE in any of the listed areas in Table 41

1. EXPLOSION in any of the listed areas in Table 4-1

2. [a or b]

2.[a or b]

All

a. Ops personnel report VISIBLE DAMAGE to per-All

a. Ops personnel report VISIBLE DAMAGE to per-manent structure g equipment in listed area due to manent structure g equipment in listed area FIRE

b. Control room Indication of degraded system m

b. Control room indication of degraded system E component (within listed areas) response due to component (within listed areas) response due to EXPLOSION FIRE FIRE in g adjacent to those areas listed in Table 4-1 UNPLANNED EXPLOSION in g adjacent to those not extinguished within 15 minutes from the time of areas listed in Table 4-1 control room notification g verification of control room alarm

1. UNPLANNED EXPLOSION in g adjacent to any of the listed areas in Table 4-1 All All h

I Copyright C 1992,1993,1994 by Duquesne Light Co.

'.2 Explosion -

Mode Criterion / Indicator Mode Criterion / Indicator FIRE in the control room, cable tray mezzanine, g Refer to Tab 4.1 " Fire

• or Tab 1 " Fission Product process control room resulting in an evacuation of Barrier Matrix" the control room per 2.56C.4 " Alternate S Shut.

_down"gnd loss o_f any required equipmen results in an uncontrolled RCS hea up

[1 aniRand 31 1

1. 2.56C.4 " Alternate Safe Shutdown" entered 2

2. Ops personnsl report inabildy to operate any of the 3

following equipment required by 2.56C.4 " Alternate 4

Safe Shutdown

• CHS-P2I A SWS-P21 A FWE-P23A & FWE-P22 EGS-EG21 Black DG Alternate S!D Panel

_S AS-C 21 A CCP-P21 A__

RHS-P2 t A

/'_3.OI1 controlled RCS heatup lasting longer than 11

( min d

FIRE in the control room, cable tray mezzanine, y Refer to Tab 4.1

• Fire'or Tab l ' Fission Product Barrier process control room resulting in an evacuation of Matrix" the control room per 2.56C.4 " Alternate Safe Shut-down" 1,2.56C.4 " Alternate Safe Shutdown" entered 3

2

~

3 4

)

l FIRE in any of the areas listed In' Table 4-1 that is EXPLOSION in any of th e a reas ilsted in Table 4-1 that affecting safety related equipment is affecting safety related equlpment

[1 and 2]

[1 and 2]

1. FIRE in any of the listed areas in Table 41

1. EXPLOSION in any of the listed areas in Table 4-1 a

2. [a or b]

2.[a or b]

All

a. Ops personnel report VISIBLE DAMAGE to per.

All

a. Ops personnel report VISIBLE DAMAGE to per-manent structure gr equipment in listed area due to manent structure QI equipment in listed area

)

FIRE

b. Control room indication of degraded system gI

b. Control room indication of degraded system gI component (within listed areas) response due to component (within listed areas) response due to EXPLOSION FIRE FIRE in m adjacent to those areas listed in Table 41 UNPLANNED EXPLOSION in m adjacent to those not extinguished within 15 minutes from the time of areas listed in Table 41 control room notification m verification of control room alarm

1. UNPLANNED EXPLOSION in gI adjacent to any of the listed areas in Table 4-1 All All k

Copyright @ 1992,1993,1994 by Duquesne Light Co.

Section 4 Emergency Preparedness Plan Emergency Action Level Bases

.3 EAL Matrix 4.3.1 NUMARCINESP407 Abnormal Rad Levels / Radiological Effluent NUMARC/NESP-007 Reference BVPS Reference AU1 Gaseous or Liquid Effuent 7.1.U Gaseous effluents 7.2.U liquid effluents AU2 Plant Radiation Levels 7.3.U Addresses exmaple EAL#4 7.4.U Addresses example EAL #1,3 6.5.U Addresses example EAL #1,3 l

AA1 Gaseous or Liquid Effluent 7.1.A Gaseous effluents 7.2.A Liquid effluents AA2 Fuel Damage / Loss of Water Level 7.4.A 6.5.A Addresses example EAL #1,2 l

AA3 Plant Radiation Levels 7.3.A AS1 Gaseous Effluent 7.1.S Deviation AG1 Gaseous Effluent 7.1.G Deviation OV i

i 1

O 4.0-8 Rev 6-01

l l

Ssction 4 Emergency Preparadness Plan Emargency Action Level Bases

.3 NUMARCINESP-007 Hazards and Other Conditions Affecting Plant Safety NUMARC/NESP-007 Reference BVPS Reference HU1 Destructive Phenomena in Protected Area 5.1.U (Addresses example EAL #1) 5.2.U (Addresses example EAL #2) 5.3.U (Addresses example EAL #4) 4.2.U (Addresses example EAL #5) 2.9.U (Addresses example EAL #6) 5.6.U (Addresses example EAL #4) 5.4.U (Addresses example EAL #7)

HU2 Fire 4.1.U HU3 Flammable or Toxic Gases 4.3.U (Flammable) 4.4.U (Toxic gas)

HU4 Security 4.6.U 1

HUS Emergency Director Judgment 4.7.U 2.10 (Uncontrolled cooldown)

.U J

JA1 Destructive Phenomena in Vital Area 5.1.A (Addresses example EAL #1) 5.2 A (Addresses example EAL #2) 5.3.A (Addresses example EAL #5) 1 2.9.A (Addresses example EAL #6) l 5.4.A (Addresses example EAL #7) 5.5.A (Addresses exampie EAL #7)

HA2 Fire / Explosion Affecting Safety Systems 4.1.A (Fire) 4.2.A (Explosion)

HA3 Toxic / Flammable Jeopardizes 4.3.A (Flammable Gas) 4.4.A (Toxic Gas)

HA4 Security Event in Protected Area 4.6.A HAS Control Room Evacuation 4.5.A HA6 ED Judgment 4.7.A l

HS1 Security Event in Plant Vital Area 4.6.S l

HS2 Control Room Evacuation 4.5.S Also 4.1.S (App. R Procedure) l HS3 ED Juagment 4.7.S HG1 Security Event / Loss of Ability to S/D 4.6.G

'dG2 ED Judgment 4.7.G Also 4.1.G (App. R Procedure w/ failures) 1 4.0-10 Rev 6-01

Section 4 Emergency Preparedness Plan Emergency Action Level Bases

[

Jection 2.0 SYSTEM DEGRADATION TAB 2.9 TURBINE FAILURE EA L 2. 9. A ALERT Mode 1,2,3 Description Turbine failure generated missiles cause penetration of a missile shield wall of any area containing safety related equipment 1.

Piant personnel report missiles generated by turbine failure with casing penetration also re.Ms in a through-wall penetration of a missile shield wall listed in Table 5-2 Basis This EAL is intended to address the threat to safety related equipment imposed by missiles generated by main turbine rotating component failures. Shield walls are incorporated into the design of the areas of concern. To permit a rapid assessment of the potential for damage to safety related equipment, an assessment of these shield walls is appropriate, if no through wall penetration is observed, equipment should not be jeopardized. The list of areas provided includes all areas containing safety-related equipment, their controls, and their power supplies. This EAL is, therefore, consistent with the definition of an ALERT.

Unit 1 Table 5-2 Plant Areas Associated With Shield Wall Penetration EAL Control Room Electrical Switchgear Safeguards WT-TK 10 Diesel Generator Bldo Cable Tray Mezz Containment Primary Aux. Building Unit 2 Plant Areas Associated With Shield Wall Penetration EAL Main Steam Valve Room 2FWE-TK210 Diesel Generator Bldo Containment Service Bldg. 745' and 760' Primary Aux Building Emergency Switchgear 730' Escalation Escalation of this event will be based on " Fission Product Barrier Matrix".

Re/erences NUMARC/NESP-007, (HA1 example #6), Rev. 2,1/92 4.2 19 Rev 6-01

Section 4 Emergency Preparedness Plan Emsroency Action Level Bases

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Section 2.0 SYSTEM DEGRADATION TAB 2.9 TURBINE FAILURE EA L 2.9. U UNUSUAL EVENT Mode 1,2,3 Description Turbine failure results in casing penetration 1.

Plant personnel report a turbine failure which results in penetration of the turbine casing or damage to main generator seals (with evidence of significant hydrogen or seat oil le1kage) 1 Basis This EAL is intended to address main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the main turbine generator. Of major concern is the potential for damage to non-safety related equipment or the leakage of combustible fluids, lubricating oils and gases (hydrogen) to the plant environs. Actual fires and flammable gas build up are appropriately classified via other events. This EAL is consistent with the definition of an Unusual Event while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment.

l i

i 1

Escalation Escalation of this event would be based on potential damage done by turbine PROJECTILES to safety related equipment.

References NUMARC/NESP-007, (HUI example # 6), Rev. 2,1/92 D\\

ty 1

4.2 20 Rev 6-01

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Section 4 Emergency Preparedness Plan Emergency Action Level Bases O

Section 4.0 HAZARDS AND ED JUDGMENT TAB 4.1 FIRE E4L 4.1.G GENERAL EMERGENCY Mode 1,2,3,4 Description FIRE in the control room, cable tray mezzanine, or process control room resulting in an evacuation of the control room per 1.56C.4 (2.56C.A) " Alternate S4/e Shutdown" and loss of any required equipment resulting in an uncontrolled RCS heatup. // and 2 and 3) 1.

1.56C.4 (2.56C.4) " Alternate Sa/e Shutdown" entered 2.

Ops personnel report inability to operate at least one of each (any) of the following components of the available train (equipment required by 2.56C.4):

Unit 1 Charging Pump AFW pump Diesel generator RPRW pump BIP Steam relief path Unit 2 CHS-P21 A CCP-P21 A EGS-EG 2-1 FWE-P23A & FWE-P22 SAS-C21 A Alternate S/D Panel SWS-P21 A RHS-P21 A I

Black D/G 3.

Uncontrolled RCS heatup lasting longer than 15 minutes.

O 4.4 2 Rev 6-01

Section 4 Emergency Preparedness Plan Emergency Action Level Bases Section 4.0 HAZARDS AND ED JUDGMENT TAB 4.1 FIRE EA L 4.1. G GENERAL EMERGENCY (Con't)

Mode 1,2,3,4 Basis See generic bases at the beginning of this section.

The EAL considers the degradation associated with the implementation of OM 1(2).56C.4 " Alternate Safe Shutdown". The procedure is designed to permit a small operating crew to shutdown and cooldown the unit without the use of the control room or alternate shutdown panel. The procedure is entered when there is a fire in the control room, cable tray mezzanine, or process control room. These areas carry cabling and equipment controls that can affect safety systems significantly. The cable separation is such that a fire in any one of these areas will not eliminate both trains of equipment capability. To achieve unit shutdown and cooldown without fire induced spurious activations and failures, only select components of a single available train are utilized. This intentionally reduces the normal redondancy of safety related equipment and thus necessitates that all equipment identified operate as required. INDICATOR

1. 2 recognizes that if one of the components performing each of the identified functions is not operating properly, plant control cannot be ensured. For the Unit 1 charging and reactor plant river water systems this can be accomplished with the available train pump or the swing "C" pump. For the AFW (FWE) system this can be accomplished by the use of the available motor driven pump or the turbine driven pump. Any available steam path is acceptable, (atmospheric dump valves or residual heat release valve). The loss of this equipment under these conditions willlead to a core melt sequence. INDICATOR #3 is included to recognize the RCS heatup toward a core melt sequence and prevent an overly conservative declaration due to momentary losses of equipment functions. When the loss of functions leads to an uncontrolled heatup the situation constitutes a General Emergency.

Escalation Not Applicable References NUMARC/NESP-007 (addition consistent w/ HG2) Rev. 2,1/92 OM 1.56C.4 4.4 3 Rev 6-01

Section 4 Emergency Preparednsss Plan Emergency Action Level Bases (O

V Section 4.0 HAZARDS AND ED JUDGMENT TA B 4.1 FIRE EAL 4.1.S SITE AREA EMERGENCY Mode 1,2,3,4 Description FIRE in the control room, cable tray mezzanine, or process control room resulting in an evacuation of the control room per 1.50C.4 (2.56C.4)" Alternate Safe Shutdown" 1.

1.56C.4 (2.56C.4) " Alternate Safe Shutdown" entered Basis See generic bases at the beginning of this section.

The EAL considers the degradation associated with the implementation of OM 1.56C.4

• Alternate Safe Shutdown". The procedure is designed to permit a small operating crew to shutdown and cooldown the unit without the use of the control room or attemate shutdown panel. The procedure is entered when there is a fire in the control room, cable tray mezzanine, or process control room. These areas carry cabling and equipment controls that can affect safety systems significantly. The cable separation is such that a fire in any one of these areas will not eliminate both trains of equipment capability. To achieve this unit shutdown and cooldown without fire

['

induced spurious activations and failures, only select components of a single available

(

train are utilized. This intentionally reduces the normal redundancy of safety related equipment. This reduction in available equipment coupled with the fire in progress and the limitations associated with instrumentation constitutes a Site Area Emergency.

Escalation Escalation would be based on 4.1.G due to loss of necessary equipment to perform OM 1.56C.4 References NUMARC/NESP-OO7 (addition consistent w/ HS2) Rev. 2,1/92 OM 1.56C.4

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4.4-4 Rev 6-01 f

Section '4 Emsrgsncy Preparedness Plan Emergency Action Level Bases Section 5.0 DESTRUCTIVE PHENOMENA TA B 5. 5 RIVER LEVEL LOW EA L 5. 5. A ALERT Mode All Description River water leve; < 648.6 Ft Mean Sea Level /1 or 2/

1. LR-CW-101, if accessible, indicates < 648.6 Ft mean sea level

2. National Weather Bureau (644-2882) or Montgomery Lock (643-8400) reports Montgomery Lower Pool stage height < -3.92 Ft.

Note: Mean Sea Level = stage height + 652.52 Ft Basis A level of < 648.6 Ft mean sea level was selected for this EAL. This river level will result in reduction / loss of suction to the intake structure pumps. Two methods of obtaining the information is included in the EAL. This precludes reliance on a single instrument.

Esca/ation Escalation to this event will be based on " Fission Product Barrier Matrix."

References NUMARC/NESP-007, (HA1 example #7), Rev. 2,1/92 4.5-11 Rev 6-01

I Section 4 Emergency Properedness Plan Emergency Action Level Basis bo Section 6.0 SHUTDOWN SYSTEMS DEGRADATION TAB 6.2 RCS INVENTORY SHUTDOWN EA L 6. 2. U Unusual Event Mode 5,6 Description Loss of Reactor Coolant System Inventory with inadequate make-up (1 and 21

1. Ops personnel report temporary RCS level instrumentation in the Control Room indicates a level drop to 14.5 inches

2. Ops personnel report inability to make-up RCS inventory Basis See generic bases for this TAB This EAL is intended to serve as a precursor to loss of RHR (RHS) The loss of RCS j

inventory could be the result of failure of temporary piping or temporary barriers (e.g.,

steam generator dams, freeze seals). The potential for such events increases during shutdown due to the accelerated maintenance activity that occurs during these periods. In addition to creating the potential for loss of inventory, this maintenance activity, removes equipment from service that could restore inventory to mitigate the h

consequences of the loss, A sudden loss of inventory could result in a loss of decay heat removal due to RHR (RHS) pump suction vortexting or preemptory operator pump manual shutdowns, as could a smaller leak that cannot be isolated.

i TABS 2.5 and 2.6 address RCS leakage. Although the mode applicability includes mode 5, it is limited to mode 5 with the RCS pressurized. There are no EALs that address RCS leakage in mode 5 with the RCS depressurized, or in mode 6. Further, those EALs identify a specific numeric leak rate, which is not appropriate to shutdown conditions.

This EAL does not specify a numeric leak rate in that the conditions surrounding the leak and the systems available to make-up losses can depend on ongoing maintenance activities. There are no make-up systems required by T/S in shutdown modes, i

Escalation Escalation to higher classifications would occur if (1) the core becomes uncovered, or (2) if the RHR (RHS) loss results in core exit temperature increase in excess of 10*Fand exceeds 200 F Re/etences Pending (NUMARC Shutdown EALs consistent w/ NUMARC/NESP-OO7 HU5)

O 4.6-11 Rev 6-01

Section 4 Emergency Preparedness Plan Emergency Action Level Basis O

Section 6.0 SHUTDOWN SYSTEM DEGRADATION TA B 6.5 FUEL HANDLING

~

EA L 6. 5. A Alert Mode All Description Major damage to irradiated fuel; or loss of water level that has or will uncover irradiated fuel outside the reactor vessel (1 and 2) 1.

VAllD Hi-Hi Alarm on RM-RM 203 or RM-RM-207 or RM-VS-103 A/B or RM-VS-104A/B (High on RMF-RQ202(1031),301 A/B (1032/2032), HVR-RQ104A/B (1024/1028), or RMR RQ203(10251) 2.

(a or b) a Plant personnel report damage of irradiated fuel sufficient to rupture fuel rods b.

Plant personnel report water Level drop has or will exceed makeup capacity such that irradiated fuel will be uncovered Basis The major concern of the EAL is a fuel handling accident or loss of water covering spent fuel. Events away from the reactor vessel (e.g., in the cavity, transfer tube, or spent fuel pool) are addressed. Events within the vessel are classified in accordance with TABS 6.1 and 6.2.

Events of this type could cause an increase in radioactivity readings and potentially a release to the environment. The magnitude of these releases is dependent on the amount of damage, depth of water above damage, and available filtration systems.

Design basis fuel handling accident doses could exceed the EPA PAG, warranting a General Emergency classification. However, as with all UFSAR analyses, there is extensive conservatism in the analysis. Thus, an Alert Emergency is deemed justified.

This declaration would result in augmentation of onsite personnel to support assessment of the release and restorative actions to stabilize the condition.

With regard to the loss of water level, design features and administrative controls limit the possible fuel uncovery to a single element. Analyses performed in response to IE Bulletin 84-03, showed that the clad on a fuel assembly suspended in air would begin to melt at about 60 minutes, assuming an ambient air temperature of 105 *F, which is conservative. This time period provides for event-specific assessments. Escalation of the classification would be based on the results of these assessments.

Esca/ation Escalation would on the basis of TAB 7.1, Gaseous Effluents References NUMARC/NESP-007 (AA2 example # 1,3), Rev 2,1/92 Itr dtd 10/24/84, JJCarey to TEMurley USNRC RI Itr ND1SCA:0095 dtd 9/17/84, MYLee to KDGrada (D

Q) 4.6-15 Rev 6-01

r 1

)

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Section 4 Emergency Preparedness Plan Emstgency Ac' tion Level Basis O

Section 6.0 SHUTDOWN SYSTEM DEGRADATION TA B 6.5 FUEL HANDLING EA L 6.5. A Alert (Con't)

Mode Alt Description (Con't)

Basis (Con 't)

INDICATOR #1 verifies the reports discussed in INDICATOR #2 by noting the increase in radiation levels, and/or airborne activity in the affected areas. An increase on the ventilation monitors signifies the release of radioactivity in the fuel gap, whereas, an increase on area radiation monitors is indicative of reduced shielding due to the decrease in water level.

Esca/ation Escalation would on the basis of TAB 7.1, Gaseous Effluents References NUMARC/NESP-007 (AA2 example # 1,3), Rev 2,1/92 Itr dtd 10/24/84, JJCarey to TEMurley USNRC Rt ltr ND1SCA:0095 dtd 9/17/84, MYLee to KDGrada 4.6 16 Rev 6-01

,_. - - + _. - - -,. - -_,_,

.n,

m Section 4 Emergency Preparedness Plan

, Emergency Action Level Basis O

Section 6.0 SHUTDOWN SYSTEM DEGRADATION TA B 6.5 FUEL HANDLING EA L 6.5. U Unusual Event Mode All Description UNPLANNED loss of water levelin spent fuel pool or reactor cavity or transfer canal with fuel remaining covered (1 and 2 and 31 1.

Plant personnel report water level drop in spent fuel pool or reactor cavity or transfer canal 2.

VAllD Hi Hi Alarm on RM RM 203 or RM-RM 207 (RMR-RO203 (1025] or RMF-RQ202 (10311)

3. Fuel remains covered with water.

Basis The major concern of the EAL is a loss of water covering spent fuel. Events away from the reactor vessel (e.g., in the cavity, transfer tube, or spent fuel pool) are addressed. Events within the vessel are classified in accordance with TABS 6.1 and C.J.

Events of this type could cause an increase in radioactivity readings and potentially a release to the environment. The magnitude of these releases is dependent on the amount of damage, depth of water above damage, and available filtration systems.

However, even without a release, elevated dose rates in adjacent areas could create access limitations. (See TAB 7.3)

The design of fuel handling equipment and administrative controls on activities involving spent fuel maintains water above the fuel during normal handling. Should there be a loss of water level, such as that associated with a failure of the reactor cavity seal, fuel elements could be exposed to air in three locations: (1) in the manipulator mast, in the RCCA change fixture, and suspended from the fuel pool bridge crane. Analyses performed in response to IE Bulletin 84-03, showed that the clad on a fuel assembly suspended in air would begin to melt at about 60 minutes, assuming an ambient air temperature of 105 *F, which is conservative. The additional heat transfer afforded by the water assumed in this EAL would extend this time to several hours. This time period provides for event specific assessments.

I Escalation of the classification would be based on the results of these assessments.

INDICATOR #2 verifies the reports discussed in INDICATOR #1 by noting the increase in radiation levels in the affected areas. An increase on area radiation monitors is indicative of reduced shielding due to the decrease in water level. INDICATOR #3 is the discriminator between the Unusual Event and the Alert.

Escalation Escalation would on the basis of TAB 7.1, Gaseous Effluents, or TAB 7.3, Radiation Levels l

[U]

References NUMARC/NESP-007 (AU2 example # 1,2), Rev 2,1/92 ltr dtd 10/24/84, JJCarey to TEMurley USNRC RI Itr NDISCA:0095 dtd 9/17/84, MYLee to KDGrada

)

1

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4.6-17 Rev 6 01

{

l Section 4 Emergency Preparedness Plan Emergency Action Level Basis J

Section 6.0 SHUTDOWN SYSTEM DEGRADATION TAB 6.6 INADVERTENT CRITICAllTY EA L 6. 6. A Alert Emergency Mode 3,4,5,6 Description inadvertent reactor criticality

1. Nuclear instrumentation indicates unanticipated sustained positive startup rate l

Basis This EAL addresses situations in which inadvertent criticalities occur. Improper rod withdrawls are included but limited in application to Modes 3,4,5, and 6. It is not intended that this Alert apply to a premature criticality during a planned reactor startup. In this situation the plant has been prepared for the reactor to be brought critical and procedural control dictate appropriate action. This situation is therefore not consistent with the declaration of an emergency. This EAL also addresses events (e.g.,inadvertant dilution, failure of loop dams) that result in dilution of RCS boron concentration. It has been postulated that localized criticality could occur in the reactor vessel due to such a failure with RCS temperature cold. Such a criticality would cease once in vessel mixing re-established negative reactivity in the affected C--

region of the core. Since this sequence would likely be less than the recognition and assessment time, the INDICATOR calls for a sustained positive startup rate.

I Escalation Escalation would on the basis of the failure of RHR to remove the heat of fission, resulting in a heat-up.

/etences Pending (NUMARC Shutdown EALs consistent w/ NUMARC/NESP-007 HA6) 4.6 18 Rev 6-01 wWT-- - - --

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