ML20211L132

EAL Basis Document

ML20211L132
Person / Time
Site:	Crystal River
Issue date:	08/31/1999
From:	FLORIDA POWER CORP.
To:
Shared Package
ML20211L113	List: 3F0899-23, Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals ML20211L132
References
NUDOCS 9909080157
Download: ML20211L132 (92)

Text

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FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72

- ATTACHMENT B TO LETTER 3F0899-23 CRYSTAL RIVER UNIT 3 EMERGENCY ACTION LEVEL BASIS DOCUMENT AUGUST 1999

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m EMERGENCY ACTION LEVEL BASIS DOCUMENT TABLE OF CONTENTS ABNORMAL RAD LEVElliRADIOLOGICAL EFFLUENT..................................... 1 Gaseous Effluents Liquid Efiluents Unexpected Radiation Levels Fuel Handling / Fuel Handling Pool Water Level NATURAI/ MAN-MADE HAZARDS AND EC JUDGMENT.................................... 14 Earthquake Experienced Flood Hurricane Tornado /High Winds AircraftNehicle Crash Toxic or Flammable Gas Explosions / Catastrophic Pressurized Equipment Failure Fire Control Room Evacuation Security Event Internal Flooding Emergency Coordinator Judgment SYSTEM MALFUNCTI ON........................................................................................... 4 Loss of Communication Failure of Reactor Protection Inability to Reach Required Mode Within Improved Technical Specification Time Limits Loss ofIndications Fuel Clad Degradation Turbine Failure RCS Leakage Loss of Function (Hot Shutdown)

Inadvertent Criticality Inability to Maintain Plant in Cold Shutdown Loss of Water Level in Reactor Vessel that Has Uncovered or Will l

Uncover Fuel LO SS O F PO WE R....................................................................................................

Loss of AC Power l

Loss of AC Power (Shutdown)

Loss ofVital DC Power Loss of Vital DC Power (Shutdown)

FISSION PRODUCT BARRIER MATRIX BASIS.................................................... 71 D E FINITI O N S..........................................................................................................

l

Emergency Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Gaseous Effluents MODES: ALL Classification:

Unusual Event Initiating Condition:

An UNPLANNED release of gaseous radioactivity to the environment that exceeds 2 times the ODCM noble gas release setpoint for 60 minutes or longer Emergency Action Level:

(1 or 2)

1. A VALID reading on RM-Al or RM-A2 gas channel exceeds the UNUSUAL EVENT threshold value listed on the Radioactive Release Permit for 60 minutes or longer 9E

2. Sample analysis confirms gaseous effluent being released exceeds 2 times the ODCM noble gas release setpoint for 60 minutes or longer Basis:

The Unusual Event threshold value listed on the Release Permit represents 2 times the ODCM limit.

Releases in excess of 2 times the ODCM limits continuing for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose is not the primary concern here; it is the degradation in plant control implied by the fact the release was not isolated within 60 minutes. Therefore, it is not intended for the release to be averaged over 60 minutes. For example, a release of 4 times the ODCM for 30 minutes does not exceed this initiating condition. Further, the Emergency Coordinator should not wait until 60 minutes elapses, but declare the event as soon as it is determined the release duration will likely exceed 60 minutes. This is identified by an increasing trend in monitor readings. This does not include spikes or other erroneous instrument r:adouts.

CR-3 Matrix Reference Number:1.1 NEI 97-03

Reference:

AU1 1

l Em:rgency Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Gaseous Effluents J

- MODES: ALL I

1 Classification:

Alert

)

)

Initiating Condition:

An UNPLANNED release of gaseous radioactivity to the environment that exceeds 200 times the ODCM j

noble gas release setpoint for 15 minutes or longer Emergency Action Level:

(1 or 2)

1. A VALID reading on RM-Al or RM-A2 exceeds the ALERT threshold value listed on the Radioactive Release Permit for 15 minutes or longer

_O_ R

2. Sample analysis confirms gaseous effluent being released exceeds 200 times the ODCM noble gas release setpoint for 15 minutes or longer Basis:

The Alert threshold value listed on the Release Permit represents 200 times the ODCM limit. Unplanned releases in excess of 200 times the ODCM limits continuing for 15 minutes or longer represent an uncontrolled situation and hence, a potential substantial degradation in the level of safety. The primary concern for the time factor here is the loss of control of radioactive material allowing the release to continue. The Emergency Coordinator should not wait until 15 minutes elapses, but declare the event as soon as it is determined the release duration will likely exceed 15 minutes.

i CR-3 Matrix Reference Number:1.2 NEI 97-03

Reference:

AA1 l

\\

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e Emerg;:ncy Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Gaseous Effluents l

MODES:ALL j

Classification:

l Site Area Emergency l

Initiating Condition:

SITE BOUNDARY dose resulting from an actual or projected release of airborne radioactivity exceeding 100 mR TEDE or 500 mR Thyroid CDE Emergency Action Level:

(l or 2 or 3) l

1. VALID RM-Al or RM-A2 Mid-Range monitor reading exceeds the values on the following table for the current stability class for 15 minutes or longer:

I*

l Stability Class Monitor Reading (mR/hr)

I A, B, or C 80 D or E-20 l

F or G 5

SE

2. Dose Assessment results indicate SITE BOUNDARY dose >100 mR TEDE g >500 mR Thyroid CDE for the actual g projected duration of the release l

l OR 3 Field survey results indicate closed windows dose rates > 100mR/hr expected to continue for more than one hour; or analyses of field survey samples indicate thyroid CDE of 500mR for one hour of inhalation, at or beyond site boundary Basis:

A RM-Al or RM-A2 mid-range monitor reading indicated on the Table based on stability class would result in a Site Boundary Dose of >100 mR TEDE using conservative meteorology (1 m/see windspeed, G Stability class, no precipitation as outlined on the attached Table).

Source term for this EAL is based on RCS with 1% failed fuel per FSAR safety analysis.

3

Em:rgency Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Gaseous Effluents, continued Basis, continued The 100 mR integrated dose in this initiating condition is based on the 10 CFR 20 annual average population exposure. It is deemed exposures less than this are not consistent with the Site Area Emergency class description. These values are 10% of the EPA 400 Protective Action Guidelines (PAG).

Integrated doses are generally not monitored in real-time. In establishing the emergency action levels, a release of one hour is assumed, and the EALs are based on a site boundary dose of 100 mR TEDE or 500 mR Thyroid CDE, whichever is more limiting.

Classification for items 2 & 3 above result from emergency response team input. For example, the Environmental Survey Team provides actual dose rates which are used to determine dose for the projected duration of the release. The Dose Assessment Team provides projected dose.

CR-3 Matrix Reference Number:1.3 NEI 97-03

Reference:

AS1 l

l 4

- Em:rgency Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Gaseous Effluents MODES: ALL Classification:

General Emergency Initiating Condition:

SITE BOUNDARY dose resulting from an actual or projected release of gaseous radioactivity exceeding 1000 mR TEDE or 5000 mR Thyroid CDE Emergency Action Level:

(1 or 2 or 3)

1. Valid RM-Al or RM-A2 Mid-Range monitor reading exceeds the values on the table below for the current stability class for 15 minutes or longer:

I*

~

Stability Class Monitor Reading (mR/hr)

A, B, or C 800 D or E 200 F or G 50 OR l

2. Dose Assessment results indicate SITE BOUNDARY dose >1000 mR TEDE o_r >5000 mR Thyroid CDE for the actual or projected duration of the release and core damage is suspected or has occurred l

OR 3.

Field survey results indicate closed windows dose rates >1000mR/hr expected to continue for more than one l

hour; or analyses of field survey samples indicate thyroid CDE of 5000mR for one hour of inhalation, at or beyond site boundary Basis:

To cchieve the dose for this initiating condition, core damage with a failure of all the fission product b:;rriers is necessary. Based on FSAR isotopic distribution for accidents and very conservative 5vorst cr.n" meteorological data, PAG limits cannot be reached without some amount of fuel damage. In classifying this event, verifying that core damage is suspected or has occurred, precludes erroneous protective action recommendations based on incorrect or default dose assessments when plant conditions cl:arly do not support the magnitude of the release.

i 5

)

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Emergency Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Gaseous Effluents, continued Basis, continued 1

A RM-Al or RM-A2 mid-range monitor reading exceeding the values on the above Table would result in a

{

Site Boundary Dose of >1000 mR TEDE using conservative meteorology (1 m/see windspeed, G Stability j

class, no precipitation as outlined on the attached Table).

The 1000 mR TEDE and the 5000 mR Thyroid CDE are based on the EPA protective action guidance which indicates that public protective actions are indicated if the dose exceeds 1000 mrem TEDE or 5000 1

mrem Thyroid CDE. This is consistent with the emergency class description for a General Emergency.

Actual meteorology (including forecasts) should be used whenever possible.

Classification for items 2 & 3 above result from emergency response team input. For example, the Environmental Survey Team provides actual dose rates which are used to determine dose for the projected duration of the release. The Dose Assessment Team provides projected dose.

CR-3 Matrix Reference Number:1.4 NEI 97-03

Reference:

AG1

?

1 i

i I

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Emergency Action Level Basis Document l

ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT I

Liquid Effluents MODES:ALL Classification:

Unusual Event Initiating Condition:

An UNPLANNED release ofliquid radioactivity to the environment exceeding 2 times the ODCM release setpoint for 60 minutes or longer Emergency Action Level:

(1 or 2)

L A VALID reading on RM-L2, RM-L7, or sample analysis confirms the release exceeds 2 times the ODCM release setpoint for 60 minutes or longer O.R

2. Release continued for 60 minutes or longer with no dilution flow Basis:

This EAL is based on failure of the monitor interlock to perform its function or loss of dilution flow. If the interlock failed, a factor of 2 times the release setpoint as compared to actual readings, can be used to judge if the EAL is exceeded. For other conditions, an evaluation ofliquid effluent radioactivity must be performed and compared against the ODCM release setpoint to determine entry conditions.

Releases in excess of 2 times the ODCM limits continuing for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose is not the primary concern here; it is the degradation in plant control implied by the fact the release was not isolated within 60 minutes. Therefore, it is not intended for the release to be averaged over 60 minutes For example, a release of 4 times the ODCM limits for 30 minutes does not exceed this initiat'.ig condition. Further, the Emergency Coordinator should not wait until 60 minutes elapses, but declare the event as soon as it is determined the release duration will likely exceed 60 minutes. An evaluation is necessary to compare monitor setpoint against the EAL limit.

CR-3 Matrix Reference Number:1.5 NEI 97-03

Reference:

AU1 f

7

Emergency Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Liquid Effluents MODES: ALL Classification:

Alert Initiating Condition:

An UNPLANNED release of liquid radioactivity to the environment exceeding 200 times the ODCM release setpoint for 15 minutes or longer Emergency Action Level:

A VALID reading on RM-L2, RM-L7, or sample analysis confirms the release exceeds 200 times the ODCM release setpont for 15 minutes or longer Basis:

This EAL is based on loss of dilution flow or failure of the monitor interlock to perform its function. If the interlock failed, a factor of 200 times the release setpoint as compared to actual readings, can be used to judge if the EAL is exceeded. For other conditions, an evaluation ofliquid effluent radioactivity must be performed and compared against the ODCM release setpoint to determine entry conditions. For example, a comparison would be necessary if dilution flow was lost.

CR-3 Matrix Reference Number:1.6 NEI 97-03

Reference:

AA1 l

8

1 1

Emergency Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT 1

Unexpected Radiation Levels 1

MODES:ALL ClassiBeation:

Unusual Event j

Initiating Condition:

An unexpected increase in radiation levels within the plant Emergency Action Level:

One or more VALID Area Radiation Monitor readings unexpectedly exceeds the values listed below for 15 minutes or longer:

RM-G3 400 mR/hr

=

RM-G4 600 mR/hr

=

RM-G5 3000 mR/hr

=

RM-G9 100 mR/hr

=

RM-G10 800 mR/hr

=

RM-G14 1000 mR/hr

=

RM-G17 800 mR/hr

=

Basis:

This EAL addresses unexpected increases in in-plant radiation levels representing a degradation in the control of radioactive material, and a potential degradation in the level of safety of the plant.

The values above represent approximately 1000 times normal monitor levels based on nominal histprical data of the monitors during normal plant operation. Portable surveys may be substituted for in plant radiation monitors. The specific area radiation monitors were chosen as they represent potential release areas within the plant and/or access corridors to the plant.

Assessment should be completed such that after the 15 minutes elapsed time, a classification decision thould be made.

Monitor Locations:

1 RM-G3 (Primary Sample Room)

RM-G4 (Auxiliary Building entrance corridor)

RM-G5 (Waste Gas Decay Tank Area)

RM-G9 (Intermediate Building outside Reactor Building (RB) personnel airlock)

RM-G10(Makeup Pump area)

RM-G14(Spent Fuel Pool Storage Area - 143' elev. Aux. Bldg. general area)

RM-G17(inside RB at personnel hatch)

CR-3 Matrix Reference Number:1.7 NEI 97-03

Reference:

AU2 9

Emtrg:ncy Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Unexpected Radiation Levels MODES: ALL Classification:

Alert Initiating Condition:

An unexpected increase in radiation levels within the plant impeding operation of systems required to maintain safe operations pr to establish or maintain cold shutdown Emergency Action level:

(1 or 2)

1. VALID radiation reading greater than 15 mIWr for 15 minutes or longer in the Control Room (RM-G1) or the Central Alarm Station (CAS)

OR

2. VALID Area Radiation Monitor reading unexpectedly exceed one or more of the values listed below for 15 minutes or longer:

RM-G3 5,000 mR/hr

=

RM G4 5,000 mIhr

=

RM.G9 5,000 mR/hr

=

RM-G10 5,000 mIWr

=

RM-G17 5,000 mR/hr

=

Basis:

This addresses increased radiation levels impeding necessary access to operating stations, or other areas containing equipment operated manually, in order to maintain safe operation or perform a safe shutdown. The specific area radiation monitors were chosen as they represent access corridors to the plant. These monitors cover general areas that would require access to maintain safe operations or to etablish and maintain safe shutdown. It is this impaired ability to operate the plant that results in the actual or potential substantial degradation of the level of safety of the plant. The cause and/or magnitude of the increase in radiation levels is not a concern of this initiating condition. The Emergency Coordinator must consider the source or cause of the increased radiation levels and determine if any

- other Initiating Condition is involved. For example, a dose rate of 15 mR/hr in the control room may be a problem in itself. However, the increase may also be indicative of high dose rates in the containment due j

to a LOCA. In this latter case, a Site Area Emergency or General Emergency may be indicated by the j

Fission Product Barrier Matrix Initiating Conditions.

I 10 a

m 1

Emergency Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Unexpected Radiation Levels, continued Basis, continued Portable surveys may be substituted for in plant radiation monitors. A generic emergency action level at greater than 5,000 mR/hr has been chosen for those areas in the plant that would need to be accessed for safe operation or safe shutdown of the unit.

Monitor Locations:

RM-G3 (Primary Sample Room)

RM-G4 (Auxiliary Building entrance corridor)

RM-G9 (Intermediate Building outside RB personnel airlock)

RM-G10 (Makeup Pump area)

RM G17 (inside RB at personnel hatch)

Msessment should be completed such that after the 15 minutes elapsed time, a classification decision should be made. This Initiating Condition is not intended to apply to anticipated temporary increases

)

due to planned events (e.g., incore detector movement, radwaste container movement, depleted resin transfers, etc.)

CAS dose rates are determined by portable monitors.

Areas requiring continuous occupancy includes the control room and any other control stations that are manned continuously, such as the Central Alarm Station. The value of 15 mR/hr is derived from the GDC 19 value of 5 rem in 30 days with adjustment for expected occupancy times. Although Section III.D.3 of NUREG-0737, " Clarification of TMI Action Plan Requirements," provides that the 15 mR/hr value can be averaged over the 30 days, the value is used here without iveraging, as a 30 day duration implies an event potentially more significant than an Alert.

CR-3 Matrix Reference Number:1.8 NEI 97-03

Reference:

AA3 11

Emergency Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Fuel Handling / Fuel Handling Pool Water Level MODES:ALL ClassiScation:

Unusual Event Initiating Condition:

An uncontrolled water level decrease in spent fuel pool pr transfer canal with fuel remaining covered Emergency Action Level:

(1 and 2)

1. (a or b)

a. Uncontrolled level decrease resulting in indications of-2.5 feet in spent fuel pool OR

b. Plant personnel report water level drop in spent fuel pool p2 fuel transfer canal AND 2.

Fuel remains covered with water Basis:

The "-2.5 feet" indication is relative to the normal "zero" reading for spent fuel pool level and represents the minimum 23 feet of water (156 feet plant datum) over the top of the fuel as described in Improved Tcchnical Specifications.

CR-3 Matrix Reference Number:1.9 NEI 97-03

Reference:

AU2 I

12 a

Emergency Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Fuel Handling / fuel HandHng Pool Water Level MODES: ALL Classificationj Alert Initiating Condition:

Major damage to irradiated fuel pr loss of water level has or will uncover irradiated fuel outside the reactor vessel l

Emergency Action Level:

(1 or 2)

1. (a and b)

a. Plant personnel report damage ofirradiated fuel AND b.

VALID high alarm as indicated on RM-G15 or RM-G16

@R

2. Plant personnel report spent fuel pool or transfer canal water level drop has pr will exceed makeup capacity such that irradiated fuel will be uncovered j

Basis:

There is time available to take corrective actions, and there is little potential for substantial fuel damage.

Thus, an Alert classification for this event is appropriate. Escalation, if appropriate, would occur via Abnormal Rad Levels or Emergency Coordinatorjudgment.

Monitor Locations:

RM-G15 (Auxiliary Building Fuel Handling Bridge)

RM-G16 (Reactor Building Fuel Handling Bridge)

' CR-3 Matrix Reference Number:1.10 NEI 97-03

Reference:

AA2 13

Em:rgency Action Lcvel Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Earthquake Experienced MODES: ALL Classification:

Unusual Event Initiating Condition:

Earthquake detected by seismic instrumentation Emergency Action Level:

(1 and 2)

1. Ground motion sensed by plant personnel AND

2. Confirmed carthquake causing Annunciator C-3-14 " Seismic System Trouble" alarm Basis:

Damage may be caused to some portions of the site, but should not affect ability of safe shutdown equipment to operate. Method of detection is based on instrumentation, validated by a reliable source, or operator assessment. As defined in the EPRI-sponsored, " Guidelines for Nuclear Plant Response to an Earthquake," dated October 1989, a " felt earthquake"is:

"An earthquake of sufficient intensity such that: (a) the ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated."

CR-3 Matrix Reference Number:2.1 NEI 97-03

Reference:

HU1 14

Em:rgency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Earthquake Experienced MODES: ALL Classification:

Alert Earthquake detected by seismic instrumentation (1 and 2)

1. Ground motion sensed by plant personnel or confirmed Annunciator C-3-14 " Seismic System Trouble" alarm AND

2. (a or b)

a. Analysis confirms the earthquake at >0.05g OR

b. Indications show degraded SAFE SHUTDOWN EQUIPMENT performance due to the earthquake Basis:

Seismic events of this magnitude can cause damage to safety functions.

Analysis of earthquakes is completed using AP-961 and its supporting procedures. The analysis to determine the magnitude of an earthquake may take an extended period of time. Ifit is determined even after several hours that the earthquake was >0.05g, the event should be classified.

This EAL is intended to address an earthquake resulting in a plant vital area being subjected to forces beyond design limits, and thus damage is assumed to have occurred to plant safe shutdown equipment.

The initial report is not interpreted as mandating a lengthy damage assessment before classification and no attempt is mLde to assess the actual magnitude of the damage.

Additional information on the earthquake (confirmation and magnitude) can be obtained from the U. S.

Geological Survey - Golden, Colorado at (303) 273-8500.

CR-3 Matrix Reference Number:2.2 NEI 97-03

Reference:

HA1 15

Em:rgency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Flood MODES:ALL Classification:

Unusual Event Initiating Condition:

Flood being experienced Emergency Action Level:

Intake canal level or visual observation indicates flood water level 2 98 feet Basis:

This EAL covers flooding due to nature' '

nomena. This EAL can be a precursor of more serious events. In particular, since CR-3 may be.4bject to severe weather as defm' ed in the NUMARC station blackout initiatives, this includes action based on activation of the severe weather mitigation procedures for flooding (e.g., precautionary shutdowns, diesel testing, staff call-outs, etc.).

Ninety-eight (98) feet is contained within the discharge and intake canals banks. The top of the concrete wall at the intake structure is 99 feet.

The highest water level recorded at CR-3 was 99.5 feet during the 03/13/93 "No Name Storm."

At 98 feet, there is no immediate impact on plant equipment but heightened awareness is appropriate should the level increase.

l CR-3 Matrix Reference Number:2.3 NEI 97-03

Reference:

HU1 16

Emerg:ncy Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Flood MODES: ALL Classification:

Alert Initiating Condition:

Flood being experienced Emergency Action Level:

(1 and 2)

1. Intake canal level or visual observation indicates flood water level 2 98 feet AND

2. Indications show degraded SAFE SHUTDOWN EQUIPMENT performance due to the flooding i

Basis:

This EAL covers flooding due to natural phenomena.

This EAL is intended to address flooding that may have resulted in a plant vital area being subjected to j

forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems.

l The initial report is not interpreted as mandating a lengthy damage assessment prior to classification and no attempt is made to assess the actual magnitude of the damage.

1 If damage from the flooding is clearly contained and localized to one train, and safe shutdown capability exists, then item 2 of the EAL is not met. If the extent of the damage is uncertain in terms ofloss of safe shutdown capability, then entry into this EAL is required.

CR-3 Matrix Reference Number:2.4 NET 97-03

Reference:

HA1 17

Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Hurricane MODES:ALL Classification:

Unusual Event Initiating Condition:

Hurricane Warning

' Emergency Action Level:

The plant is within a Hurricane Warning area I

Basis:

This EAL can be a precursor of more serious events. In particular, since CR-3 may be subject to severe

]

weather as defined in the NUMARC station blackout initiatives.

This should include a notification from the National Hurricane Center via the State Warning Point.

CR-3 Matrix Reference Number:2.5 NEI 97-03

Reference:

HU1 18

Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Tornado MODES: ALL ClassiBeation:

Unusual Event Initiating Condition:

Tornado within the Protected Area Emergency Action Level:

Report by plant personnel of a Tornado striking within the Protected Area Basis:

This EAL is based on the assumption a tornado strikes (touches down) within the protected area boundary and may have potentially damaged plant structures containing functions or systems required for safe shutdown of the plant. If such damage is confirmed visually or by other in-plant indications, the event may be escalated to an Alert.

Waterspouts remaining intact after coming onshorelland are classified as tornadoes.

CR-3 Matrix Reference Number:2.6 NEI 97-03

Reference:

HU1 19 l

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Em:rg:ncy Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT 1

Tcrnado/High Winds MODES: ALL Classification:

l l

Alert Initiating Condition:

Tornado or High Winds or windborne object (s) strike structures and results in significant visible damage 1

l i

Emergency Action Level:

)

(1 and 2)

)

1 l

1

1. Tornado gr High Winds or windborne object (s) strike one of the following structures:

. Auxiliary Building,

)

. BWST,

)

. Control Complex, j

. EFT-2 Building, j

. Diesel Generator Building,

. Intermediate Building,

• Reactor Building AND

2. (a or b)

a. Confirmed report of significant visible damage to buildings listed above O_.B b.

Indications show degraded SAFE SHUTDOWN EQUIPMENT performance due to Tornado, high winds, or windborne objects.

Basis:

This EAL addresses events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report is not interpreted as mandating a lengthy damage assessment before classification and no attempt is made to assess the actual magnitude of the damage.

The highest recorded sustained windspeed at CR-3 during the 03/13/93 "No Name Storm" was 56 mph.

20

Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Tornado /High Winds, :ontinued Basis, continued Waterspouts remaining intact after coming onshore / land are classified as tornadoes.

CR-3 Matrix Reference Number:2.7 NEI 97-03

Reference:

HA1 l

)

21

Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Aircraft / Vehicle Crash MODES:ALL Classification:

Unusual Event Initiating Condition:

Aircraft pr Vehicle crash within the Protected Area potentially damaging plant structures containing functions and systems required for safe shutdown of the plant Emergency Action Level:

Report by plant personnel of Aircraft or Vehicle Crash involving any of the following permanent structures within the Protected Area:

. Auxiliary Building,

.BWST,

. Control Complex,

• EFT-2 Building,

. Diesel Generator Building, eIntermediate Building, e Reactor Building Basis:

This EAL is intended to address such items as a planc, helicopter or vehicle crash, potentially damaging plant structures containing functions and systems required for safe shutdown of the plant. Automobiles, trucks, and forklifts are vehicles within the context of this EAL. The intent is to address any vehicle that can cause significant damage to plant structures.

CR-3 Matrix Reference Number:2.8 NEI 97-03

Reference:

HU1 22

Em:rgency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Aircraft / Vehicle Crash MODES:ALL ClassiScation:

Alert j

Initiating condition:

Aircraft g Vehicle strikes vital structures and results in significant visible damage Emergency Action Level:

(1 and 2)

1. Confirmed report of significant visible damage to any of buildings listed below:

. Auxiliary Building, e BWST,

. Control Complex,

. EFT-2 Building,

. Diesel Generator Building,

. Intermediate Building,

• Reactor Building AND

2. Indications show degraded SAFE SHUTDOWN EQUIPMENT performance due to Aircraft g Vehicle Crash Basis:

This EAL is intended to address such items as a plane or helicopter or vehicle crash damaging plant structures containing functions and systems required for safe shutdown of the plant. Automobiles, trucks, and forklifts are also vehicles within the context of this EAL. Significant damage refers to structural damage that is beyond cosmetic damage.

This EAL is intended to address events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems.

The initial report is not interpreted as mandating a lengthy damage assessment prior to classification j

and no attempt is made to asses the actual magnitude of the damage.

If damage from the vehicle or aircraft crash is clearly contained and localized to one train, and safe shutdown capability exists, then the EAL is not met. If the extent of the damage is uncertain in terms of loss of safe shutdown capability, then entry into this EAL is required.

CR-3 Matrix Reference Number:2.9 NEI 97-03

Reference:

HA1 23

Enurgency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Toxic or Flammable Gas MODES: ALL Classification; Unusual Event Initiating Condition:

Release of Toxic or Flammable Gas within, or potentially affecting the Protected Area E_mergency Action Level:

(1 or 2)

1. Report or detection of toxic or flammable gases within the SITE BOUNDARY that could enter the Protected Area in amounts that can affect normal operation of the plant OR

2. Confirmed notification by FPC, County, or State personnel of a potential evacuation or sheltering of l

site personnel based on an offsite event Basis-I This Initiating Condition is based on releases in concentrations within the Site Boundary that could; (1) affect the health and safety of plant personnel; (2) affect the safe operation of the plant; or (3) potentially put the plant within an evacuation or sheltering area due to an offsite event.

)

Gases within the Site Boundary that are below life-threatening (< IDLH) or flammable concentrations j

are not applicable to this Initiating Condition. Concentrations at these levels would not affect plant personnel or the safe operation of the plant. Gases at the site boundary that are above life-threatening i

or flammable concentrations, yet have not exceeded those concentrations within a facility structure, j

would satisfy the first EAL and would require the declaration of an Unusual Event.

Toxic or Flammable gases which are released offsite (e.g., transportation accident) confirmed by FPC, County, Local, or State personnel have the potential for requiring the evacuation or sheltering of the Owner Controlled Area (Site Boundary).

A localized /small-scale event within the Site Boundary that may involve gases at life threatening or flammable concentrations do not meet the intent of this Initiating Condition.

CR-3 Matrix Reference Number:2.10 NEI 97-03

Reference:

HUS 24

Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Toxic or Flammable Gas MODES:ALL Classi8 cation:

Alert Initiating Condition:

Release of toxic or flammable gases within a facility structure which jeopardizes operation of systems required to maintain safe operations or to establish or maintain Cold Shutdown Emergency Action Level:

(1 or 2 or 3) l

1. Flammable Gas levels >25% Lower Explosive Limits OR

2. Toxic gas levels 2 IDLil levels in areas that require continuous occupancy to maintain safe operations or establish or maintain cold shutdown O_R

3. Toxic gas levels 2 IDLH levels within the Protected Area such that plant personnel are unable to l perform actions necessary to maintain safe operations or establish and maintain cold shutdown using personal protective equipment Basis:

This Initiating Condition is based on gases that have entered a plant structure affecting the safe operation of the plant. This Initiating Condition applies to buildings and areas contiguous to plant vital areas or other significant buildings or areas.

Concentrations at these amounts will restrict or prevent normal actions from being taken to operate the plant. This EAL is not intended to include precautionary general evacuation of personnel.

If personnel can safely enter areas not required to be continuously occupied using protective equipment, this Initiating Condition /EAL is not met.

IDLH - Immediately Dangerous to Life or Health CR-3 Matrix Reference Number:2.11 NEI 97-03

Reference:

HA3 25

Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Explosions / Catastrophic Pressurized Equipment Failure MODES:ALL Classification:

Unusual Event Initiating Condition:

UNPLANNED EXPLOSION within the Protected Area Emergency Action Level:

Report by plant personnel of VISIBLE DAMAGE to permanent structures pr equipment within the PROTECTED AREA due to an EXPLOSION or catastrophic failure of pressurized equipment Basis:

For this EAL, only those explosions of sufficient force to damage permanent structures or equipment within the protected area should be considered. No attempt is made in this 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 declaration.

This EAL is not intended to cover small steam line breaks, small pipe cracks, or small steam / feed leaks.

The Emergency Coordinator also needs to consider security aspects of the explosion and, if applicable, refer to the security EALs.

CR-3 Matrix Reference Number:2.12 NEI 97-03

Reference:

HU1 26

Em rg::ncy Action Level Basis Document i

i NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Explosions / Catastrophic Pressurized Equipment Failure l

MODES: ALL Classification:

Alert l

Initiating Condition:

t EXPLOSION within the plant affecting the operability of plant safety systems required to establish or maintain safe shutdown i

Emergency Action Level.

(1 and 2) l

1. EXPLOSION or catastrophic failure of pressurized equipment in any of the following structures-

. Auxiliary Building,

.BWST, e Control Complex, e EFT-2 Building,

• Diesel Generator Building,

. Intermediate Building,

. Reactor Building AND l

2. (a or b)

a. Report by plant personnel of EXPLOSION or catastrophic failure of pressurized equipment causing VISIBLE DAMAGE to SAFE SHUTDOWN EQUIPMENT OR

b. Indications show degraded SAFE SHUTDOWN EQUIPMENT performance due to the Explosion i

or pressurized equipment failure l

l l

Basis:

l l

j This EAL is intended to address events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safe shutdown equipment. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage.

l The observation of damage to a structure is sufficient to make a declaration.

27 i

pT7-Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Explosions / Catastrophic Pressurized System Failure, continued Basis, continued If damage from the explosion or catastrophic failure of pressurized equipment is clearly contained and localized to one train, and safe shutdown capability exists, then the EAL is not met. If the extent of the damage is uncertain in terms ofloss of safe shutdown capability, then entry into this EAL is required.

CR-3 Matrix Reference Number:2.13 NEI 97-03

Reference:

HA2 1

28

1 l

Em:rg:ncy Action Level Basis Document l

NATURAL / MAN-MADE HAZARDS AND EC JUDGRENT Fire MODES: ALL Classification:

Unusual Event Initiating Condition FIRE within the PROTECTED AREA that could affect SAFE SHUTDOWN EQUIPMENT Emergency Action Level:

(1 and 2)

1. FIRE in or threatening one of the following structures:

. Auxiliary Building, e BWST, e Control Complex, e EFT-2 Building,

. Diesel Generator Building, eIntermediate Building, eReactor Building AND

2. FIRE not extinguished within 15 minutes from Control Room notification qr receipt of a verified Control Room fire alarm Basis:

This EAL 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 consequence. This Initiating Condition applies to buildings and areas contiguous to plant vital areas or other significant buildings or areas.

Verification of the alarm in this context means those actions taken in the control room or other location to determine the control room alarm is not spurious.

1 i

Fire in other areas adjacent to vital areas may warrant classification if the fire is of a magnitude that threatens vital areas.

29

~-

Emcrgency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Fire, continued Basis, continued The 15 minute time period begins with the time when a credible notification that a fire is occurring or a verified fire detection system alarm is received. The intent of the 15 minute duration is to discriminate against small fires that are readily extinguished.

CR-3 Matrix Reference Number:2.14 NEI 97-03

Reference:

HU2 I

i

)

i l

i l

30

Emerg:ncy Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Fire MODES:ALL ClassiBeation:

Alert Initiating Condition:

FIRE affecting the operability of SAFE SHUTDOWN EQUIPMENT Emergency Action Level:

(1 or 2)

1. Report by plant personnel of VISIBLE DAMAGE to SAFE SHUTDOWN EQUIPMENT due to the FIRE OR t

2. Indications show degraded SAFE SHUTDOWN EQUIPMENT performance due to the FIRE t

Basis:

The key to classifying fires as an Alert is the damage as a result of the incident. The fact that the equipment required for safe shutdown of the unit has been affected or damaged as a result of the fire is the driving force for declaring the Alert.

1 I

If damage from the fire is clearly contained and localized to one train, and safe shutdown capability exists, then the EAL is not met. If the extent of the damage is uncertain in terms of loss of safe shutdown capability, then entry into this EAL is required.

CR-3 Matrix Reference Number:2.15 NEI 97-03

Reference:

HA2 -

l 31

Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Crntrol Room Evacuation MODES:ALL Class 18 cation:

Alert Initiating Condition:

Evacuation of Control Room is Required Emergency Action Level:

Control Room evacuation is required per AP-990, " Shutdown Outside of the Control Room" Basis:

With the control room evacuated, additional support, moriitoring and direction through the Technical Support Center and/or the Emergency Operations Facility in necessary.

Declaration of an Alert may be delayed until the transfer to remote shutdown is completed. This is appropriate since establishing control of the plant takes precedence.

i I

CR-3 Matrix Reference Number:2.16 NEI 97-03

Reference:

HA5 l

l 32

Emerg:ncy Action Level Ba::is Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Control Room Evacuation MODES:ALL Classification:

Site Area Emergency Initiating Condition:

Evacuation of Control Room is Initiated and Plant Control cannot be established l

)

Emergency Action Level:

(1 and 2)

1. Control Room evacuation is required per AP-990, " Shutdown Outside of the Control Room" AND

2. Control of the necessary equipment p_qt established per AP-990 within 15 minutes Basis:

The 15 minutes begins at the first attempt to turn the transfer switch to transfer control from the Main Control Room to the Remote Shutdown Panel.

The timely transfer of control to alternate control areas has not been accomplished. The faihre to transfer control would be evidenced by deteriorating reactor coolant system or steam generator parameters.

The determination of whether or not control is established at the Remote Shutdown Panel is based upon the judgment of the Nuclear Shift Manager.

The Nuclear Shift Manager is expected to make a r:asonable, informed judgment within fifteen minutes of the transfer from the Control Room that the operating crew has control of the plant from the Remote Shutdown Panel.

CR-3 Matrix Reference Number:2.17 NEI 97-03

Reference:

HS2 l

33 J

Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Security Event MODES: ALL Classiflestion:

Unusual Event Initiating Conditions:

Confirmed Security event which indicates a potential degradation in the level of safety of the plant Emergency Action Level:

(a or b or c)

Report by Security Shift Supervisor of one or more of the following events:

a. Occurrence of SABOTAGE / INTRUSION M

b. HOSTAGE / EXTORTION situation or hostile strike action threatening to interrupt plant operations E

A violent CIVIL DISTURBANCE ongoing outside the PROTECTED AREA but within the Owner c.

Controlled Area (SITE BOUNDARY)

Basis:

This EAL is based on CR-3 Physical Security Plan. Security events which do not represent at least a potential degradation in the level of safety of the plant, are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72.

CR-3 Matrix Reference Number:2.18 NEI 97-03

Reference:

HU4 34

Emergency Action Level Basis Document 1

NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT l

Security Event MODES: ALL Classification:

Alert Initiating Condition:

t Confirmed Security Event in a plant Protected Area.

Emergency Action Level:

(1 or 2)

1. Discovery of BOMB within the PROTECTED AREA

_O_g

2. INTRUDER (S) penetrates the PROTECTED AREA Basis:

This class of security events represents an escalated threat to plant safety above that contained in the Unusual Event. For the purposes of this Initiating Condition, a civil disturbance which penetrates the protected area boundary can be considered an intrusion.

CR-3 Matrix Reference Number:2.19 NEI 97-03

Reference:

HA4 35

Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Security Event MODES: ALL Classification:

Site Area Emergency Initiating Condition:

Confirmed Security Event in a plant Vital Area.

Emergency Action Level:

1. INTRUDER (S) penetrates or a BOMB is discovered in any of the areas listed below:

. Auxiliary Building,

. BWST,

. Control Complex,

. EFT-2 Building,

. Diesel Generator Building,

. Intermediate Building, e Reactor Building Basis:

This class of security events represents an escalated threat to plant safety above that contained in the Alert IC in that an intruder has progressed from the Protected Area to a Vital Area.

If an intruder or intruders penetrates or a bomb is detonated in the Control Room or Remote Shutdown Room, a General Emergency would be declared.

CR-3 Matrix Reference Number:2.20 NEI 97-03

Reference:

HS1 36

Em:rgency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Security Event i

l MODES: ALL Classification:

General Emergency Initiating Condition:

Security Event resulting in loss of physical control of the facility 1

Emergency Action Level:

INTRUDER (S) has taken control of the Control Room, or Remote Shutdown Room or plant equipment such that plant personnel are unable to operate equipment required to establish and maintain safe shutdown conditions Basis:

This Initiating Condition encompasses conditions under which a hostile force has taken physical control of a vital area or equipment required to reach and maintain safe shutdown. If control of the plant equipment necessary to maintain safety functions can be transferred to another location, then the above limiting condition is not met. Loss of physical control of the Control Room or remote shutdown capability alone may not prevent the ability to maintain safety functions per se.

CR-3 Matrix Reference Number:2.21 NEI 97-03

Reference:

HG1 37

Emerg:ncy Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Internal Flooding l

MODES: ALL

. Classification:

Unusual Event 1

Initiating Condition:

Internal flooding affecting areas containing safe shutdown equipment Emergency Action Level:

(1 and 2)

1. Indication of uncontrolled flooding in the Auxiliary Building or Intermediate Building AND

2. Water level / flooding has the potential to affect or immerse SAFE SHUTDOWN EQUIPMENT Basis:

This addresses the possible effects of flooding from system malfunctions, component failures, or repair activity mishaps that could threaten the safe operation of the plant. The flooding could affect equipment not designed to be submerged.

CR-3 Matrix Reference Number:2.22 NEI 97-03

Reference:

HU1 l

l 38

Em:rgency Action Level Basis Document -

NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Internal Flooding MODES,; ALL Classification:

A1:rt Initiating Condition:

Internal flooding affecting SAFE SHUTDOWN EQUIPMENT i

l J

Emergency Action Level:

(1 and 2)

1. Water level exceeds 1.5 feet in the Auxiliary Building or Intermediate Building i

2. (a or b)

a. Indications show degraded SAFE SHUTDOWN EQUIPMENT due to the flooding O_R

b. Electrical hazards prevent plant personnel normal access to areas of plant containing SAFE SHUTDOWN EQUIPMENT Basis:

This addresses the possible effects of flooding from system malfunctions, component failures, or repair activity mishaps that has either threatened the safe operation of the plant or resulted in a complete loss of function required for cold shutdown.

The water level was selected based on a level when Motor Control Centers would experience water intrusion.

If damage from the internal flooding is clearly contained and localized to one train, and safe shutdown capability exists, then item 2 of the EAL is not met. If the extent of the damage is uncertain in terms of loss of safe shutdown capability, then entry into this EAL is required.

CR-3 Matrix Reference Number:2.23 NEI 97-03

Reference:

HA1 39 L

Emcrgency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Emergency Coordinator Judgment MODES: ALL Classification:

Unusual Event Initiating Conditions:

Other conditions existing, which in the judgment of the Emergency Coordinator, warrant declaration of an Unusual Event Emergency Action Level; Other conditions exist which indicate a potential degradation in the level of safety of the plant Basis:

This EAL addresses unanticipated conditions not addressed explicitly elsewhere but warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the Unusual Event emergency class.

This EAL should also be referenced if, in thejudgment of the Emergency Coordinater, an Unusual Event should be classified if plant symptoms are less than the threshold of an existing EAL.

CR-3 Matrix Reference Number:2.24 NEI 97-03

Reference:

HU5 40

Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Emergency Coordinator Judgment MODES: ALL ClassiBeation:

Alert Initiating Conditions:

Other conditions exist, which in the judgment of the Emergency Coordinator, warrant declaration of an Alert Emergency Action Level:

Other conditions exist which indicate that events are in process or have occurred which involve potential or actual substantial degradation of the level of safety of the plant i

Basis:

This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but warrant l

declaration of an emergency because conditions exist which are believed by the Emergency Coordinator l

to fall under the Alert emergency class.

i l

l Any release is expected to be limited to small fractions of the EPA plume Protective Action Guideline Exposure Levels.

l This EAL should also be referenced if, in the judgment of the Emergency Coordinator, an Alert should be classified if plant symptoms are less than the threshold of an existing EAL.

CR-3 Matdx Reference Number:2.25 NEI-97-03

Reference:

HA6 41

i 1

Emergency Action Lcvel Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Emergency Coordinator Judgment MODES:ALL Classification:

Site Area Emergency Initiating Conditions:

Other conditions exist, which in the judgment of the Emergency Coordinator, warrant declaration of a Site Area Emergency Emergency Action Level:

Other conditions exist which indicate actual or likely major failures of plant functions needed for the protection of the public Basis:

This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the emergency class description for Site Area Emergency.

A release is not expected to result in exposure levels exceeding EPA plume Protective Action Guideline i

Exposure Levels beyond thn Site Boundary (1 Rem TEDE or 5 Rem Thyroid CDE).

The Site Boundary is defined as 0.83 miles radially from the center of the Reactor Building.

This EAL should also be referenced if, in the judgment of the Emergency Coordinator, a Site Area Emergency should be classified if plant symptoms are less than the threshold of an existing EAL.

CR-3 Matrix Reference Number:2.26 NEI 97-03

Reference:

HS3 42

l Em:rgency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Emergency Coordinator Judgment MODES:ALL 4

I Classification:

General Emergency Initiating Condition:

Other conditions exist, which in the judgment of the Emergency Coordinator,4.varrant declaration of a General Emergency 4

Emergency Action Level:

{

(1 or 2)

Other conditions exist which indicate:

1. Actual or imminent substantial core degradation with potential for loss of containment integrity

~

I OR i

)

2. The potential for uncontrolled radionuclide releases that can be expected to exceed EPA Protective

]

Action Guidelines Plume Exposure Levels beycnd the SITE BOUNDARY Basis:

This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that j

warrant declaration of an emergency because conditions exist which are believed by the Emergen-Coordinator to fall under the General Emergency class.

Releases can reasonably be expected to exceed EPA Protective Action Guidelines Plume Exposure Levels bcyond the Site Boundary (1 Rem TEDE or 5 Rem Thyroid CDE).

CR-3 Matrix Reference Number:2.27 NEI 97-03

Reference:

HG2 J

43 1

Em rgency Action Level Ba:is Document SYSTEM MALFUNCTION Loss of Communication MODES: ALL Classification:

Unusual Event Initiating Condition:

Unplanned loss of all In-Plant or all offsite Communication capability Emergency Action Level:

(1 or 2)

1. Loss of d the following in-plant communications capability:

FPC Internal Telephone System

. PAX Portable UHF Radios OR

2. Loss of d the following offsite communications capability:

FPC Telephone System State Hot Ring Down (SHRD)

State-Wide Emergency Satellite Communication (ESATCOM) System ALL FTS 2000 NRC Phones (Emergency Notification System (ENS), Health Physics Network (HPN), Counterpart Links)

Control Room Cel!ular Phone Basis:

The purpose of this Initiating Condition and its associated EALs is to recognize a loss of communications capability either defeating the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate problems with offsite authorities.

The loss of offsite communications ability is expected to be significantly more compehensive than the condition addressed by 10 CFR 50.72.

i The onsite or offsite communications loss must encompass the loss of all means of routine direct communications with intended parties. This includes the ENS, Commercial lines, Microwave, and FAX transmissions. This EAL is used only when extraordinary means are used to make communications possible (relaying of information from radio transmissions, individuals being sent to offsite locations, etc.).

Credit is not ~ taken for portable satellite phones due to the time it takes tc establish a communications link. Once a link is established with a portable satellite phone, the event may be terminated.

CR-3 Matrix Reference Number:3.1 NEI 97-03

Reference:

SU6 44

Em:rg:ncy Action Level Basis Docum:nt SYSTEM MALFUNCTION I

i Failure of Reactor Protection MODES: 1,2,3 Classification:

Alert Initiating Condition _;.

Fcilure of Reactor Protection System (RPS) instrumentation to complete or initiate an automatic reactor trip once an RPS setpoint has been exceeded and manual trip was successful Emergency Action Level:

(1 and 2) l 1.

RPS Trip setpoint exceeded and no Reactor trip occurred AND 2.

Manual Reactor trip from Control Room was successful and the reactor is shutdown Basis:

This conditien indicates failure of the Reactor Protection System to trip the reactor. This condition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient and thus the plant safety has been compromised, and design limits of the fuel may have been exceeded.

An Alert is indicated because conditions exist that lead to potential loss of fuel clad or RCS. Reactor protection system setpoint being exceeded (rather than limiting safety system setpoint being exceeded) is specified here because failure of the automatic protection system is the issue. A manual trip is any set of actions by the reactor operator (s) in the Control Room which causes sufficient control rods to be rapidly inserted into the core and brings the reactor suberitical (e.g., reactor trip button, de-energizing control i

rod power from the control room). Operator actions to drive rods or other actions taken or occurring outside the control room does not constitute a reactor trip because it does not meet the rapid insertion criterion.

l An automatic reactor trip is considered as the RPS tripping the reactor.

CR-3 Matrix Reference Number:3.2 NEI 97-03

Reference:

SA2 45

I Em:rg:ncy Action Level Basis Document j

i SYSTEM MALFUNCTION Failure of Reactor Protection MODES: 1,2 l

l Classification:

Site Area Emergency Initiating Condition:

Fcilure of Reactor Protection System (RPS) instrumentation to complete or initiate an automatic reactor trip once an RPS setpoint has been exceeded and manual trip was NOT successful Emergency Action Level:

(1 and 2)

1. RPS Trip setpoint exceeded and no Reactor trip occurred AND

2. Manual Reactor trip from Control Room was not successful in shutting down the reactor Basis:

Automatic and manual trips are not considered successful if action away from the Control Room was required to trip the reactor. Manual trip is successful if the trip push button or de-energizing control rod power in the Control Room results in shutting down the reactor.

An automatic reactor trip is considered as the RPS tripping the reactor.

The trip is considered unsuccessful when enough control rods have not inserted to cause the reactor power to fall below that percent power associated with the ability of the safety systems to remove heat and continue to decrease. Subsequent actions necessary for the reactor to be prepared for a cooldown and depressurization are not to be considered.

Under these conditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed. A Site Area Emergency is indicated because conditions exist that lead to imminent loss or potential loss of both fuel clad and RCS. Although this Initiating Condition may be vi:wed as redundant to the Fission Product Barrier Matrix, its inclusion is necessary to better assure timely recognition and emergency response.

CR-3 Matrix Reference Number:3.3 NEI 97-03

Reference:

SS2 46

1 Em:rg:ncy Action Level Basis Document SYSTEM MALFUNCTION Failure of Reactor Protection MODES: 1,2

]

Class 18 cation:

General Emergency l

l 1

Initiating Condition:

{

Failure of the Reactor Protection System to complete an automatic trip and manual trip was NOT successful and there is indication of extreme challenge to the ability to cool the core Emergency Action Level:

(1 and 2)

1. (a and b) l RPS Trip setpoint exceeded and no Reactor trip occurred a.

AND

b. Manual Reactor trip from Control Room was not successful in shutting down the reactor AND

2. (a or b)

I a.

Core exit thermocouple temperatures > 700*F, as indicated on SPDS O_R

b. Adequate Secondary Cooling is not available Basis:

Under the conditions of this Initiating Condition and its associated EALs, the efforts to bring the reactor suberitical have been unsuccessful and, as a result, the reactor is producing more heat than the maximum decay heat load for which the safety systems were designed. Although there are capabilities away from the reactor control console, such as emergency boration, the continuing temperature rise indicates that these capabilities are not effective. This situation could be a precursor for a core melt sequence.

i 700 F is a good indicator of an extreme challenge to the ability to cool the core and is consistent with the

" potential loss" factor in the Fission Product Barrier Matrix.

J Another consideration is the inability to initially remove heat during the early stages of this sequence. If cmergency feedwater flow is insufficient to remove the amount of heat required by design from at least ons steam generator, an extreme challenge should be considered to exist.

In the event either of these challenges exist at a time the reactor has not been brought below the power anociated with the safety system design a core melt sequence exists. In this situation, core degradation c:n occur rapidly. For this reason, the General Emergency declaration is intended to be anticipatory of ths Fission Product Barrier Matrix declaration to permit maximum offsite intervention time.

CR-3 Matrix Reference Number:3.4 NEI 97-03

Reference:

SG2 47

Em:rgency Action Level Basis Document SYSTEM MALFUNCTION i

Inability to Reach Required Mode Within Improved Technical Cpecification Time Limits MODES: 1,2,3,4 Classification:

Unusual Event Initiating Condition:

Inability to reach required operating mode within Improved Technical Specification limits Emergency Action Level:

(1 and 2)

1. Entry into an Improved Technical Specification LCO statement requiring a mode reduction AND

2. The plant is not brought to the required operating mode within the time prescribed by the LCO required action Basis:

Limiting Conditions for Operation (LCOs) require the plant to be brought to a required shutdown mode when the Improved Technical Specification required configuration cannot be restored. The plant is within its safety envelope when being shut down within the allowable required action time in the Improved Technical Specifications. An immediate Notification of an Unusual Event is required when the plant is not brought to the required operating mode within the allowable required action time in the Improved Technical Specifications.

Declaration of an Unusual Event is based on the time at which the LCO-specified required action time period elapses under the Improved Technical Specifications and is not related to how long a condition may have existed.

CR-3 Matrix Reference Number:3.5 NEI 97-03

Reference:

SU2 48

Emerg:ncy Action Lcvel Basis Document SYSTEM MALFUNCTION Loss ofIndications MODES: 1,2,3,4 Classification:

Unusual Event Initiating Condition:

UNPLANNED loss of most pr all Control Room Annunciators for 15 minutes or longer i

Emergency Action Level:

(1 or 2) i

1. UNPLANNED loss of Annunciator panels A-G and Annunciator printer for 15 minutes or longer OR

2. UNPLANNED loss of NNI-X and NNI-Y for 15 minutes or longer Basis:

This Initiating Condition and its associated EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. Recognition of the availability of computer based indication equipment is considered (SPDS, plant computer, etc.). The Annunciator printer includes the Annunciator CRT display as the display mimics the printer. A loss of both is required to meet the IC.

A loss of Annunciators is considered to be a loss of the visual, as opposed to a loss of the audible portion of the Annunciator. Annunciator panels A-G contain the major control systems (RPS, ES, ICS, etc.).

Loss on NNI-X and NNI-Y will cause the loss of most or all safety system indication.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Due to the limited number of safety systems in operation during cold shutdown, refueling, and defueled modes, no IC is indicated during these modes of operation.

CR-3 Matrix Reference Number:3.6 NEI 97-03

Reference:

SU3 49

r Em:rgency Action Level Basis Document SYSTEM MALFUNCTION Loss ofIndications MODES: 1,2,3,4 Classification:

Alert Initiating Condition:

UNPLANNED loss of most pr all Control Room Annunciators for 15 minutes or longer with either a SIGNIFICANT TRANSIENT in progress pr Plant Computer and SPDS unavailable Emergency Action Level:

(1 and 2)

1. (a or b) a.

UNPLANNED loss of Annunciator panels A-G and Annunciator printer for 15 minutes or longer b.

UNPLANNED loss of NNI-X and NNI-Y for 15 minutes or longer i

AND 2.

(a or b)

a. SIGNIFICANT TRANSIENT in progress

-OR 1

b. Loss of Plant Computer and SPDS Basis:

This Initiating Condition and its associated EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a transient. Recognition of the availability of computer based indication equipment is considered (SPDS, plant computer., etc.).

The Annunciator printer includes the Annunciator CRT display as the display mimics the printer. A loss of both is required to meet the IC.

. A loss of Annunciators is considered to be a loss of the visual, as opposed to a loss of the audible portion of the Annunciator.

Annunciator panels A-G contain the major control systems (RPS, ES, ICS, etc.)

50

1 i

I Emergency Action Level Basis Document j

SYSTEM MALFUNCTION Loss ofIndications, continued i

Basis, continued Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled I

modes no IC is indicated during these modes of opemtion.

CR-3 Matrix Reference Number:3.7 NEI 97-03

Reference:

SA4 t

i 51

I Em rg:ncy Action Lev:1 Basis Document SYSTEM MALFUNCTION Loss of Indications MODES: 1,2,3,4 Classincation:

Site Area Emergency I

\\

Initiating Condition:

Inability to monitor a SIGNIFICANT TRANSIENT in progress I

Emergency Action Level:

(1 and 2 and 3 and 4)

I

1. (a or b)

Loss of Annunciator panels A-G and Annunciator printer for 15 minutes or longer a.

O_E

b. Loss of NNI-X and NNI-Y for 15 minutes or longer AND

2. SIGNIFICANT TRANSIENT in progress AND

3. Loss of Plant Computer and SPDS

4. Inability to directly monitor any one of the following:

1 Suberiticality Core Cooling Containment Conditions RCS Inventory Basis:

.This Initiating Condition and its associated EAL are intended to recognize the inability of the control room staff to monitor the plant response to a transient.

The Annunciator printer includes the Annunciator CRT display as the display mimics the printer. A loss of both is required to meet the IC.

A loss of Annunciators is considered to be a loss of the visual, as opposed to a loss of the audible portion of the Annunciator.

52

Em:rgency Action Level Basis Document SYSTEM MALFUNCTION Loss ofIndications, continued Basis, continued -

Indications needed to monitor safety functions necessary for protection of the public must include control room indications, computer generated indications and dedicated annunciation capability. The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled and in a coolable geometry, to remove heat from the core, to maintain the reactor coolant system intact, and to maintain containment intact.

Planned and unplanned actions are not differentiated in this EAL since the loss of instrumentation of l

this magnitude is of such significance during a transient, that the cause of the loss does not make the I

condition more tolerable.

I CR-3 Matri: Reference Number:3.8 NEI 97-03

Reference:

SS6 i

4 53 l

1 I

Em:rg:ncy Action Level Basis Document 1

SYSTEM MALFUNCTION 1

Fuel Clad Degradation MODES: ALL Classification:

Unusual Event Initiating Condition:

l RCS specific activity exceeds LCO q

i Emergency Action Level:

Radiochemistry analysis indicates:

{

l (a or b)

)

i

a. Dose Equivalent Iodine (I-131) >1 pCi/gm for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or longer OR 1

i l

b. Specific activity >100/E-bar for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or longer i

I Basis:

)

This Initiating Condition is included as an Unusual Event because it is considered to be a potential degradation in the level of safety of the plant and a potential precursor of more serious problems. This EAL addresses RCS samples exceeding Improved Technical Specifications for radioactivity levels in the RCS.

RCS purification will provide for Iodine and crud cleanup in the reactor coolant system and reduce activity to < 1.0 pCi/gm within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

The EAL values are based on Improved Technical Specification Limits.

E-bar is the weighted average energy of RCS isotopes.

CR-3 Matrix Reference Number:3.9 NEI 97-03

Reference:

SU4 1

54

Em:rgency Action Lcvd Baris Docum:nt SYSTEM MALFUNCTION Turbine Failure MODES: 1,2,3 Classification:

Unusual Event Initiating Condition:

Turbine failure results in casing penetration Emergency Action Level:

Report by plant personnel of turbine failure causing penetration of the turbine casing or damage to main g:nerator seals Basis:

l This EAL is intended to address main turbine rotating component failures of sufficient magnitude to cruse observable damage to the turbine casing or to the seals of the turbine generator. Of major concern in the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen) to the plant environs. Actual fires and flammable gas build up are appropriately classified via Fire and Flammable G:s EALs. This EAL is consistent with the definition of an Unusual Event while maintaining the enticipatory nature desired and recognizing the risk to non-safety related equipment.

Escalation of the emergency classification is based on the potential damage done by missiles generated by the failure. It is not the intent of this Initiating Condition to declare an event based on damage di: covered in a maintenance evolution. Generator seal damage observed after generator purge does not meet the intent of this EAL because it did not impact normal operation of the plant.

CR-3 Matrix Reference Number:3.10 NEI 97-03

Reference:

HU1 1

55

Em:rg:ncy Action Lcvel Basis Document SYSTEM MALFUNCTION

)

l Turbine Failure I

MODES: 1,2,3 Classification:

{

f Alert i

Initiating Condition:

Turbine failure generated projectiles cause significant visible damage to SAFE SHUTDOWN l

l EQUIPMENT Emergency Action Level:

(1 or 2)

1. Report by plant personnel of projectiles generated by a turbine failure causing significant visible damage to any of the following structures:

Auxiliary Building, l

BWST, Control Complex, Diesel Generator Building, EFT-2 Building, Intermediate Building, Reactor Building e

OE

2. Indications show degraded SAFE SHUTDOWN EQUIPMENT perforrnance due to turbine generated projectiles Basis:

This EAL is intended to address the threat to safe shutdown equipment imposed by missiles generated by main turbine rotating component failures. The list of areas includes all areas containing safe shutdown equipment, their controls, and their power supplies. This EAL is, therefore, consistent with th3 definition of an Alert in that if missiles have damaged or penetrated areas containing safety-related equipment the potential exists for substantial degradation of the level of safety of the plant.

This EAL is intended to address events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems.

The initial report is not interpreted as mandating a lengthy damage assessment prior to classification end no attempt is made to asses the actual magnitude of the damage. This EAL is not intended to be used for temporary loss of control room habitability where timely repairs can be affected.

56

1 l

l Emergency Action L.evel Basis Document SYSTEM MALFUNCTION Turbine Failure, continued Basis. continued If damage from the turbine failure is clearly contained and localized to one train, and safe shutdown capability exists, then the EAL is not met. If the extent of the damage is uncertain in terms ofloss of cafe shutdown capability, then entry into this EAL is required.

CR-3 Matrix Reference Number:3.11 NEI 97-03

Reference:

HA1 i

57

r Emerg:ncy Action Level Basis Document SYSTEM MALFUNCTION RCS Leakage MODES: 1,2,3,4 ClassiScation:

Unusual Event Initiating Condition:

RCS leakage Emergency Action Level:

(1 or 2)

1. Unidentified Leakage or Pressure Boundary Leakage 10 gpm

_O_B

2. Identified Leakage 25 gpm Basis:

The terms " identified," " unidentified," and " pressure boundary" leakage are as defined in Improved Technical Specifientions.

This Initiating Condition is included as an Unusual Event because it may be a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant.

The 10 gpm value for the unidentified and pressure boundary leakage was selected as it is observable with normal control room indications. Lesser values must generally be determined through time-consuming surveillance tests (e.g., mass balances). The EAL for identified leakage is set at a higher value due to the lesser significance of identified leakage in comparison to unidentified or pressure boundary leakage.

CR-3 Matrix Reference Number:3.12 NEI 97-03

Reference:

SU5 58

4 Emergency Action Level Basis Document SYSTEM MALFUNCTION 1

Loss of Function (Hot Shutdown)

MODES: 1,2,3,4 f

Classification:

Site Area Emergency Initiating Condition:

Complete loss of core heat removal capability Emergency Action Level:

(1 and 2)

1. Complete loss of Main, Emergency, and Auxiliary Feedwater and unable to establish HPI cooling AND

2. Loss of Subcooling Margin (SCM)

Basis:

This EAL addresses comp!cte loss of functions, including loss of heat removal capability, required for hot shutdown. Under these conditions, there is an actual major failure of a system intended for protection of the public. Thus, declaration of a Site Area Emergency is warranted. The EALs will allow for HPI/PORV cooling upon loss of all feedwater. Subcooling margin may be lost momentarily during this evolution but the ability to establish HPI cooling will not have been lost.

CR-3 Matrix Reference Number:3.13 NEI 97-03

Reference:

SS4 59 J

r Em:rg:ncy Action Level Bnris Document SYSTEM MALFUNCTION Inadvertent Criticality MODES: 2, 3, 4, 5, 6 ClassiScation:

Unusual Event Initiating Condition:

Inadvertent criticality during refueling or shutdown Emergency Action Level:

An extended or unplanned sustained positive startup rate monitored by nuclear instrumentation Basis:

This condition can be identified using the startup rate monitor. The term " extended"is used to allow for exclusion of expected short term positive startup rates from planned fuel bundle or control rod movements during core alterations. The short term startup rates are the result of the increase in neutron population due to suberitical multiplication.

This Initiating Condition /EAL is not intended to classify an early criticality during reactor startup. This i

type event is indicative of errors in reactivity data / calculations and/or mis-operation. The loss of the

{

required shutdown margin can be quickly restored by manual actions or automatic reactor trip.

j CR-3 Matrix Reference Number:3.14 NEI 97-03

Reference:

SU8 1

i i

60

Em:rgency Action Level Baris Docum:nt SYSTEM MALFUNCTION Inability To Maintain Plant In Cold Shutdown MODES: 5, 6 Classification:

Alert Initiating Condition:

Complete loss of functions required for core cooling during refueling and cold shutdown modes Emergency Action Level:

(1 or 2)

1. Inability to maintain reactor coelant temperature below 200*F OR

2. Uncontrolled reactor coolant temperature approaching 200*F Basis:

For PWRs, this Initiating Condition and its associated EAL are based on concerns raised by Generic

- Letter 88-17 " Loss Of Decay Heat Removal." A number of phenomena, such as pressurization, vortexing, steam generator U-tube draining, RCS level differences when operating at a mid-loop condition, decay hrat removal system design and level instrumentation problems can lead to conditions where decay heat removalis lost and core uncovery can occur. NRC analyses show that sequences can cause core uncovery in 15 to 20 minutes, and severe core damage within an hour after decay heat removal is lost. Under these conditions, RCS integrity is lost and fuel clad integrity is lost or permanently lost, which is consistent with a Site Area Emergency. Site-specific indicators for these EALs are those methods used by the plant in response to Generic Letter 88-17, which include core exit temperature monitoring and RCS water level monitoring. In addition radiation monitor readings may also be appropriate as an j

indicator of this condition.

" Uncontrolled" means that system temperature increase is not the result of planned actions by the plant stafT.

The EAL guidance related to uncontrolled temperature rise is necessary to preserve the anticipatory philosophy of NUREG-0654 for events starting from temperatures much lower than the cold shutdown temperature limit.

A momentary UNPLANNED excursion above 200*F when the heat removal function is available is not intended to constitute an alert. Separate statements (1 and 2) are included to recognize additional plant c:pability to maintain cooling of the reactor.

CR-3 Matrix Reference Number:3.15 NEI 97-03

Reference:

NEI-SA3 61

Emergency Action Level Basis Document SYSTEM MALFUNCTION Loss of Water Level in Reactor Vessel That Has or Will Uncover Fuel MODES: 5, 6 Classification:

Site Area Emergency Initiating Condition:

Loss of water level in the reactor vessel that has or will uncover fuel in the reactor vessel Emergency Action Level:

(1 and 2 )

1. Loss of decay heat removal per AP-404 AND

2. (a or b)

Incores indicating superheated conditions a.

_O_ R

. b.

Incores unavailable and time to uncovery exceeded as specified in OP-301 Basis:

Under the conditions specified by this Initiating Condition, severe core damage can occur and reactor coolant system pressure boundary integrity may not be assured. OP-301, " Operation of the Reactor Coolant System," contains time to core uncovery without decay heat removal curves.

For CR-3, this Initiating Condition covers sequences such as prolonged boiling following loss of decay heat removal. Thus, declaration of a Site Area Emergency is warranted under the conditions specified by the Initiating Condition.

Incore indication of superheated conditions is sufficient fbr this EAL since no means of water level indication exists in the active fuel region.

CR 3 Matrix Reference Number:3.16 NEI 97-03

Reference:

SS5 l

1 1

62

Emcrgency Action Level Basis Document LOSS OF POWER Loss of AC Power MODES:ALL Classification:

Unusual Event Initiating Condition:

Loss of All Offsite Power for 15 minutes or longer Emergency Action Level:

(1 and 2)

1. Of6f te Power Transformer (OPT) and Backup ES Transformer (BEST) and Auxiliary Transformer not available for 15 minutes or longer AND

2. EDGs supplying power to required 4160V ES Bus (ses)

Basis:

Prolonged loss of AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete Loss of AC Power (Station Blackout).

Fifteen minutes is used as a threshold to exclude transient or momentary power losses.

Available indicates transformers are capable of energizing required busses.

In Modes 1-4, both ES busses are required to be available.

In Modes 5-6, one ES Bus is required to be available.

CR-3 Matrix Reference Number:4.1 NEI 97-03

Reference:

SUI i

1 63 i

Emergency Action Level Basis Document LOSS OF POWER Loss of AC Power MODES: 1,2,3,4 Classification:

Alert Initiating Condition:

AC power capability to required buses reduced to a single source for 15 minutes or longer such that an additional failure would result in station blackout Emergency Action Level:

AC power capability to the ES 4160V busses reduced to a single power source for 15 minutes or longer such that only one of the following is available:

"A" EDG "B" EDG Offsite Power Transformer (OPT) e Backup ES Transformer (BEST)

Aux Transformer Basis:

This Initiating Condition and the associated EALs are intended to provide an escalation from " Loss of Offsite Power for Greater Than 15 Minutes." The condition indicated by this Initiating Condition is the degradation of the offsite and onsite power systems such that any additional single failure would result in a station blackout.

Available indicates transformers are capable of energizing required busses.

EDG = Emergency Diesel Generator CR-3 Matrix Reference Number:4.2 NEI 97-03

Reference:

SA5 64

Emergency Action Lcvel Basis Document LOSS OF POWER Loss of AC Power MODES: 1,2,3,4 Classi8 cation:

Site Area Emergency Initiating Condition:

Loss of All Offsite and required Onsite AC Power for 15 minutes or longer Emergency Action Level:

Neither 4160 ES bus is capable of being energized within 15 minutes Basis:

Loss of all AC power compromises all plant safety systems requiring electric power including ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prolonged loss of all AC power will cause core uncovering and may challenge containment integrity. The fifteen minute time duration is to exclude transient or momentary power losses.

NOTE:In Modes 5 and 6, the same initiating condition /EAL is an Alert classification.

CR-3 Matrix Reference Number:4.3 NEI 97-03

Reference:

SS1 65

Em::rg:ncy Action Lev:1 Ba:is Document LOSS OF POWER Loss of AC Power MODES: 1,2,3,4 1

Classification:

G:neral Emergency Initiating Condition:

i Prolonged Loss of All Offsite and Onsite AC power Emergency Action Level:

(1 and 2)

1. Neither 4160 ES bus is capable of being energized AND

2. (a or b)

a. Restoration of 4160V ES Bus A pr 4160V ES Bus B is not likely within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> O_E

b. Core exit thermocouples >700*F as indicated on SPDS Basis:

700 F is a good indicator of an extreme challenge to the ability to cool the core and is consistent with the

" potential loss" factor in the Fission Product Barrier Matrix.

Loss of all AC power compromises all plant safety systems requiring electric power including ECCS and the Ultimate Heat Sink. Prolonged loss of all AC power will lead to loss of fuel clad, RCS, and may challenge containment integrity. The four hours to restore AC power is based on the CR-3 station blackout coping analysis performed in conformance with 10 CFR 50.63 and Regulatory Guide 1.155,

" Station Blackout." Although this Initiating Condition may be viewed as redundant to the Fission Product Barrier Matrix, its inclusion is necessary to better assure timely recognition and emergency response.

This Initiating Condition is specified to assure that in the unlikely event of a prolonged station blackout, i

timely recognition of the seriousness of the event occurs and that declaration of a General Emergency occurs as early as is appropriate, based on a reasonable assessment of the event trajectory.

66

Emerg:ncy Action Level Basis Document LOSS OF POWER Loss of AC Power, continued Basis, continued The likelihood of restoring at least one emergency bus should be based on a realistic appraisal of the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions.

CR-3 Matrix Reference Number:4.4 NEI 97-03

Reference:

SG1 1

l i

67

Emrrg:ncy Action Level Basis Document LOSS OF POWER Loss of AC Power (Shutdown)

MODES: 5, 6, No Mode (defueled)

Classification:

Alert Initiating Condition:

Loss of All Offsite and Onsite AC Power to Required Busses During Cold Shutdown or Refueling Mode for 15 minutes or longer Emergency Action Level:

Ntither 4160 ES bus is capable of being energized within 15 minutes Basis:

Loss of all AC power compromisee all plant safety systems requiring electric power including ECCS, Containment 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 temperature and pressure, increasing the time to restore one of the emergency busses, relative to that specified for the Site Area Emergency EAL. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

CR-3 Matrix Reference Number:4.5 NEI 97-03

Reference:

SA1 68

Em::rg:ncy Action Level Basis Document LOSS OF POWER Loss of Vital DC Power MODES: 1,2,3,4 Classification:

Site Area Emergency i

Initiating Condition:

Loss of all Vital DC Power for 15 minutes or longer Emergency Action Level:

Standby Power Status Lights for BUS A1, A2, and BUS B1, B2 on the Main Control Board (SSF Panel) are out Basis:

Loss of all DC power compromises ability to monitor and control plant safety functions. Prolonged loss of cll DC power could cause core uncovery and loss of containment integrity when there is significant decay hrat and sensible heat in the reactor system. Fifteen minutes is used to exclude transient or momentary power losses.

CR-3 Matrix Reference Number:4.6 NEI 97-03

Reference:

SS3 69

I.

Emergency Action Level Basis Document l

LOSS OF POWER Loss of Vital DC Power (Shutdown)

MODES: 5, 6 ClassiScation:

Unusual Event Initiating Condition:

Loss of all Vital DC Power for 15 minutes or longer Emergency Action Level:

Standby Power Status Lights for BUS A1, A2 and BUS B1, U2 on the Main Control Board (SSF Panel) are out Basis:

Loss of required DC power compromises ability to monitor and control plant safety functions. Prolonged lo:s of all DC power could cause core uncovery and loss of containment integrity when there is significant decay heat and sensible heat in the reactor system. Fifteen minutes is used to exclude transient or momentary power losses.

CR-3 Matrix Reference Number:4.7 NEI 97-03

Reference:

SU7 70

Emergency Action Level Basis Document FISSION PRODUCT BARRIER MATRIX BASIS FUEL CLAD LOSS FACTORS 1.

CORE CONDITIONS IN REGION THREE OR SEVERE ACCIDENT REGION OF INADEQUATE CORE COOI2NG CURVES (EOP-07)

The initial core damage assessment curve is used to relate the observable parameters of incore i

temperature and RCS pressure to clad temperature. In region three or the severe accident region,

{

elevated clad temperatures may exceed temperatures that will lead to zirc/ water reactions and rapid

]

failure of the clad will occur if not halted, i

1 ie i

i

".':+ l i M.-Wll.

.; 3 7 t + /

- t-ti-

.y 4 9

.- (

+4 1

_j

"" 4 4 y_ f j jf..

- q..}. /

p 4........L fp + f.

p 4 tr+

j

"- 4 fp 4 fg p

p ;j a j

g "~

^

g 3 3 3j,....... q y 3 p y

)

4 + qf.p y.p g3 E "" 4

.p./ 4 f, i..y.r.,1

/ 4

"- +

E fr y p 3 9 j

+ q

'~ y 3

- p p

( 3 p.....rn......I

'~ 4 3

.j jy

y. y ; y y y

• ~

4 3,43 4 1 p y y y y

'" y 4 g

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o 4 p

u.... en 2.

RCS ACTIVITY >300 pCi/gm I"'

This amount of coolant activity is well above that expected for iodine spikes and corresponds to about I

2% to 5% fuel clad damage. This amount of clad damage indicates significant clad heating and thus the Fuel Clad Barrier is considered lost.

3.

RM-G29 OR 30 >100 R/hrfor 15 minutes or longer Monitor readings have increased and are sustained, not spikes. Readings of >100 R/hr on these monitors indicate activity in the Reactor Building above what would be expected for normal reactor coolant. The IJ minutes will aid in accounting for spikes and uneven mixing that occurs in the initial phases of an RCS leak in the RB. High initial concentrations that accumulate in the upper portion of the RB may lead to erroneous fuel damage assumptions.

4. EC DEEMS FUEL CLAD BARRIER IS LOST Based on Emergency Coordinatorjudgment.

71 I

i Emergency Action Level Basis Document FISSION PRODUCT BARRIER BASIS FUEL CLAD POTENTIAL LOSS FACTORS

]

1 1.

RCS CONDITIONS WARRANTENTRYINTO EOP-07 j

EOP-07 is the " Inadequate Core Cooling" procedure which indicates that there are superheated conditions in the core which may lead to clad degradation, t

2.

CORE EXIT THERMOCOUPLES >700'F 700 F is a good indicator of an extreme challenge to the ability to cool the core. Temperatures are determined using guidance in EOP-07.

3.

EC DEEMS FUEL CLAD BARREER IN JEOPARDY Based on Emergency Coordinatorjudgment.

l 72

e Emergency Action Level Basis Document FISSION PRODUCT BARRIER BASIS RCS LOSS FACTOR 1.

RCS 12AK RESULTING IN LOSS OF ADEQUATE SUBCOOIJNG MARGIN (SCM)

A loss of adequate SCM resulting from RCS leakage would indicate that the rate ofleakage from the RCS is exceeding the rate of addition from the injection system. Therefore, the RCS boundary should be considered lost any time adequate SCM is lost due to leakage.

2.

OTSG TUBE LEAK RESULTING IN LOSS OF ADEQUATE SUBCOOI1NG MARGIN (SCM)

A loss of adequate SCM resulting from RCS leakage would indicate that the rate ofleakage from the RCS is exceeding the rate of addition from the injection system. In addition, with a loss of SCM, accurate RCS inventory cannot be determined. Therefore, the RCS boundary should be considered lost any time adequate SCM is lost due to leakage.

3.

RM-G29 OR 30 > 10 R/hr The reading of > 10 R/hr is a value which indicates the release of reactor coolant to the containment.

The reading is based on RCS activity in normal operation concentrations.

4.

EC DEEMS RCS BARRIER IS LOST

)

Based on Emergency Coordinatorjudgment.

l I

73

Emergency Action Level Basis Document FISSION PRODUCT BARRIER BASIS RCS POTENTIAL LOSS FACTORS 1.

RCS LEAK REQUDtING ONE OR MORE INJECTION VALVES By procedure, the HPI injection valves will be used to increase RCS inventory if pressurizer level cannot be n3aintained greater than 50 inches with letdown isolated. Thus, the use of one or capability and therefore a potential loss of the RCS barrier.

2.

OTSG TUBE LEAK REQUIRENG ONE OR MORE INJECTION VALVES By procedure (EOP-06), the HPI injection valves will be used to increase RCS inventory if pressurizer level cannot be maintained at 220 inches during a tube leak event. Thus, the use of one or more injection valves would indicate leakage in excess of the normal makeup capability and therefore a potential loss of the RCS barrier.

3.

RCS LEAK RESULTS IN ES ACTUATION ON LOW RCS PRESSURE Should the injection system fail or the operator fail to open the injection valves upon a failure of the Makeup system to maintain RCS inventory, RCS pressure will decrease to the ES actuation setpoint.

This potential loss factor in addition to number one (above) will ensure that the RCS barrier will be considered potentially lost for any inability of the makeup system to maintain adequate inventory during a loss of coolant event.

4.

OTSG TUBE LEAK RESULTS IN ES ACTUATION ON LC W RCS PRESS.URE Should the injection system fail or the operator fail to open the injection valves upon a failure of the Makeup system to maintain RCS inventory, RCS pressure will decrease to the ES actuation setpoint.

This potential loss factor in addition to number one (above) will ensure that the RCS barrier will be considered potentially lost for any inability of the Makeup system to maintain adequate inventory during an OTSG tube leak event.

S.

RCS PRESSURE TEMPERATURE RELATIONSHIP VIOLATES NDT LIMITS.

RCS conditions of high pressure accompanied by low temperature increase the potential for Reactor Coolant System brittle failure. This potential loss factor will ensure that the RCS barrier is considered potentially lost whenever the system is at risk of a non-ductile failure.

C. EC DEEMS RCS BARRIER IN JEOPARDY Based on Emergency Coordinatorjudgment.

74

Emergency Action Level Basis Document FISSION PRODUCT BARRIER BASIS CONTAINMENT LOSS FACTORS 1.

RAPID UNEXPIAINED RB PRESSURE DECREASE FOLLOWING INITIAL INCREASE During a loss of coolant event, RB pressure should rise to some value determined by the size of the leak and the response of the RB cooling systems. Following the initial peak, RB pressure should exhibit a steady decreasing trend. Any deviation from this should be the result of a known change in plant status. A rapid decrease of unknown cause is therefore indicative of possible containment failure.

2.

CONTAINMENT PRESSURE OR SUMP LEVEL NOT CONSISTENT WITH LOCA CONDITIONS Sump level or containment pressure Not increasing indicates containment bypass and a loss of containment integrity.

3. AN OTSG HAS TUBE LEAK PER EOP-06. " STEAM GENERATOR TUBE RUPTURE" AND AN UNESOLABLE STEAM LEAK OUTSIDE RB An unisolable steam leak outside the RB on an OTSG with a tube leak would provide a direct leakage path to the environment from the RCS. This " loss" EAL recognizes that steam generator tube leakage can represent a bypass of the containment barrier as well as a loss of the RCS barrier.

The first " loss" EAL addresses the condition in which a ruptured steam generator is also faulted.

This condition represents a bypass of the RCS and containment barriers. In conjunction with RCS Barrier " Potential loss" EAL #2, this would always result in a Site Area Emergency.

4.

CONTAENMENT ISOLATION IS INCOMPLETE AND RELEASE PATH 2D THE ENVIRONMENT EXISTS This factor should be used any time an incomplete RB isolation results in a direct path from the RB atmosphere to the environment. The conditions expected for this EAL would be a known path or a visual indication of the failure or path. Confirmation may be from elevated radiation readings in areas adjacent to the RB.

5.

EC DEEMS CONTAINMENT BARRIER IS LOST Based on Emergency Coordinatorjudgment.

75

Emergency Action Level Basis Document FISSION PRODUCT BARRIER BASIS CONTAINMENT POTENTIAL LOSS FACTORS 1.

RB PRESSURE >54 psig RB design pressure is 54.4 psig. Internal pressure greater than this value has the potential to exceed design leakage values.

2.

RB HYDROGEN CONCENTRATION >4%

l Hydrogen concentrations > 4% are above the lower explosive limit.

3.

RB PRESSURE >30 psig WITH NO BUILDING SPRAY AVAIIABLE The RB spray actuation setpoint is 30 psig. With RB pressure above this value and no spray I

available, the potential exists to exceed the RB design values.

l 4.

RMG-29 OR 30 READINGS >25,000 R/hr l

This monitor reading is indicative of severe core damage conditions and is consistent with the monitor indication listed on the Protective Action Recommendations Table for " core damage indications." Monitor rerdings have increased and are sustained, not spikes. Regardless of whether containment is challenged, this amount of activity in containment, if released, could have such severe consequences that it,is prudent to treat this as a potential loss of containment, such that a l

General Emergency declaration is warranted.

1 5.

CORE CONDITIONS IN SEVERE ACCIDENT REGION OF ICC CURVES FOR GREATER THAN l

15 MINUTES Core conditions in the Severe Accident Region represent imminent melt sequence which, if not corrected within 15 minutes, could lead to vessel failure and an increased potential for containment failure. The Emergency Coordinator should make the declaration as soon as it is determined that the restoration procedures have been, or will be ineffective.

C. EC DEEMS CONTAINMENT BARREER IN JEOPARDY Based on Emergency Coordinatorjudgment.

i 76

Emergency Action Level Basis Document DEFINITIONS ALERT: Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions 3

of the EPA Protective Action Guideline exposure levels.

BOMB: An explosive device (See EXPLOSION)

CIVIL DISTURBANCE: A group of ten (10) or more people violently protesting station operations or j

activities at the site. A civil disturbance is considered violent when force has been used in an attempt to injure site personnel or damage plant property.

EXPLOSION: A rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components.

EXTORTION: An attempt to cause an action at CR-3 by threat of force. Bomb threats that are unsubstantiated are not included in this definition.

1 j

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is NOT required iflarge quantities of smoke and heat are observed.

GENERAL EMERGENCY: Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential loss of containment integrity. Releases can be reasonably be expected to exceed EPA Protective Action Guidelines exposure levels at the SITE BOUNDARY.

HOSTAGE: A person or object held as leverage against the station to ensure that demands will be met by CR-3.

INTRUSION / INTRUDER: Suspected hostile individual present in a protected area without authorization.

PROTECTED AREA: All areas within the CR-3 security perimeter fence that require badged authorization for entry.

SABOTAGE: Deliberate damage, mis-alignment, or mis-operation of safe shutdown equipment with the intent to render the equipment unavailable.

SAFE SHUTDOWN EQUIPMENT: Equipment necessary to achieve and maintain the reactor suberitical with controlled decay heat removal.

77

Emergency Action Level Basis Document DEFINITIONS, continued SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following:

(1) Automatic turbine trip at >25% reactor thermal power (2) Electricalload rejection >25% full electrical load (3) Plant runback (4) Reactor trip (5) Safety injection system actuation (6) >10% thermal power oscillations (7) Loss of decay heat removal in Modes 5 or 6 CITE AREA EMERGENCY: Events are in process or have occurred which involve actual or likely failures of plant functions needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels at the SITE BOUNDARY.

SITE BOUNDARY: That area, including the PROTECTED AREA, that extends 4400 ft. or 0.83 miles in a circle around the Reactor Building. Also referred to as the Owner Controlled Area.

UNPLANNED: An event or action is UNPLANNED ifit is not the expected result of normal operations, testing, or maintenance. Events that result in corrective or mitigative actions being taken in accordance with abnormal or emergency procedures are UNPLANNED.

NOTE: With specific regard to radioactive releases, a release of radioactivity is UNPLANNED if the release is not authorized by a Release Permit or exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.

UNUSUAL EVENT: Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety occurs.

VALID: An indication or report or condition is considered VALID when it is conclusively verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed.

Implicit in this definition is the need for timely a:sessment (e.g., within 15 minutes).

VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analyses. Damage is sufficient to cause concern regarding the continued operability or reliability of affected safety structure, system, or component. Example damage includes:

deformation due to heat or impact, denting, penetration, rupture, cracking, paint blistering. Surface blemishing (e.g., paint chipping, scratches) should not be included.

78

FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 ATTACHMENT C TO LETTER 3F899-23 DEVIATIONS FROM NEI 97-03 DRAFT FINAL REVISION 3 OCTOBER 1998 (FORMERLY NUMARC/NESP-007)

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DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 l

ATTACHMENT D TO LETTER 3F0899-23 1

ISSUES ON CR-3 EAL SUBMITTAL DISCUSSED WITH NRC STAFF DURING TELECONFERENCE CONDUCTED AUGUST 26,1999 1

l l

Responses to NRC Issues Regarding Adoption of New EAL Methodology Page 1 of 3 The following issues were discussed during a teleconference held August 26,1999. FPC's emergency action level (EAL) is identified in bold typeface followed by a brief summary of the U. S. Nuclear Regulatory Commission's (NRC's) question or concern requiring a response. FPC's response is in italic typeface and provides reference to correponding changes made to the EALs, basis documents, or Deviation Matrix, as necessary.

EAL 1.9 (also EAL 1.10.2) (NUMARC/NESP-007 AU2-1, AA2-2)

In your July 13,1999 submittal, you explained that your EAL did not include a setpoint for a water level decrease in the refueling cavity because there is no water level indication. Ilowever, the NUMARC EAL does not specify a water level but rather a water level decrease. It seems that there may be other means for detecting a water level decrease in the reactor refueling cavity or that a general statement regarding water level decrease could be included for this condition.

During the teleconference, FPC explained that the termfuel transfer canal at CR-3 is equivalent to refueling cavity. Upon understanding this, the NRC sta.8 participants stated nofurther action was required. Nevertheless, a change was made to the Deviation Afatrixfor this EAL providing this clan)ication.

EAL 2.11 (NUMARC/NESP-007 AUI)

In your July 13,1999 submittal, the basis of this EAL was revised to state "The initiating condition only applies to areas that do not require continuous occupancy." This wording is confusing and raises a concern regarding classification of events where continuous occupation (such as the control room) is affected by toxic gas. Please address this concern.

FPC recognizes the source of the concern and made the necessary changes to EAL 2.11 and its basis document. A new EAL 2 was added to read " Toxic Gas levels klDLH levels in areas that require continuous occupancy to maintain safe operations or establish or maintain cold shutdown. " The previous EAL 2 was renumbered to EAL 3. Other changes were made to the basis document as noted in Attachment B.

EAL 2.15 (NUMARC/NESP-007 HAl-4)

In your July 13,1999 submittal, the basis of this EAL was revised to state: "If damage from the fire is clearly contained and localized to one train, then safe shutdown equipment is not affected and the EAL is not met. If the extent of the damage is uncertain in terms of loss of safe shutdown equipment, then entry into this EAL is required."

Although the NRC agrees that it is beneficial to restrict the applicability of the fire event EAL so that j

minor fires which are localized, under control and only affect a single train of a safety related system would not be declared as an Alert, the proposed revision to limit the applicability of the EAL by defining when " safe shutdown equipment is considered to be affected" does not appear to be appropriate. A fire causing damage to safety related equipment clearly affects that equipment. It appears that a different method of constraining the applicability of this EAL is needed. In addition, a similar limiting condition for a tornado does not appear to be appropriate.

Responses to NRC Issues Regarding Adoption of New EAL Methodology Page 2 of 3 1

During the August 26,1999 teleconference, proposed changes to this statement were discussed.

These are reflected in the revised basis documentfor EAL 2.15provided with this submittal.

Similar changes were made to EALs 2.4, Flood 2.9, Aircraft / Vehicle Crash, 2.13, Explosions / Catastrophic Pressurized System Failure, 2.23, Internal Flooding, and 3.11, Turbine Failure. The limitationspreviously addedfor EALs 2.2, Earthquake Erperience, and 2.7, Tornado /High Winds, were deleted.

EAL 3.16 (NUMARC/NESP-007 SS5-1)

In your July 13,1999 submittal, the basis of this EAL was revised to state:

"1.

Loss of decay heat removal per AP-404 AND 2.a incores indicating superheated conditions OR 2.b Incores unavailable and time to uncovery exceeded as specified in OP-301."

It is not clear that the revised EAL is consistent wih the guidance in NUMARC/NESP-007. In particular, NUMARC refers to a loss of water level that may uncover the core. Your EAL does not refer to a loss of water level. Is an incore indicating superheated conditions used as an indication of core uncovery? If so, is this a better indication of this condition than water level? In addition, it seems that it would be appropriate to include a water level indication EAL under this IC. Finally, the deviation document is not consistent with the current EAL.

FPC explained during the August 26,1999 teleconference that core level indication is not used at CR-3 as an indication of core uncovery. The reactor coolant inventory tracking system (RCITS) provides a measurement of water levelin the reactor vessel head region. It does not measure water levelin the activefuel region. At CR-3, superheated conditions is an effective indication of core uncovery since there is no reactor vessel water levelindication in the activefuel region of the core.

This clarification was made to the basis documentfor EAL 3.16 and the explanation was included in the deviation matrixfor EAL SS-5.

EAL Fission Product Barrier (FPB) - Loss of Containment based upon Steam Generator Leak The CR EAL is "An OTSG has tube leak and unisolable steam leak outside RB per EOP-06" The NUMARC EAL is

" Release of secondary side to atmosphere with primary to secondary leakage greater than tech spec allowable" The NEI 97-03 EAL is

" Primary-to-secondary leak rate greater than 10 gpm with nonisolable steam release from affected S/G to the environment"

mmim ine Responses to NRC lssues Regarding Adoption of New EAL Methodology Page 3 of 3 Please describe the relationship between the CR EAL and the NUMARC and NEI 97-03 EALs and justify any deviations.

FPC explained during the August 26,1999 teleconference that the entry conditions of EOP-06 is greater than 1 gym OTSG tube leakage and no decay heat in operation. The NRCparticipants acknowledged the 1 gym leak rate is conservative to the 10 gym NEI criteria. FPC agreed to reference the EOP-06 entry conditions in the deviation matrixfor this EAL. In addition, for clarity, it was determined that the EAL statement should be revised to read "An OTSG has tube leak per E0P-06 SGTR and an unisolable steam leak outside RB. " This wording change was also inade to the basis documentfor this EAL.

EAL Fission Product Barrier (FPB) - Loss of Containment based upon ICC Curves The July 13,1999 submittal did not address the staff's concern regarding why a serpoint based upon reactor vessel level was not included as is provided in the NUMARC guidance.

FPC explained during the August 26,1999 teleconference that there is no reactor vessel water levelindication in the activefu*l region of the core at CR-3. This clarification was included in the deviation matrixfor this EAL

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