ML20100G113

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Rev 3 to Ccnpp EALs Technical Basis Document
ML20100G113
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 01/31/1996
From: Rudigier G
BALTIMORE GAS & ELECTRIC CO.
To:
Shared Package
ML20100G111 List:
References
NUDOCS 9602220363
Download: ML20100G113 (26)
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Text

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4 ENCLOSURE  !

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CALVERT CLIFFS NUCLEAR POWER PLANT EMERGENCY ACTION LEVELS TECIINICAL BASIS DOCUMENT REVISION 3 i

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9602220363 960215 PDR ADOCK 05000317 F PDR i

Baltimore Gas & Electric Company Docket Nos. 50-317 and 50-318 Independent Spent Fuel Storage Facility Docket .No. 72-8 February 15,1996

., ENCLOSURE CALVERT CLIFFS NUCLEAR POWER PLANT EMERGENCY ACTION LEVELS TECHNICAL BASIS DOCUMENT

' REVISION 3

SUMMARY

Only the revised pages of the Technical Basis Document are included in this transmittal. New words/information are identified by bold letters and revision bars. Deleted words/information are identified by line-out and revision bars. Typographical and reference corrections are identified by revision bars only.

SPECIFIC REVISION ITEMS Page Item i Table of Contents:

Added "QA4 - Station Blackout While Defueled," page Q:14.

Renumbered pages Q:14 through Q19 to accommodate new page.

A:2 Deleted non applicable step.

G:8 Added new initiating condition, "QA4 - Station Blackout While Defueled."

. Q:14 Calvert Cliffs Initiatina Condition:

1 Basis for new initiating Condition QA4 is QA Surveillance Report S-94-3-26. Regulatory Guide 1.101 (NUMARC/NESP-OO7) includes defueled as a mode.  !

l Plant-Soccific Information:

New basis analysis for creating the new Initiating Condition.

EAL:

New EAL worded to support analysis ofInitiating Condition.

Q:15 Renumbered pages to accommodate new page Q:14.

through Q:21 E:7 Added a cross-reference to the new initiating condition to aid document users.

Continued on the next page.

I 1

.c ENCLOSURE CALVERT CLIFFS NUCLEAR POWER PLANT ,

EMERGENCY ACTION LEVELS TECHNICAL BASIS DOCUMENT REVISION 3 I:1 Elant-Snecific Information:

Added the statement "Calvert Cliffs EAL is based directly on NUMARC."

Removed reference to areas of concern for safe shutdown based on the revised EAL. ,

I
2 Tabic-Removed the table containing " Areas of Concern for Safe Shutdown." Continuation of revised Plant-Specific Information.

EAL: 1 Revised EAL to support the revised plant-specific information.

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References:

Removed reference to AOPs referring to safe shutdown. Added references supporting new analysis ofInitiating Condition.

I:3 Elant-Soccific Information:

Added analysis for determining the magnitude of an Alert level fire. This methodology is i with the Unusual Event Initiating Condition.  ;

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l EAL:

3 Reworded existing EAL to support the logic addressed in the Plant-Specific Information. ,

Removed reference to explosion. This becomes a separate EAL.

. o l Continued on the next page.

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,," ENCLOSURE CALVERT CLIFFS NUCLEAR POWER PLANT EMERGENCY ACTION LEVELS TECHNICAL BASIS DOCUMENT REVISION 3 I:4 Plant-Soccific Information: (Continued from 1:3)

Continuation of revised Plant-Specific Information.

EAL 2 New EAL to support the analysis of the Initiating Condition.

JMLL.l:

New stand-alone EAL for explosion.

Information added to characterize the nature of an explosion. Removed analysis of how fire affects the ability to achieve safe shutdown is determined.

Table Corrected reference to 21 Fuel Oil Storage Tank.

I New analysis identifies how the significance of fire and explosions is determined.

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References:

Added references supporting new analysis of the Initiating Condition.

O:1 Typographical errors corrected.

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. .. TABLE OFCONTENTS CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 & 2 EMERGENCY ACTION LEVELS TECIINICAL BASIS DOCUMENT REVISION 3 L

EPARED.

//2f/N DATE:

Em rgencyPlanning-G.C.Jthdigier /

bY DATE: / 29 f[

Pfint - xrations - J. V. Grooms REVIEWED: /

Y A Yl b(M U, DATE: YU N \

Opeptfi nsTraining.D.13.Fr er

)

,. f(

f e%MogYams -G. '. B r/

_[ DATE: /A I

l b

diatio ty - E. H. Roach ~

o- c.-

DATE: /' 24 h

REVIEWED:

/ .

%ign Engineering-Mech ical -C. J. Ludlow DATE: //7v84 h --, DATE: / M!f 5 Desi ngineeritig- cal R. B. Sydnor REVIEWED:

DATE: /tly/ft Nuclear Engineerin - S. . Bailey h rw DATE: /!4Y 9[ '

Secu/ity-hyfC Neyriian' /

,#crbe DATE: /!d@!7 DATE: / N-Dir'ector-Brndgency Planning Unit - T. E. Forgette

- hb"@h DATE: /-J/- F (-

POSRC / ,- Meeting No.

DATE: /# 4 11 ant General Manafer[

EfTective Date: with ERPIP 3.0. Revision . Change

[b (

Calvert Cliffs EAL Basis Document Rev.3

,, LIST OF EFFECTIVE PAGES REV.3 1 i

i FAGE REVISION i 3 il 1 lii 0

$ A:1 A:2 3 [

A:3 1 G:1 0 ,

G:2 0 G:3 0 G:4 0 ,

G:5 0 G:6 0 G:7 0 G:8 3 G.9 0 ,

G:10 0 R:1 0 R2 0 R:3 1 R:4 0 R:5 1 R:6 0 R:7 0 R:8 0 R:9 0 R:10 0 R:11 0 R:12 0 R:13 0 R:14 1 R:15 0 R:16 0 R:17 0 i R:18 0 ,

R 19 0 R:20 0 R:21 0 R:22 0 R:23 0 R:24 0 B:1 0 B:2 0  !

B:3 1 B:4 1 B:5 1 -

B:6 0 B:7 0 i

  • - ** LIST OF EFFECTIVE PAGES REV. 3 FAfrE REVISION B:8 0 B:9 0 B:10 0 B:11 0  ;

B:12 0 B:13 0 ,

B:14 0 l B:15 0 B:16 0 B:17 0 B:18 0 B:19 0 j 13:2 0 0 11:2 1 0 .,

I.:22 0 B'23 0 B:24 1 ,

B 25 0 B:26 0  !

B:21 0 B:2t' 0 B:29 0 B:30 0 B.31 0 B:32 0 B:33 0 B:34 1 B:35 1 B:36 0 B:37 0 B:38 0 Q:1 0 Q:2 0 Q:3 0 Q:4 0 Q:5 0 Q:6 0 Q:7 0 Q;8 0 Q:9 0 l Q:10 0 i Q:11 0 Q:12 0 Q:13 0 Q:14 3 Q:15 3 Q:16 3 Q:17 3 Q:18 3 Q:19 3 .

Q:20 3 Q:21 3

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- ' ' LIST OF EFFECTIVE PAGES REV 3 FAfrX REVISION i E:1 0 E:2 0 E:3 0 E:4 0 E:5 0 ,

E:6 0 E:7 3 E:8 1 E:9 1 E:10 0 E:11 1 ,

E:12 0 i

E:13 0 E:14 0 E:15 0 E:16 0 T:1 1 T:2 1 T:3 1 T:4 1 1:1 3 i 1:2 3 '

1:3 3 1:4 3 1:5 3 N:1 0 N:2 0 N;3 0 N:4 0 0:1 3 0:2 0 0:3 0 i O:4 0  !

0:5 0  !

I O:6 0 O:7 0 0:8 0 0:9 0 0:10 0 0:11 0 0:12 0 0:13 0 O:14 0 0:15 0 .

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3 ,; TABLE OF CONTENTS ADMINISTRATIVE CONTROL OF THE EAL 1ECHNICAL BASIS .. _ = A:1 1 3

4 GENERAL NOTES FOR EAL TECHNICAL BASIS . ,. ......... . .G:1 2 1 RADIOACI1VITY RRIRASE l RUI Unplanned R=Aanctive Release Exceeding 2 X Tech Spec Limits for AT LEAST j

60Mmutes.......................................................... .. ..R:1 .

RU2 U-=~~' Increase in Plant Ra&meion...... . .. . .... . -R 5 -

l 5

RU3 Potential Degradation of Containment of Dry Stored Spent Fuel . .. . _ R:7 RAI Unplannal Radioactive Release Exceeding 200 X Tech Spec Limits for AT LEAST l

15 Minutes. .............. . . . . . . . . . . . . .. ....... . .... R:9 l

RA2 Danuge OR 'Uncovery of Single Irradiated Fuel Asamnhly Outside the Reactor Vessel..R
13 l RA3 Raanhan Increases That Impede Safe Plant Operation.... ... .. .. ......... =R:15  !

RSI Off-Site Dose of AT LEAST 0.1 Rem (EDE + CEDE) Or 0.5 Rem CDE Thyroid..........R:18 -l 1 RG1 Off-Site Dose of AT LEAST 1 Rem (EDE + CEDE) Or 5 Rem CDE Thyroid. = R:22 i

, FISSION PRODUCT BARRIER DEGRADATION

BUl Loss OR Potential Loss of CNTMT Barder... .. .. ..... . . . . ... . .. .... .. B
1 i BU2 RCS Leakage .... .. . ..
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .... B
2 BU3 Fuel Clad Degradation ............. ... . . .. . .. . . .. .. B :4 ,

BAl 14ss OR Potential IAss of EITHER Fuel Clad Barrier OR RCS Barrier.. x B:6 l BS1 Loss Or Potential Loss of ANY Two Barriers........ . . . . . . . . . ... ....... B:7

BG1 Loss of Two Barricts AND Potential Loss of Third Barrier ; . .. .. ... .. B : 10 FUEL CLAD BARRIER EALL x . . . . . . . . . . . . . . . . . ...B:11 FCBI Safety Function Status / Functional Recovery __ .. ...B:12
FCB2 Temperature.... . .. . . . . .. . .. . ...B:14 1 FCB3 Radiation... .. . .. . . . . .. . . . . . ... B:15 i a

FCB4 Reactor Vessel Water Level, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... B:17  :

1 4 FCBS SEC Judgement: . .. . . . . . . . ...B:18 ,

i RCS BARRIER EALs .... .... ... . . . . . . . . . . . . . . . . . . . . . . . . . ...B:19 l l RCBI Safety Function Status / Functional Recovery.... . .. .. .. .. ... .. ....... B:20 RCB2 Temperature... .. . . . . . . . . . . . . . . . . . . , , . ... .. .... . . . .. B:2 2

. RCB3 Radiation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ..B:24 RCB4 Coolant Leakage . . .. ... . . .. . . . . . .. ... ..B:25

, RCBS SEC Judgement..... .. . . . . . . . . . . . . . . . . . . . . . . . . . B:27 CONTAINMENT BARRIER EALs . . . ..... . . . . . . . . . . . . . . . .. .... B:28 CNB1 Safety Function Status / Functional Recovery.. . .. .. .... . . . . . . ..B:29

CNB2 Temperature.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. B:30 CNB3 Radiation .... .. .... . . . . ... . ... ..... .. .. .. . . . . . .. B:3 2 1 CNB4 Coolant Leakage., . . . . . . . ................ . . . . . . . . . . . . . . ... .... .. B:3 4 j 4

CNB5 Pressure... . .... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ... B:36 l 1 CNB6 SEC Judgement ... .. ..B:38 l

EQUIPMENT FAILURE l QUI Unplanned Loss of Any Function Needed to Maintain Cold Shutdown....., .. . . ... Q:1 l QU2 Unplanned Loss of Most or All Safety System Annunciators for GREATER THAN 15 Minutes- ........... . . . .

. . .. Q:3 QU3 Unplanned Loss of All On-Site or Off-Site Communications Capabilities . .. . . .... Q:S QU4 Inability to Reach Required MODE Within Technical Specification Limits.. . .. .. .. Q:7 QAl Failure of Automatic Reactor Trip. .. .. .. . . . . . . . . . . . . . . . . . . . . . ... .

... .. Q:8 QA2 Inability to Maintain Plant in Cold Shutdown = . . . . . .. .. .. Q:10 QA3 Unplanned Loss of Safety System Annunciators With Transient in Progress.. . .. . .. Q:12 4 QA4 Station Blackout While Defueled .. . . .. Q:14 l QS1 Failure of BOTH Automatic AND Manual Reactor Trip.. .. .

.. Q:4415 i

QS2 Complete Loss ofFunction Needed to Achieve or Maintain Hot Shutdown.. . . . . . .. Q:4416 QS3 Loss of Water Level That Can Uncover Fuel in the Reactor Vessel..... . . . . . . . . ..Q:4718 QG1 Failure of BOTH Automatic AND Manual Reactor Trip -AND- Extreme Challenge to the Ability to Cool the Core... ... . . . . . . . . . .. .

. . ..Q:4920 Calvert Cliffs EAL Basis Document i Rev.3 4

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.. ADMINISTRATIVE CONTROL OF THE EAL TECHNICAL BASIS i Administrative revisions shall not change the intent of the Basis AND shall not cause a wording difference with ERPIP 3.0, Attachment 1.

IV.B. I .b. Administrative revisions shall be approved by the Director-Emergency j Planning.

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c. Administrative revisions approved by the Director-Emergency Planning will be distributed in accordance with PR-2-100, Document and Drawing Control.
2. Technical rnision. i
a. Technical revisions shall be reviewed by:

(1) Emergency Plan' ting ,

(2) Nuclear Operations (3) Operations Training (4) Chemistry Programs (5) Radiation Safety (6) Nuclear Engineering (7) Design Engineering (8) Nuclear Security (9) Licensing

b. The Emergency Planning reviewer will collect and reconcile review comments. Resiews will be documented on the Basis resiew/ approval sheet,
c. Technical revisions shall be approved by the Director-Emergency Planning. The Director will consider review comments and their reconciliation,
d. Technical revisions shall be submitted to POSRC and the Plant General Manager in accordance with NS-2-101, Conduct of the Plant Operations and Safety Review Committee / Procedure Review Committec/ Qualified Reviewer.
c. Technical revisions approved by the Plant General Manager shall be submitted to the NRC for information in accordance with CCI-154, Preparation of NRC Correspondence. This submittal shall specify that a revision to ERPIP 3.0, Attachment 1, Emergency Action Imels, to implement the B4 sis document change, will be processed in forty-five (45) days.
f. After action IV.B.2.e. is complete (i.e., the correspondence is mailed) then a revision to ERPIP 3.0,Immediate Actions, Attachment 1, Emergency Action Levels may be initiated in accordance with ERPIP 900, Preparation of Emergency Response Plan and Emergency Response Plan Implementation Procedures. U= i: =cind Sms.b krx :" tc i...x. =:: 1-: 6: :."=9c : : cf1:"h; h=mt beeneduoed (i.e., in: = =c'n', de EAL ::h;;; rn r: :: m:::

de ;; $ = "'- :- ' i: R.C. I 10!, mci:ic; 3)--The effective date Calvert Cliffs EAL Basis Document A:2 Rev.3

,, GENERAL N3TES FOR EAL TECHNICAL CASIS TaWe GJ: Casapartsen of NUMARC Guidelines to BGAE ICh NUMARC Systems MultlAnnetion Catemor7 Ennersency Class Generic NUMARC IC Calvert Cliffs IC Unusunt Event SUI . less of All OfInne Power to Easential Busses Eul . loss of Off-Site Power

, for Oreater 1han 15 Minutes SU2. Inabihty to Read Required Shutdown Wsthin QU4. Insinhty to Reach Required MODE Within Tedm. cal Specification limits Technical Specification IJmits SU3. Unplanned Loss of All Safety System QU2 Unplanned loss of Most or All Safety Sptem

?  : r .for Omatar Than 15 Minutes Annunciators for OREATER THAN 15 Minutes SU4. Fuel Clad Dearadataan HU3. Fuel Clad Dearadation SUS . RCS Imakame BU2. RCS Imakase SU6. Unplanned Imss of All Onaste or Offsne QU3. Unplanned Imes of All On-Sne or Off-Site Communications Capabilities Communications Capabilities SU7. Unplanned imes of Required DC Power EU2 Imes of Vaal125 Volt DC Power for During Cold Shutdown or Refueling Mode for OREATER TilAN 15 Minutes Greater 1han 15 Minutes Shutdown EAL not currently addreened by QUI Unplanned loss of Any Functaan Needed to NUMARC Maintain Cold Shutdown Alert 8 Al .1mes of All Offsne Power and Imss of All EA! . Station Bladout While on Shutdown Coohng Onsite AC Power During Cold Shutdown or QAd . Station Blackout Mhile Denseled Refueling Mode SA2. Failure of Reactor Protection System QAl - Failure of Automatic Reactor Trip Instrumentation to Complete or Initiate an Automatic Reactor Scram Once a Reactor Protectaan Systan Setpoint lias Been Exceeded and Manual Scram was Successful S A3. Inabihty to Maintain Ptarn in Cold Shutdown QA2. Inahitrty to Maintain Plant in Cold Shutdown l 8 A4. Unplanned less of Most or All Safety System QA3 Unplanned Imas of Safety System Annunciation or Indication in Control Rres s With A-ha With Trarmient in Progrees Either (1) a Significant Transient in Prorees or (2)

Compensatory Non-Alarming Indicators r e Unavailable SA5. AC Power Capabihty to lasern.at Buance EA2.Only One AC Power Source Available to Reduced to a Single Power Source for Orcater Than Supply 4LV Emergency Buses 15 Minutes Such1 hat Any Additional Single Failure Would Result in Station Blackout Site Emergency SSI .1 mss of All Offsite Power and Ims of All ESI . Station Blackout Onsite AC Power to Essential thannes SS2. Failure of Reactor Protection System QSI . Failure of BOTil Automatic AND Manual Instrumentation to Complete or initiate an Automatic Reactor Trip Reactor Scram Once a Reactor Protection System Setpoint IIan Deen Exceeded and Manual Saam Was NOT Successful SS3 Imma of All Vatal DC Power EA3 1 mas of125 Volt DC Power and Reactor Trip ES2. loss of All 125 Volt DC Buses Site Emergency SS4. Complete Ims of Function Needed to Achieve QS2 CompleteIms:ofFunction Neededto Achieve w Maintain HM Shutdan a Maintain HM Shutdan (Continoed)

SSS Loss of Water level 1 hat flas or Will Uncover QS3 Imss of Water level 1 hat Can Uncover Fuel in Fuel in the Reactor Vessel the Reactor Vessel SS6. inabihty to Monitor a Significant Transient in ES2 1 Ass of All125 Volt DC Buses Progress General Emergency 801 Prolonged Ims of All Off Sne Power and EGI Prolonged Station Blackout Prolonged imme of All On-Site AC Power 802. Failure of the Reactor Protection System and QOX Failure of BOTil Automatic AND Manual Manual Saam was NOT Successful and There is Reactor Trip .AND- Extreme Challenge to the Ability Indication of an Extreme Challenge to the Ability to to Cool the Core Cool the Core Calvert ClifrS EAL Ba$is Document G:8 Rev.3

m2.A,- A . e4 4,-a, a & - J. -.M=.d.4 m. .h.: m --= , Jim-, .ta- e ,e 3s s _a ..i *_;e,.i.,* mi -

EQUIPMENT FAILURE 1

i j Emmereency Classification Level: ALERT

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i i Anelle.able Operational Modes: DEFUELED l, a

Calveri Cliffs Initiatian Condition
QA4 Station Blackout While Defueled NUMARC Recomaltion Catemory: System Malfumetloa '

NUMARC Initiatian Condition:

! SAI IAss of All Off46te Power and IAss of All On-Site AC Power to Essential Busses During Cold Shutdows Or Refueling Mode l

Barrier
Not Applicable i

] NUMARC Generic Basis:

IAns cf all AC power compromises all plant safety systeams requiring electric power including RHR, ECCS, j Costalement Heat Removal, Spent Fuel Heat Resnoval and the Ultimate Heat Sink. When la cold shutdown, refueling, or defueled anode the event can be classified as an Alert because of the significantly reduced decay heat, lower tesaperature and pressure,lacresslag the time to rectort one of the essergency busses, relative to the? specified

. for the Site Eanergency EAL. Escalating to Site <E>anergency, if appropriate, is by < Radioactivity Pale == or SEC>

{ Judgensent ICs. Fifteen minutes was selected as a threshold to esclude transient or momentary power losses.

Plant-Snecific Information

i Of concerm during defueled conditions is the loss of Spent Fuel Fool cooling. If either Unit has fuel la its reactor vessel them a Site Esmergency or Alert will be declared under Initiating Condition ES1 and EA1 respectively for loss of all off-site power and loss of all on-site AC power to essential busses. His Initiating Condition (QA4) applies whem j- both Units are defueled. When defueled, contingency plans are implemented for Spent Fuel Pool cooling raalfunction

, regardless of the reason. Contingency plans are implemented concurrent with the problem recognition to restore power. To esclude declarations because of transients or momentary power losses, the temperature threshold of

. 155'F was selected. Temperature at this level (design tesaperature for the system) is a more appropriate indication that the loss of cooling and inability to restore it art an Alert level thetat.

Thus, the EAL is written as:

l Power to Spent Fuel Cooling Pumps lost AND Spent Fuel Fool temperature increases to greater than

155'F.

l

! Source Documents / References / Calculations:

1. Abnormal Operating Procedures AOP-38, Absonnal Shutdown Cooling AOP-6F, Spent Fuel Pool Cooling System Malfunctions
2. UFSAR, Chapter 9.4, Spent Fuel Pool Cooling System
Calvert Cliffs EAL Basis Docun.cnt Q
14 Rev.3 j

EQUIPMENI FM

! Emurgency Classification Imel SITE EMERGENCY ApplicableOpenmanalModes I,2 -

Cahert ChifsInitiating Can& tion- L 4 QS1 Failure of BOTH A=ta===*Ae AND lbsammal Reactor Trip' ,

i NUMARC Racognition Catamory-. SystemMalfunction

. NUMARCInitiating Candition-  !

SS2 Failure of Reactor Pratar*ian System Instrumanemhan to Complete or Initiate on Automatic Reactor Scram Once a Reactor Prasartia= System Setpolat Has Been F-tad and Manual Scram Was N(Fr Successful -

BMIig; Not Applicable j l NUMARC Generic Basis- i Automatic and manual scrams are not considered successful if action away from the reactor control console was required to

, scram the reactor.  !

Under these conditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed. . A Site <E>mergency is indicated because conditions exist that lead to imminent loss or potential loss of both  !

ibel clad and RCS. Although this IC may be viewed as rednadmat to the Fission Product Barner Degradation IC, its ,

inclusion is -ey to better assure timely recognition and emergency response. Escalation of this event to a General

!' Emergency would be via Fission Product Barrier Degradation or <SEC Judgement > ICs.

Plant-SoecificInformation-

EOP-0, Post-Trip Immediate Actions, are described under IC QAl, Failure of Automatic Reactor Trip. As stated under QA1, entry into the Alert ernergency classification occars whenever it is determined by the ShiA Supervisor that a required ,

1 automatic reactor trip did not occur, based op the entry conditions into EOP-0. Entry into the Site Emergency is made consistent with EOP4 procedural requirements and so cos.+,ds to g satisfying the reactivity control criteria of EOP 0.

'Ihis means that both automatic and manual actions were g effective in bringing the reactor suberitical and that entry into

' EOP4, Functional Recovery Procedure,is required.

a

! Thus, the EAL is written as:

i EOP-8, Fumetional Recovery Prueedore, is Implemented per EOP-0, Post Trip Immediate Actions, i e Reactivity Control j l Carr NOT is used hacanna the ability to meet the final =E-p= + criteria is the appropriate concern, not whether ,

4 intermediate &= criteria are not being achieved at one point in time.

i i Source Documents / References / Calculations-

1. Emergency Operating Procedures

]

  • EOP4, Post Trip Immediate Actions EOP-8, Functional Recovery Procedure

. +

Calvert Cliffs EAL Basis Document Q:15 Rev. 3 1

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.. EQUIPMENT FAILURE J

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Emergency Classincation Imvel SITE EMERGENCY  ;

Applicable Operational Modes 1,2,3,4  ;

Calven CidfsInitiating Condition-  ;

j QS2 Complete Iass of Function Needed to Achieve or Maintain Hot Shutdown l j NUMARC Rscognition Cateqinev: System Malfunction

[ NUMARC Initiating Candition-  ;

i SS4 Complete Less of Function Needed to Achieve or Mamtsin Hot Shutdown f 1

Barrier: Not Applicabic j NUMARC GenericBasis- -l 4 This <IC and its manaci=*~1 Generic EAI> address complete loss of functions, including ultimate heat sink and reactivity I control, required for hot shutdown with the reactor at pressure and temperature. Under these conditions, there is an actual

audor failure of a system intended for protection of the public. Thus, declaration of a Site <E>mergency is warranted.

j Rar=1= tion to General Emergency would be via < Radioactivity Release, Fission Product Bamer Degradation, or SEC

j. Judgement > ICs.

3 Multi-unit stations with shared safety functions should further consider how this IC may affect more than one unit and how

this may be a factor in escalating the emergency class.

Plant-Specific Information Per Calvert Cliffs Technical Specifk:ations, the following functions are required to be operable during Cold Shutdown and Refueling modes and are necessary to maintain Hot Shutdown (Mode 4) conditions (temperature, pressure, and .

subcriticality): I Reactivity Control Systems (TS 3.1).

Coolant Loops and Coolant Circulation (TS 3.4.1,3.9.8)

Safety Valves (TS 3.4.2)

On-Site Power Sources (TS 3.8)

AC and DC power systems availability are separately addressed under the Loss of Power Event Category. Thus, these are not addressed under this Initiating Condition. The Overpressure Protection System and Reactor Coolant System Vents are not directly related to core cooling and subcriticality functions. Failures of these systems functions resulting are addressed ,

j by Fission Product Barrier Degradation ICs. Loss of Monitoring Instrumentation is not directly related to maintaining .

~ subcriticality and heat removal functions, and therefore is not required to be addressed by this IC.

! i Per AOP-3B, Abnormal Shutdown Cooling Conditions, auxiliary feedwater and atmospheric steam dump capability to at least one SG is necessary to achieve Hot Shutdown conditions under natural circulation conditions. Around the transition from Mode 3 to Mode 4, the Shutdown Cooling System (SDCS) is typically used as the means to remove sensible and decay 1

i

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Calvert Cliffs EAL Basis Document - Q:16 Rev.3 .

.' EQUIPMENT FAILURE heat. Once the SDCS is placed in service, the steam generator heat sink capability is no longer necessary. Thus, the EAL roGects that neither the steam generators nor Shutdown Cooling are fully capable of performing heat removal functions.

De applicable ar-f== criteria for Core and RCS Heat Removal are shown on the Safety Function Status Checks and are fully explained under the basis information for EAL FCB1, Safety Function Status / Functional Recovery.

Per Technical Specification Table 1.1, Operational Modes, the required SDM is K e gtl ess than 0.99 for Mode 4 (Hot Shutdown). De existence of a positive startup rate that could not be eliminated by operation of any reactivity control

. mechanism corresponds to conditions where. a mador function intended for the protection of the public has failed and therefore meets the threshold for a Site Emergency classification.

4 Thus, EAL 1 is written as:

EOP-8, Functional Recovery Prweedere, is Implemented AND EITHER of the Following:

+ Reactivity Control Ar-p== Criteria Can NOT Be Met

+ Shutdown Cooling is NOT In Service AND Core and RCS Heat Removal Amp *== Criteria Can NOT Be Met j Can NOT is used because the ability to meet the final acceptence criteria is the appropriate concern, not whether intermediate acceptance criteria are not being achieved at one point in time.

In service means that the SDCS is in the proper configuration for RCS heat removal (SDCS isolation valves open, LPSI pumps operating, etc.) and is considered " operable" as defined in the Calvert Cliffs Technical Specifications Section 1.6.

l In order for there to be a path for heat removal between the core and the steam generators or the shutdown cooling system,

, there must be enough RCS liquid imentory to maintain natural circulation. Recent information from the CE Owners Group indicates that two-phase natural circulation (reflux boiling) works very well and will maintain the RCS between 200 'F and 300 'F. This requires that the RCS water level be below the top of the hot legs. Per AOP-3B, Attachment 14,50" RVLMS

. Indication corresponds to the middle of the hot leg and is the 5th RVLMS alarm level. Staying above this level (and below the top of the hot legs at the 71" level) assures that, at a minimum, reflux boiling can be maintained.

Hus, EAL 2 is written as:

3 Zero (0) Indicated Subcooling Margin Determined Using CET Temperatures AND Valid RVLMS Level Indication ofLESS THAN 50 Inches 4

l Source Documents / References / Calculations:

1. TechnicalSpecifications
2. Abnormal Operating Procedures
4. Internal Memorandum, J. R. Ilill to R. L. Wenderlich, CE Operations Subcommittee Meeting - Trip Repo 1, April 16, 1993 Calvert Cliffs EAL Basis Document Q:17 Rev.3 4
  • c i r ' - EQN FN i

Panergency C8===&=84- Level: SITE EMERGENCY  ;

l ApplicableOperationalModes 5,6 Calvert Chifs Initiating Condition-i IAss of Water I.Avel That Can Uacover Fuel in the Reactor Vessel i QS3 NUMARCInitiating Condition-t

~

SS$14ss of Water Level in the Reactor Vessel That Has or Will Uncover Fuel in the Reactor Vessel  ;

i Bagdat: PUEL CLAD i 4

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3. NUMARC Generic Basis Under the conditions specified by this IC, severe core damage can occur and reactor coolant system pressure boundary integrity may not be assured. <> For PWRs, this IC covers sequences such as prolonged boiling following loss of decay heat ,

[ removal.  ;

, Thus, declaration of a Site <E>mergency is warranted under the conditions specified by the IC, Farmlation to a General Emergency is via < Radioactivity Release IC RG1, Off Site Dose of AT LEAST 1 REM (EDE+ CEDE) Whole Body or 5 ,

l REM (CDE) Thyroid >.

Plant-Specific Information-Sequences that can result in uncovery of fuel in the stactor vessel (indirectly by prolonged boiling) include leakage through

. SG nozzle dams, pipe breaks in the Shutdown Cooling (SDC) System or Chemical & Volume Control System (CVCS), or loss of the SDC function. These leakage sources are outside the reactor vessel and at most could only result in water level  ;

decreases to the bottom of the hot leg elevation. This water level decrease would cause loss of SDC suction. In-core

instrumentation (ICI) penetrations for Calvert Cliffs are through the vessel head. Thus, these do not have to be considered for this IC.

h "

A review of attachments to AOP-3B, Abnormal Shutdown Cooling Conditions, shows that depending on previous power history and assuming an initial RCS temperature of 140*F, boiling in the core can begin in as little as 7 minutes following loss of SDC during mid-loop operation. AOP-3B also shows that under these conditions, without any operator action, core uncovery can begin within about 80 minutes aAct loss of SDC.

Available methods to restore RCS inventory and to remove core hea't include restoring the SDCS, icjecting into the RCS from the Refueling Water Tank (RWT) using the HPSI, LPSI, CS or charging pumps, using the steam generators as a heat sink, using the Refueling Pool as a heat sink, aligning a LPSI pump to take suction from the RWT, or even i Qecting into l the RCS using Safety Injection Tanks (SITS). Given the number ofmethods to restore inventory, and the amount of time

, available, it is highly unlikely that this JC will be entered.

Thus, the FAL is written as:

AOP-3B, Absorunal Shutdown Cooling. Conditions, Is Implemented AND ANY of the Following Conditions Exist
' * ' Alternate Methods for Restoring RCS Inventory Are NOT Effective Valid RVLMS Reading Indicating 0% I.evel 4
  • Valid CET Reading Indicating Superheat Conditions t'

Cahert Cliffs EAL Basis Document Q:18 Rev.3 i

EQUIPMENT FAILURE NOT Egective means that inventory is not being restored based on available operable instrumentation readings such as CETs, RVLMS, Hot hg Level, or from decreasing level indications from applicabic suction sources such as the RWT, containment sump, or SITS.

Valid means that the indication is from instrumentation determined to be operab'e l in accordance with the Technical W6emtions or has been verified by other independent methods such as indications displayed on the control panels, reports from plant personnel, or radiological survey results. For example, under conditions where the CETs and the PNLMS are disconnected to allow reactor vessel head removal, these instrument readings would not be valid.

Source Documents / References / Calculations

1. AbnormalOperatingProcedures AOP 3B, Abnormal Shutdown Cooling Conditions l

1 l

Calvert Cliffs EAL Basis Document Q:19 Rev.3

7 .

.i*** EQUIPMENT FAILURE 4

Paargency Classincation Level GENERAL EMERGENCY l ApplicableOperationalMadas 1 Calvert Cliffs Initiating Condition-QG1 Fallare af BOTH A*-anie AND Mannal Reactor Trip -AND-Estreme Challeep to the Ability to Cool the Core i NUMARC Racognition Category. System Malfunction l NUMARCInitiating Condition-f J

'802 - Failure of the Reactor Pmtection Systern to Complete an Automatic Scram and Manual Scram was NOT Successhd ,

4

- and There is Indic=alam of an Extreme Challenge to the Ability to Cool the Core l Barriar. Not Applicable  ;

i NUMARC Ganaric Basis:

Automatic and manual scrams are not considered successful if action away from the reactor control console is required to j scram the reactor, i i

4 Under the conditions of this IC and its maeariated < Generic > EAL, the efforts to bring the reactor suberitical have been

~'

=====41 and, as a result, the reactor is producing more heat than the maximum decay heat load for which the safety.

t systems were designed. Although there are capabilities away from the reactor control console, such as emergency boration,

o the continuing temperature rise indicates that these capabilities are not effective. This situation could be a y,wo-i for

, . a core melt sequence.  ;

For PWRs, the extreme challenge to the ability to cool the core is intended to mean that the core exit temperatures are at or .

, approaching 1200*F or that the reactor vessel water level is below the top of the active fuel, o

  • Another consideration is the inability to initially remove fut during the early stages of this sequence. For PWRs, if  ;

emergency feedwater flow is insufficient to remove the amount of heat required by design from at least one steam generator,  ;

. an extreme challenge should be considered to exist. o

! 13 the event either of these challenges exist at a time that the reactor has not been brought below the power associated with the safety system design (typically 3% to 5% power), a core melt sequence exists. In this situation, core degradation can ,

i. occur rapidly. For this reason, the General Emergency declaration is intended to be anticipatory of the fission product .l l barrier matrix declaration to permit maximum offsite intervention time.

I Plant SpecificInformation- -

EOP-0, Post-Trip Immediate Actions, are described under IC QAl, Failure of Automatic Reactor Trip. As stated under  ;

. QS1, entry into the Site Emergency classification means that both automatic and manual reactor trip were net effective in  ;

bringing the reactor subcritical and that functional recovery of reacthity control is required in accordance with EOP-8.

Ranalation to the General Emergency is indicated whenever Reactor power is Egi decreasing following actions to bring the reactor subcritical including automatic and manual' reactor trip, manually inserting the control rods, tripping the CEDM motor generator sets or performing emergency boration and there are indications of inadequate core cooling.

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- Calvert Clifth EAL Basis Document Q:20 Rev.3 .

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EQUIPMENT FAILURE Thus, the EAL is written as:

EOP-8, Functional Recovery Procedure, is Implemented AND Both of the Following:

  • Reactivity Control Can NOT Meet Acceptance Criteria AND

+ Core and RCS Heat Removal Can NOT Meet Acceptance Criteria Can NOT is used because the ability to meet the final =~*pe== criteria is the appropriate concern, not whether intermediate Wa= criteria are not being achieved at any given moment.

Source Domments/ References / Calculations:

1. Emergency Operating Procedures

+ EOP-0, Post-TripImmediate Actions

+ EOP-8, Functional Recovery Procedure J

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2 1

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Calvert Clitis EAL Basis Document Q:21 Rev.3

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- ** ' ELECTRICAL EmergencyClassificationImni ALERT ApplicableOperahonalModes 5,6 Calvert Chirs Iniustina Condition-EAR' Station Blackout While On Shatdown Cooling NUMARC Recognidon Category: System Malfunction NUMARC Initiating Condition-sal Loss of All Off-Site Power and Ims of All On-Site AC Power to Ramanrial Busem During Cold Shutdown Or Refueling Mode Barrier: Not Applicable NUMARC Generic Basis- l 1hes of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal, Spent Fuel Heat Removal and the Ultimate Heat Sink. When in cold shutdown, refueling, or defueled mode the event can be classified as an Alert because of the significantly reduced decay heat, lower 4.wre and pressure, increasing the time to restore one of the emergency bum relative to that specified for the Site Emergency EAL. Escalating to Site <E>mergency, if appropnate, is by < Radioactivity Release or SEC> Judgement ICs. Fificen minutes was selected as a threshold to exclude transient or momentary power losses.

Plant-Specific Information- i AOP-3B is the procedure entered in modes 5 and 6 for a loss of shutdown cooling regardless of the initiating fault. This procedure is implemented concurrent with problem recognition.Section IX of AOP-3B provides the procedural steps for  ;

restoration of electrical power to the 4kV power supplies. These are the safety related buses that prmide power to the pumps used for shutdown cooling. This EAL addresses Station Blackout conditions during cold shutdown or refueling.

For Station Blackout while defueled, see Initiating Condition QA4, Station Blackout while defueled.

Thus. the EAL is written as:

AOP-3B, Abnorunal Shutdown Cooling. is Implemented Due to Loss of 4 kV Power Supplies For GREATER THAN 15 Minutes Source D&=e==/Referaaca=/C=1cn1=*ians:

1. AbnormalOperating Procedures I AOP-3B, Abnormal Shutdown Cooling L

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1-l Calvert Cliffs EAL Basis Document E:7 Rev.3

4

..** FIRE Eaisi.cv Classification Level: UNUSUAL EVENT ApplicableOperationalModes ALL  !

Calvert Cliffs Initiatine Condition:

IU1 Fire Withis Pawtected Area Boundary Not Estlaguished Within 15 Minutes of Deteetlom NLlhfARC Recoenition Catenory: Hazards and Other Conditions Affecting Plant Safety i NUMARC Initiating Condition:

HU2 Fire Within Protected Area Boundary Not Extinguished Within 15 Minutes of Detection Barrier: Not Applicable NUMARC Generic Basis: ,

The purpose of this IC is to address the magnitude and extent of fires that may be potentially significant precursors to ,

damage to safety systems. This excludes such items as fires within administration buildings, waste-basket fires, and other small fires of no safety mnacquence. This IC applies to buildings and areas contiguous to plant vital areas or other 4 e'gnificant buildings or areas. The intent of this IC is not to include buildings (i.e., warehouses) or areas that are not contiguous or immediately adjacent to plant vital areas. Verification of the alarm in this context means those actions taken in the control room to determine that the control room alarm is not spurious.

.l Escalation to a higher emergency class is by IC <IAl, Fire or Explosion Affecting Safe Shutdown >. <>

Plant-Snecific Infonnation:

Calvert Cliffs EAL is based directly on NUMARC.

"--t C&:M C!i.T: =i' --- 1: .^1r:- ' Cp::'! ; Parfr= (AOP) 9A 1::;gh ?S :: "u f.:= widh 1: fr' ,

p :^.:? ' =d -it! := 10: =: '; n!r'r x r- hrr 1:y centin quip =: :q;!::d f= d dr$ n. Fir; in 1: C=:::! R== HVAC Recr :=j !rd :: p;r Sing !=: :: 1: -h:- .= duo =. ;n=b. T!=:, i: C=:::1 R=: .

HVAC R== ("== 512) h= 5:-- -f &f :: 1: ==4 ==:= f= =r: 6:$2-i 1

4 Calvert Cliffs EAL Basis Document I:1 Rev.3

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  • l l

, . ' ' FIRE I

Arees != C=:=: != S:!: Sb ' :::

e C
-t=! R::-  : "!r-i=' P:=:=1!= R:: z
C:: :=' R::r HVAC Reom  : ^ ; !!! . j F=d:::= P;r; Reem
Cf!: Sp.  ; P::--  : Chrging P ; R=2: I
Cf': C' -- -  : D!---! C:- :: Prr
S:"?;--Room  : Pf=!!:; W: r Tri-(RWF)44(20
ECCS S- ; P:-  : C: ---" S::=;: Tri (CST) 12
E=ci:: W::= P ; R=-  : Par--"' W:: S::=;: Tri ("WST) !!(21)
C: -_;:-- : Cr" ; P ; Prr  : F=' Oi! S:: g: Tri ("OST) 12  ;

e " '- P -- P: :: ::!= R=x Time-lost c' S': E'"-  ; . =: i: --!:y:d : 1: EAL Td':: :: rr= i-: !! := : '-"I :: S':

Shuklewnese-: r!f d ' j de SEC.

Visible smoke is sufficient to conclude that a fire exists. Flames do not have to exist. Oder by itself does not  ;

constitute a fire. '

A fire is extinguished when the Fire Brigade Leader determines that active combustion has ceased and there is no ,

immediate danger of the fire spreading. l l

! Thus, the EAL is written as:

l Pi= W P 2- ^ : Ar= C :"2 2 ; S:!: Str'f=- E;;b==: L= ! ;41REATER THAN 15 M ::=..

. l Fire in/ involving any of the below listed areas, that is not extinguished within 15 minutes of Control Room notification or receipt of a 1C248, Fire System Control Panel, alarm for fire detection and fire suppression system actuation.

  • Auxiliary Building e Hydrogen Storage Tanks e Containment
  • Intake Structure e Containment Butler Bldg.
  • ISFSIProtected Area e Containment Emergency Air
  • Main station & service station transformers l Lock Vestibule
  • North Service Bldg.12 foot elevation I e Diesel Generator rooms.
  • Diesel Generator Bldgs. (0C/1A) e Turbine Building
  • Fire Pump House . 13KV Switchgear houses e FucI Oil Storage Tanks e 13KV Voltage Regulators Source Documents / References / Calculations:

1

^

! .12:n=' Oprating P::::dares I

" OP 9A t';:=gh 9S, A!:==:: S f: SS t':-WCO : 0! Rec = Ev==tica p :::i= :ri=

l 1.2: Issue Report IRO-012603, Fire in Room 512...,10-23-92

2. April 28,1995 letter, T. E. Forgette to Emergency Planning Unit file 9.5, st: April 14,1995 fire in Unit 2 Auxiliary Building, five foot elevation, fan room.
3. Issue Report IR0-004-422 (AIT IR199502146), failure to declare Alert in exercise for fire / explosion.
4. EPU file 4.14, EALs; June 30, 1993 letter: " Methodology for Development of Emergency Action Levels",

NUMARC/NESP-007, Revision 2, Questions and Answers, June 1993, Ilazards and Other Conditions Affecting Plant Safety, question 7, page 22. .

Cahert Cliffs EAL Basis Document I:2 Rev.3 1

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.'* FIRE Emergency Classincation Level ALERT AnplicabicOperationalModes ALL j Calvert Chffs Initiating Condition-i IA1 Fire or Explosion Affecting Safe Shutdown i

NUMARC Recognition Catcaory Hazards and Other Conditions Affecting Plant Safety  ;

NUMARCInitiating Condition-HA2 Fire or Explosion Affecting the Operability of Plant Safety Systems Required to Establish or Maintain Safe 4 Shutdown BudcI: Not Applicable NUMARC Generic Basis (Site-speciAc) Areas containing functions and systems required for the safe shutdown of the plant should be specified. (Site-  !

J Specific) Safe Shutdown Analysis should be consulted for equipment and plant areas required for the applicable mode. This l will make it easier to determine if the fire or explosion is potentially affecting one or more trains of safety systems. )

Escalation to a higher emergency class, if appropriate, will be based on < Equipment Failure, Electrical, Fission Product Barrier Degradation, Radioactivity Release, or SEC Judgement ICs>. <>

With regard to explosions, only those explosions of sufficient force to damage permanent structures or equipment required for safe operation within the identified plant area should be considered. As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to near by structures and materials. The inclusion of a " report of visible damage" should not be interpreted as mandating a lengthy damage assessment before classification. No attempt is made in this < Generic > EAL to assess the actual magnitude

, of the damage. The occurrence of the explosion with , reports of evidence of damage (e.g., deformation, scorching) is sufficient for the declaration. The declaration of an Alert and the activation of the TSC will proside the <SEC> with the resources needed to perform these damage assessments. The <SEC) also needs to consider any security aspects of the explosions,if applicable.

Plant Soecific Information:

Each Calvert Cliffs unit uses the Abnormal Operating Procedures (AOP) 9A through 9S to address fires within the plant protected and vital areas that are of particular concern because they contain equipment required for safe shutdown.  :

Ihere are two ladependent clocks for determining the magnitude of a fire based on time. One clock starts when a l

, fire is detected. For practical purposes a fire is detected when the report of the fire is received in the Control Room.  ;

! Report of a fire may be by Control Room fire alarm or by voice message. A fire alarm refers to IC24B, Fire System 1 1

Control Panel, for fire detection and fire suppression system actuation. Fire pump running and trouble alarms by themselves do not constitute a report of a fire. This clock includes: the time it takes to confirm or verify the fire report, pins the response team assembly time, plus the time it takes the responders to establish a fire fighting strategy, plus the time it takes to tsctually extinguish the fire.

Th_ut, the EAL 1 is written as:

Fire in an Area of Concern for er Exp!::!:: .^."r.!:;; $: .^3 E:y t: .^.d!= Or M:!: ch Safe Shutdown that is not extinaulshed within 30 minutes of its detection.

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Cahert Cliffs EAL Basis Document I
3 Rev.3 ,

( ,,'.*** FIRE Visible sanoke is safficient to conclude that a fire exists. Flames do not have to exist. Oder by itself does not constitate a fire.

A fire is extingelshed when the Fire Brigade leader deteranimes that active combustion has ceased and there is no leasediate danger of the fire spreading.

The other clock for determaining the magnitude of a fire is the tiene it takes to extinguish the fire. This clock begias when the first extlagaishing agent is applied to the fire.

'fims, EAL 2 is written as:

Fire la an Ana of Concera for Safe Shutdom u that is not entisemished within 15 minutes of the first entlessleblem asent being applied.

This EAL accomets for situations where the tiene to validate and respond to the fire is short.

, EAL 3 is written as:

l l Explosion la an Area of Concers for Safe Shutdown. l An explasion is a rapid, violent, unconfined combustion, a catastrophic failure of pitssurized equipment, or a violent electric arc, of sufficient force to potentially damage equipment, structures or components.

6- tb S= b c,y"uff. ; ebili:y :: r"m = - *- ' ::' 'n't- k 6:=-!:d by phy:' '

oW' . = ' j C .! P:::tr!-cont;;! :';;ic i S:t- . C: c:Sn O' '----- :: :y;;;;; ? :!f S 1: ' ::

" '- '- L. __. : --j:: S= rf .-!:= 5:= :: S:= i: x 'ni;; ; ':: ,.. :* "'!!y of :"--'!:;; :-/: 6"t- Fr r ;':. "': "AL k ::' :: ;:::M :: b; - '--d f=-isolatod-breaker = :":- 5:=. O,n=t!'!:y t'- '-- r r: :::

,. :f; t: _t '-- ^' n ef t": =:::basedh Fire and/or explosion in the Control Room HVAC Room may lead to power being lost to the alternate shutdown panels.

Thus, the Control Room HVAC Room (Room 512) has been added to the areas of concern for safe shutdown. The list of r.reas of concern for Safe Shutdown are shown below and are prominently displayed on the EAL Table.

Areas of Concern for Safe Shutdown

+ Control Room

  • Electrical Penetration Rooms a Control Room HVAC Room + Auxiliary Feedwater Pump Room a Cable Spreading Room + Charging Pump Rooms
  • Cable Chases
  • Diesel Generator Rooms
  • Switchgear Room
  • Refueling Water Tank (RWT) 11(21)

= ECCS Pump Room . Condensate Storage Tank (CST) 12

  • Pretreated Water Storage Tank (PWST) 11(21)
  • Component Cooling Pump Room + Fuel Oil Storage Tank (FOST) 21 M l

The significance of these EALs is not that safety systems have been degraded. What is significant is that a fist of such magnitude that it can act be extinguished in the times specified exists la na area of concern for safe shutdown.

Likewise, an explosion is significant because it occurred in an area of concern for safe shutdown, not because it degraded safety systems.

d Calvert Cliffs EAL Basis Document I:4 Rev.3 i

.  ;.** FIRE Source Documents /ReferencevCalculations

1. Abnormal Operating Procedures
2. Issue Report IRO-012603, Fire in Room $12...,10-23-92 i
3. April 28,1995 letter, T. E. Forgette to Ennergency Planning Unit file 9.5, re: April 14,1995 fire la Unit 2 Auxiliary Building, five foot elevation, fan room.

, 4. Issue Report IRO-004-422 (AIT IR199502146), failure to declare Alert la esertise for firt/ explosion.

5. EPU file 4.14, EAla; June 30,1993 letter: " Methodology for Developuneet of Emergency Action Levels",

NUMARC/NESP-407, Revision 2 Questions and Answers, June 1993; Hazards and Other Conditions Affecting Plant Safety, questlos 13, pay 24.

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9 Calvert Cliffs EAL Basis Document I:5 Rev.3 l

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. . ,-- . . - ~ . .. - . - . - . - . ~ . . . . . - . . . - - - - .

r,3 .*

)

...," CTHER BAEARDS l 4 f Emergency Classifkation Level. UNUSUAL EVENT ApplicableOperationalModes ALL

!? Calvest Chirs Initiating Condition.

i CU1 SEC Judgement

NUMARC Racognitien Cateparv
Hazards and Other Conditions Affecting Plant Safety
  • l NUMARCIr.itiating Condition: l 3

HUS Other Conditions Existing Which in the Judgement of the Emergency Director Warrant Declaration of an Unusual j 4

Event ,

Barrier: Not Applicable l f NUMARC Generic Basis-

, 'this.<Genenc> EAL is intended to address unanMpated conditions not addressed explicitly cisewhere but that warrant l

declaration of an emergency because conditions exist which are believed by the <SEC> to fall under the Unusual Event l
. emergency class.

4 t From a broad i,r .,, ive, one area that may warrant <SEC> Judgernent is related to likely or actual breakdown of site l specific event mitigating actions Framples to consider include inadequate emergency response procedures, transient t response either unexpected or not understood, failure or unavailability of emergency systems during an accident in excess of ,

i that assumed in accident analysis, or insufficient availability of equipment and/or support personnel.

?  !

Specific examples of actual events that may require <SEC> judgement for Unusual Event declaration are listed here for  !

, consideration However, this list is by no means all inclusive and is not intended to limit the discreten of the site to provide ihrther examples.  ;

  • Aircraft crash on-site

= Train derailment on-site 4

= Near-site explosion which may advemely affect normal site activities. .  !

= Near-site release of toxic or flammagle gas which may adversely affect normal site activities '

= Uncontrolled RCS cooldown due to Secondary Depressurization j it is also intended that the <SEC's> judgement not be limited by any list of events as defined here or as augmented by the site. This list is provided solely as examples for consideration and it is recognized that actual events may not always follow  !

a pre conceived description.

j Baal:SagstlicInicrmation-A Site Emergency Coordinator (SEC) is the title for the emergency director function at Calvert Cliffs. Thus, the EAL is written as:

Any Condition Which in the SEC's Judgemeent Indicates Potential Degradation in the 14 vel of Safety of the Plant 4

j.'

1 la this manner, the EAL addresses conditions that fall under the Notification of Unusual Event emergency classification description contained in NUREG-0654, Appendix 1 that is retained under the NUMARC methodology.

1 Calvert Cliffs EAL Basis Document O:1 Rev.3

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