ML20212C265

Forwards Addl Info Requested Re EAL Rev to NUMARC/NESP-007 Methodology

ML20212C265
Person / Time
Site:	Catawba
Issue date:	10/21/1997
From:	Gordon Peterson DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-M96519, TAC-M96520, NUDOCS 9710290142
Download: ML20212C265 (125)

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Duke Power Company '

A Ikke Ewy Compxy Cttawba Nuclear Station

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4800 Concord Road York, SC 29745

. Gary R. Meteoa - (803) 831-4251 omcr Mce besident (803J 831-3426Mx October 21, 1997 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

Subject:

Catawba Nuclear Station Docket Nos. 50-413, 50-414 License Nos. NPF-35, NPF-52 Classification Scht a of Emergency Action Levels (NRC TAC M96519 and M96520)

Ref.: 1) Emergency Plan Change Submittal dated August 29,1996 2)NRC Request for Additional Information Regarding Emergency Action Level Revision to NUMARC/NESP-007 Methodology dated January 14, 1997

3) Duke Power Response to Request for Additional Information Regarding Emergency Action Level Revision to NUMARC/NESP-007 Methodology, dated March 29, 1997 Attachment 1 contains the additional information requested by Larry Cohen, Bill Meier and Vic Nerses on June 23, 1997, regarding Catawba's Emergency Action Level Revision to NUMARC/NESP-007 Methodolc>gy. Please contact Gary Mitchell at (803) 831-3235 if there are any questions on this information.

Yours tru

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, f G. R. Peterson [f) ,

Vice President /U  !

9710290142 971021 "

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Attachment 1 Re,sponse to NRC Ouestions a

Catawba Emergency Action Levels submitted August 29, 1996 and Response to Request for Additional Information discussed in a- conference call June 23, 1997 Revision to Fission Product Barrier Matrix The Catawba Emergency Planning Group performed a review of issues l from the March 1997 exercise at Three Mile Island. As a result of this review, the following note is being added to the Fission Product Barrier Matrix:

Note 3: When determining Fission Product Barrier status, the Fuel Clad Barrier should be considered to be lost or potentially lost if the conditions fo?. the Fuel Clad Barrier loss or potential loss EALs were met previously during the 3 event, even if the conditions do not currently exist.

4 Q1: Have the changes made as a result of the NRC's request for additional information (RAI) been discussed and agreed upon with the offsite authorities (State and local) ? If so, are there letters of agreement you can submit on the docket to verify that agreement?

A1: No, these changes have not been discussed and agreed upon with the offsite authorities. Duke Energy will review the NRC approved NUMARC/NESP-007 based classification scheme with the offsite authorities and receive their agreement prior to implementation.

Q2, NUMARC IC AUl, AA1; Duke IC 4.3.U.1, 4.3.A.1: The NUMARC ICs address effluent releases that are multiples of tne Radiological Tech. Specs. The basis for the NUMARC ICs allows the use of the instantaneous release rate limit contained in the ODOM for plants that have eliminaced the RETS. The Duke plants list Selected Licensee Commitments (SLC) as the source of the referenced release rate limit although the limit is also contained in the ODCM, which is an NRC controlled document and part of the license. What is the reason for referencing the SLC rather than the ODCM if the information is contained in the ODCM as well?

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d e A2: Duke Power amended:our Technical Specifications and relocated-the Radiological' Effluent _ Technical Specifications-(RETS) to the. respective stations Selected: Licensee j- Commitroent -(SLC) Manual. This amendment was requested for  :

all-three sites _on' February 7, 1990, and was approved on May

- _22, 1991, in Tech. Spec. Amendment 119 for McGuire Unit 1 and 1011for McGuire Unit 2, and on December 9, 1992,.in i Tech. Spec. Amendment 97 for Catawba Unit 1 and 52 for

{ Catawba Unit 2.- The SLC manual is Chapter -16 of the site's

j. FSAR and.is controlled by the 10CFR50.59 process.

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j Q3, NUMARC IC AS1, AG); Duke IC 4.3.S.1, 4.3.G.1: The bases for j the NUMARC ICs states that "the FSAR source terms applicable to ~

each monitored pathway should be used.in conjunction'with annual

! average meteorology in determining indications for the monitors i in that pathway." A draft NEI white paper, dated 9/10/94, stated l that the use of the FSAR accident source term without f modification could result in conservative EAL thresholds i.nd

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possible overlap with the Alert thre,shold. This white pr.per

!- recommends the uce of a " reasonable" source term. The

i. information submitted in the response to the RAI-indicates that

! -the source term considered in the derivation of the. Duke 1

' thresholds for monitors is from the ODCM methodology (assumed

.value for "K") . What is the rationale for.using the ODCM isotopic mix for the higher level EALs that are associated with some (accident) level of core damage? Has this assumed isotopic mix been modified in any way?

A3: Duke Energy originally looked at accident source terms in performing detailed monitor' response calculations for the Site Area Emergency and General Emergency classifications, but experienced significant overlap between the Alert and Site-Area Emergency classification monitor readings. The primary reason for the monitor reading overlap was the assumed dif ference in source term -isotopic spectrum in calculating site boundary dose rates that would cause an Alert or Site Area Emergency classification.- The NUMARC EALs work backwards from a site boundary dose rate to.

determine monitor readings,.and the monitor response is not linearly proportional to dose. For example, the Total Body _ dose conversion factor for Ar-41 (1.8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> half-life) is about 30. times higher than Xe-133, but the monitor response is less than 3 times _ higher. If you a assume a-

" hotter" (higher energy) spectrum, it takes significantly fewer counts on the monitor to get an equivalent dose at the site boundary, and, therefore, monitor reading overlap can occur.

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- .. -. . - .. = . . .

To elimina'3 the overlap, Duke Energy decided to use a consistent source term throughout. Xe-133 was chosen since it is the predominant noble gas isotope released during normal operations (e.g., 97% of Catawba noble gas in 1996) and the NUMARC EALs use site normal operating release rate limits'as its starting point. Our attempt at a " reasonable" FSAR source term assumption resulted in significant monitor reading overlap, and we decided not to artificially adjust the FSAR source terms without any real basis to " solve" the overlap problem. The fact is that post-accident source terms will be continually changing, and will be extremely accident and time dependent.

Duke Energy also looked at this problem from'the context that it is very unlikely that a Site Area Emergency would be classified based on a radiation monitor reading. From experience we know that accident classification will be made primarily based on plant conditions. In addition, we have implemented on-shift dose assessment. Our on-shift dose assessment tool takes into account real time meteorology and accident source term spectra. The radiation monitor readings will be used to classify the higher emergency classifications only if dose assessment cannot be completed within 15 minutes.

The NUMARC EALs start with the 500 mrem /yr (= 0.05 mrem /hr) basis and then use multiples of that release rate for the four classifications (Unusual Event,-Alert, Site Area Emergency, General Emergency). To mccount for the higher energy ESAR source term for a Site Area Emergency and General Emergency, we have made the multiple from the Alert to the Site Area Emergency a factor of 5 rather than 10.

This adjusts the monitor reading for a higher energy accident spectrum and prevents overlap, while removing the non-conservatism of using t;.e factor of 10 multiple between each of the four emergency classes. See attachments 3, 4 and 5 for revised Emergency Action Levels.

Q4, NUMARC IC AA2; Duke IC 4.3.A.2: The disposition cross-reference lists Duke EAL 4.3.A.2-3 as being equivalent to both AA2.3 and AA2.4 in the NUMARC scheme. Since EAL 4.3.A.2-3 only lists a level for the NC System and only applies to cases in which KF-122 cannot be closed, it is unclear how this EAL is equivalent to NUMARC EAL AAc. 4 for cases in which KE-122 is closed. I recognize that Duke EAL 4.3.A.2-2 is listed as equivalent to NUMARC AA2.2, but there doesn' t seem to be an equivalent EAL in the Duke scheme that gives a preemptive spent fuel pool level for making a timely declaration for cases in which the transfer valve is closed.

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A4: Catawba agrees. The reference to KF-122 has been deleted from EAL 4.3.A.2-3. EAL 4.3.A.2-4 has been added to address NUMARC EAL AA2.4 See attachments 3, 4 and 5 for the revised EALs.

05, NUMARC IC AA3; Duke IC 4.3.A.3: For EAL 4.3.A.3-3, it is unclear how a classifying official (especially one on-shift) can determine, in a timely manner, when the EAL is satisfied. Is the declaration of this EAL contingent on the personnel expected to perform the safe shutdown activities, since the margin to the TEDE limit is dependent on the existing annual occupational dose?

Is the classifying official expected to estimate the time to perform the necessary tasks? Why isn't the EAL threshold based on a radiation level that is derived from estimated task duration and an assumed pre-existing dose?

A5: We agree that the EAL needs to be clear to a classifying official and should not be personnel dependent. Catawba has chosen for EAL 4.3.A.3-3 to use a generic emergency action level of greater than or equal to 5000 mrad /hr for areas in the plant that are normally accessible as low dose rate areas that have equipment installed, operated, and used for.

safe operation or safe shutdown of the unit. This value has been chosen for the following reasons: (1) to be consistent with equivalent NUMARC/NESP-007 based Emergency Action Levels implemented at Oconee, and (2) radiation levels at or above this range may make it difficult to complete tasi.

necessary for safe operation of the plant or to establish or maintain cold shutdown without exceeding normal occupational dose limits of 5 Rem per year TEDE. The EAL has been modified to include area monitor numbers and the location of the area monitor. Also, similar information has been added to EAL 4.3.U.2-3. See attachments 3,4 and 5 for revised EALs and basis.

Q6, NUMARC SS4; Duke IC 4.4.S.2: I can accept the use of the CSFSTs as the indicators for this IC, but there appears to be a conflict in the classification of a Core Cooling - RED path between this EAL and 4.1.F.1 on the Fission Product Barrier matrix. A person classifying a Core Cooling - RED condition by referring to the matrix would classify it as an Alert condition, instead of the SAE called for in 4.4.S.2. This conflict needs to be resolved.

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A6: Catawba agrees. We have deleted EAL 4.4.S.2-2, " Core Cooling CSF - RED" and renumbered the remaining EALs.

Ultimate heat sink and reactivity control are specifically mentioned in the NUMARC IC SS4 basis, so that the core cooling reference is not needed here. A Core Cooling CSF -

RED condition is classified as an Alert condition under EAL 4.1. F.1. This eliminates the conflict. See attachments 3, 4 and 5 for the revised EALs.

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U.S. NRC October 21, 1997 Page 2 xc:

L. A. Reyes, Regional Administrator USNRC,-Region II (2 copies)

Peter Tam, Project Manager CNS USNRC, ONRR V. Nerses, Project Manager MNS USNRC, ONRR

Darrell Roberts, Senior Resident Inspector Catawba Nuclear Station l

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. .i List of Attachments

- 1. Responses to Issues 1-6 from June 23, 1997. conference call l

= 2.-Revised Disposition of NUMARC/NESP-007,. Rev. 2 Initiating Conditions and Emergency. Action Levels.in the Catawba'EAL l Submittal-

3. Revised Catawba Emergency ' Plan Section D pages with Revision J Marks 4 Revised Catawba Emergency Plan Section D pages without i LRevision Marks (Includes a complete copy of section D due to i page number _ changes).

4 3. Revised Catawba Emergency Plan Implementing Procedure

! RP/0/A/5000/01 pages:with Revision Marks (Includes a complete 3- copy of RP/0/A.'5000/01) i I

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ATTACHMENT 1 Responses to Issues 1-6 from JUNE 23,1997 Conference Call

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ATTACHMENT 2

Revised Disposition of NUMARC/NESP-007, Rev. 2 l Initiating Conditions and Emergency Action Levels in Catawba 'EAL' Submittal I

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Catawba Nuclear Site 2

Disposition of NUM ARC /NESP-007. Rev. 2 IC/EAL in Catawba EAL Submittal NUMARC IC/EAL Catawba EAL Recognition Category and EAL Number -

Recognition Category A

, AUl/l Abnormal Rad Levels / Radiological Effluent 4.3.U.i I and 2 .

AU1/2 Abnormal Rad Levels / Radiological Effluent 4.3.U.l 3 and -4

- AUl/3 Deleted -- Catawba does not have perimeter monitors AUl/4 Deleted - Catawba does not have automatic real time dose assessment AU2/1 Abnormal Rad Levels / Radiological Effluent 4.3 U.21 AU2/2 Abnormal Rad Levels / Radiological Effluent 4.3.U.2-2 AU2/3 Deleted - Catawba does not have dry fuel storage AU2/4 Abnormal Rad Levels / Radiological Effluent 4.3.U.2 3 l AAl/1 Abnormal Rad Levels / Radiological Effluent 4.3.A.1-1 and -2 AA1/2 l Abnormal Rad Levels / Radiological Effluent 4.3.A.1-3 and -4 i AAl/3 Deleted -- Catawba does not have perimeter monitors AAl/4 Deleted - Catawba does not have automatic real time dose assessment AA2/1 Abnormal Rad LevelsT. .diological Effluent 4.3.A.2 1 AA2/2 Abnormal Rad Levels / Radiological Effluent 4.3.A.2 2

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AA2/3 Abnormal Rad Levels / Radiological Effluent 4.3.A.2 3 l AA2/4 Abnormal Rad Levels / Radiological Effluent 4.3.A.2-1,4 AA3/1 Abnormal Rad Levels / Radiological Effluent 4.3.A.31 and 2 AA3/2 Abnormal Rad Levels / Radiological Effluent 4.3.A.3-3 ASl/l Abnormal Rad Levels / Radiological Effluent 4.3.S.1 1 ASI/2 Deleted -- Catawba does not have perimeter monitors AS1/3 Abnormal Rad Levels / Radiological Effluent 4.3.S.1 2 ASl/4 Abnormal Rad Levels / Radiological Ef0uent 4.3.S.1 3 AOl/l Abnormal Rad LevelvRad41ogical Effluent 4.3.0.1 1 AGI/2 l Deleted - Catawba coes not have perimeter monitors  ;

AOl/3 Abnormal Rad Levels /Radiolog! col Effluent 4.3.0.12 AOl/4 Abnormal Rad Levels / Radiological Effluent 4.3.0.1 3 d

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{ Catawba Nuclear Site  !

Disposition of NUM ARC /NESP-007, Rev. 2 IC/EAL in Catawba EAL Submittal I j NUMARC IC/EAL Catawba EAL Recognition Category and EAL Number i

Recognition Category 5

) SUl/l Loss of Power 4.5.U.1-1

, SU2/1 System Malfunction 4.2.U.1 1

, SU3/1 System Malfunction 4.2.U.2 1

SU4/1 Deleted - Catawba has no failed fuel monitor. Reactor coolant i

sampling is used to determine fuel clad degradation, SU4/2 System Malfunction 4.2.U.31 - Aeolles in Modes 15 on!v because the l Technical Soecification aoolies only in these modes.

SUS /l System Malfunction 4.2.0.41, 2, and 3 l SU6/1 System Malfunction 4.2.U.51 and 2

SU7/1 Loss of Power 4.5.U.2 1 sal /l Loss of Power 4.5.A.1-1

) SA2/1 Loss of Shutdown Function 4.4.A.1 1

} SA3/1 Loss of Shutdown Function 4.4.A.21 SA4/1 System Malfunction 4.2.A.1 1 i

! SAS/l Loss of Power 4.5.A.2-1 j SS1/1 Loss of Power 4.5.S.1-1 4

SS2/1 Loss of Shutdown Function 4.4.S.1-1 -

4 SS3/1 Loss of Power 4.5.S.2 1 SS4/1 Loss of Shutdown Function 4.4.S.21, and 2

! lSS5/1 Loss of Shutdown Function 4.4.S.3 1. and 2, and-3 SS6/1 System Malfunction 4.2.S.1-1

SGl/l Loss of Power 4.5.0.1 1

) SG2/1 and 2 Loss of Shutdown Function 4.4.0.1 1 2

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Catawba Nuclear Site 1

Disposition of NUMARC/NESP-007. Rev. 2 IC/EAL in Catawba EAL Submittal NUMARC IC/EAL Catawba EAL Recognition Category and EAL Number Recognition Category A .' '

l AUl/l Abnormal Rad Levels / Radiological Effluent 4.3 U l.1 and .2 ,

AUl/2 Abnormal Rad Levels /Radiolog: cal Effluent 4.3.U.1-3 and 4 i

} AUl/3 Deleted Catawba does r.ot have perimeter monitors j AUl/4 Deleted - Catawba does not have automatic real time dose assessment AU2/1 Abnormal Rad Levels / Radiological Effluent 4.3.U.2 1 j AU2/2 - Abnormal Rad Levels / Radiological Effluent 4.3.U.2 2

AU2/3 Deleted -- Catawba does not have dry fuel storage >

.! AU2/4 Abnormal Rad Levels / Radiological Effluent 4.3.U.2 3 l AAl/1 Abnormal Rad Levels / Radiological Effluent 4.3.A.1-1 and 2

! AA1/2 Abnormal Rad Levels / Radiological Effluent 4.3.A.1 3 and -4

, AAl/3 Deleted -- Catawba does not have perimeter monitors AAl/4 I '

Deleted -- Catawba does not have automatic real time dose assessment j AA2/1 Abnormal Rad Levels / Radiological Effluent 4.3.A.2 1 AA2/2 Abnormal Rad Levels / Radiological Effluent 4.3.A.2 2 AA2/3 Abnormal Rad Levels / Radiological Effluent 4.3.A.2-3 AA2/4 Abnormal Rad Levels / Radiological Effluent 4.3.A.2-4 AA3/1 Abnormal Rad Levels / Radiological Effluent 4.3.A.3 1 and -2 AA3/2 - Abnormal Rad Levels / Radiological Effluent 4.3.A.3 3 AS1/1 Abnormal Rad Levels / Radiological Elfluent 4.3.S.1-1

'ASI/2 Deleted -- Catawba does not have perimeter monitors ASI/3 Abnormal Rad Levels / Radiological Effluent 4.3.S.1-2 ASl/4 Abnormal Rad Levels / Radiological Effluent 4.3.S.I 3 AGl/l Abnormal Rad Levels / Radiological Effluent 4.3.G.1-1 AGl/2 Deleted - Catawba does not have perimeter monitors ,

AG1/3 Abnormal Rad Levels / Radiological Effluent 4.3.G.1-2 ,

AGl/4 Abnormal Rad Levels / Radiological Effluent 4.3.G.1-3 i

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. 1 Catawba Nuclear Site Disposition of NUMARC/NESP-007 Rev. 2 IC/EAL in Catawba EAI, Submittal NUMARC IC/EAL Catawba EAL Recognition Category and EAL Number Recognhlon Category S SUl/l Loss of Power 4.5.U 1 1

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i SU2/1 System Malfunction 4.2.U.1 1 SU3/1 System Malfunction 4.2.U.2-1 SU4/1 Deleted - Catawba has no failed fuel monitor Reactor coolant sampling is used to determine fuel clad degradation.

SU4/2 System Malfunction 4.2.U.31 - Applies in Modes 1-5 only because the Technical Specification applies only in these modes.

SU5/1 System Malfunction 4.2.U.4-1,-2, and 3  :

SU6/1 System Malfunction 4.2.U.51 and 2 SU7/1 Loss of Power 4.5.U.2-1 sal /l Loss of Power 4.5.A.1 1 SA2/1 Loss of Shutdown Function 4.4.A.1 1 SA3/1 Loss of Shutdown Function 4.4.A.2 1 SA4/1 System Malfunction 4.2.A.1 1 SAS/l Loss of Power 4.5.A.2 1 SSl/l Loss of Power 4.5.S.1-1 SS2/1 Loss of Shutdown Function 4.4.S.1 1 SS3/1 Loss of Power 4.5.S.2-1 SS4/1 Loss of Shutdown Function 4.4.S.2-1, and .2 SS5/l Loss of Shutdown Function 4.4.S.3-1, and -2, SS6/1 System Malfunction 4.2.S.1-1 SGl/l Loss of Power 4.5.G.1-1 SG2/1 and 2 Loss of Shutdown Function 4.4.G.1-1 S. '

Cataw ba Nuclear Site ENCLOSLRE 4.3 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT UNUSUAL EVENT 4.3.U.1 Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds Two Times the SLC Limits for 60 Minutes or Longer.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.3.U.1 1 A valid Trip 2 alarm on radiation monitor EMF-49L or EMF 57 for a 60 minutes or will likely continue for 260 minutes which indicates that the release may have exceeded the initiating condition and indicates the need to assess the release with procedure HP/0/B/1009/14.

4.3.U.l.2 A valid indication on radiation monitor EMF-36L of 2 !.0SE :04 5.4E+03 cpm for 2 l 60 minutes or will likely continue for 260 minutes which indicates that the release >

may have exceeded the initiating condition and indicates the need to assess the release with procedure HP/0/B/1009/25.

4.3.U.13 Gaseous effluent being released exceeds two times SLC 16.11-1 for 2 60 minutes as determined by Radiation Protection (RP) procedure.

4.3.U.1-4 Liquid effluent being released exceeds two times SLC 16.11-6 for 2 60 minutes as determined by RP procedure.

NOTE: Il monitor reading is sustained for the time period indicated in the EAL and the required assessments (procedure calculations) cannot be completed within this time period, declaration must be made based on the valid radiation monitor reading.

4 BASIS:

The term " Unplanned", as used in this context, includes any release for which a liquid waste release (LWR) or gaseous waste release (GWR) package was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm set points) on the applicable package.

Valid means that a radiation monitor reading has been confirmed to be correct.  ;

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.. Catawba Nuclear Site ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT UNUSUAL EVENT 4.3.U.2 Unexpected increase in Plant Radiation or Airborne Concentration.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

1 4.3 U.21 Indication of uncontrolled water level decrease of greater than 6 inches in the reactor refueling cavity with allirradiated fuel assemblies remaining covered by water.

4.3.U.2 2 Uncontrolled water level decrease of greater than 6 inches in the spent fuel pool and l

a fuel transfer canal with all irradiated fuel assemblies remaining covered by water.

4.3.U.2 3 Unplanned valid area radiation monitor (EMF) reading increases by a factor of 1000 l over normal levels. as shown in Enclosure 4.10 of RP/0/A/5000/01, i BASIS:

Valid means that a radiation monitor reading has been confirmed to be correct.

All of the above events tend to have long lead times relative to potential for radiological release outside the site boundary; thus, impact to public health and safety is very low. ,-

In light of reactor chvity seal failure incidents. explicit coverage of these types of events via EALs I and 2 is appropriate given their potential for increased doses to plant staff. A threshold value of 6 inches is used to allow time for mitigating actions to successfully terminate the inventory loss, Credit should not be taken for inventory additions to maintain level above the 6 inch threshold. Classification as an Unusual Event is warranted as a precursor to a more serious event.

EAL 3 addresses unplanned increases in in plant radiation levels that represent a degradation in the control of radioactive material, and represent a potential degradation in the level of safety of the plant. ne EMF readinns for an Unusual Event are 1000 times the rv>rmal value.

Enclosure 4.10 of RP/0/A/500W01 will orovide the actual readings for these monitors. This EAL escalates to an Alert if the increases impair safe operation.

REFERENCE:

NUMARC/NESP 007, REV. 2, Oh92, AU2 D 22

/ Catawbo Nuclect Site ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ALERT 4.3.A.1 Any Unplanned Releadof Gaseous or Liquid Radioactivity to the h.nvironment that Exceeds 200 Times the SLC limits for 15 Minutes or Longer.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.3.A.1 1 A valid indication on radiation monitor EMF-49L or EMF 57 of21.2E+05 cpm for 215 minutes or will likely continue for 215 minutes which indicates that the release may have exceeded the initiating condition and indicates the need to assess the release with procedure HP/0/B/1009/14. ,

l 4.3.A.I.2 A valid indication on radiation monitor EMF 36L of 2.,1.08E 2 5.4E405 cpm for 215 minutes or will likely continue for 215 minutes which indicates that the release .

may have exceeded the initiating condition and indicates the need to assess the release I with procedure HP/0/B/1009/25.

4.3.A.I.3 Gaseous effluent being released exceeds 200 times the level of SLC 16.11-1 for 215 minutes as determined by RP procedure.

4.3.A.1-4 Liquid effluent being released exceeds 200 times the level of SLC 16.116 for 215 minutes as determined by RP procedure.

NOTE: If monitor reading is sustained for the time period indicated in the EAL and the required assessments (procedure calculations) cannot be completed within this time period, declaration must be made based on the valid radiation monitor reading.

BASIS:

The term " Unplanned", as used in this context, includes any release for which a liquid waste release (LWR) or gaseous waste release (GWR) package was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm set points) on the applicable package.

Valid means that a radiation monitor reading has been confirmed to be correct.

This event escalates from the Unusual Event by escalating the magnitude of the release by a factor of 100.

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Cataw ba Nuclear Site ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ALERT 4.3.A.2 Major Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.3.A.21 An unplanned valid trip II alarm on any of the following radiation monitors:

a. Spent Fuel Building Refueling Bridge 1 EMF-15 2 EMF-4

b. Spent Fuel Pool Ventilation IEMF-42 2 EMF 42

c. Reactor Building Refueling Bridge i

IEMF 17 2 EMF-2 l

d. Containment Noble Gas Monitors 1 EMF 39 2 EMF 39

) 4.3.A.2 2 Plant personnel report that water level drop in reactor refueling cavity, spent fuel pool, or fuel transfer canal has or will exceed makeup capacity such that any irradiated fuel will become uncovered.

4 4.3.A.2-3 NC system wide range level < 95 % after initiation of NC system make-up AND

Any irradiated fuel assembly not capable of being lowered into spent fuel pool or reactor vessel.

ANO-YJ l22 =r S &M D 25

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,- Cataobo Nuclear Site 4.3.A.24 Soent make up Fuel Pool or Fuel Transfer Canal level decrease of >2 feet after initiation of M!iR Any irradiated fuel assembly not capable of being fully lowered into the spent fuel pool racks or transfer canal fuel transfer system basket.

BASIS:

This IC applies to spent fuel requiring water coverage. 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 Level / Radiological Effluent or Emergency Coordinator / EOF Director Judgment.

EAL 2: Due to concems for ALARA and personnel safety, personnel should not remain in the area to observe that irradiated fuel is uncovered. Personnel should exit the area as quickly as possible and report the occurrence to the Control Room.

REFERENCE:

NUMARC/NESP 007, REV. 2. 01/92. AA2 D 26

, ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT i

ALERT 4.3.A.3 Release of Radioactive 51aterial or Increases in Radiation Levels Within the Facility That Impedes Operation of Systems Required to Staintain Safe Operations or to Establish or Staintain Cold Shutdown.

OPERATING 510DE APPLICABILITY: All i

ES!ERGENCY ACTION LEVELS:

l 4.3.A.31 Valid reading on EMF.12 greater than 15 mR/hr in the Control Room.

i 4.3.A.3 2 Valid indication of radiation levels greater than 15 mR/hr in the Central Alarm Station (CAS) or Secondary Alarm Station (S AS).

4.3.A.3 3 R d!dr Sch ! =r =;;i.":; !"=;:r: r:= = =S 'he ' ^: x f:I e

.dn'd: rS :enr!:r = : =d!'S = =d:::!: r!d de :: :r:r S

n= ri &l

...... ..

.!::d =;== !! l': :f 5 ":= ;= y= "DE.

Valid radiation monitor reading exceeds the limits shown in Enclosure 4.10 of RP/0/A/5700/00.

1 I

{ BASIS:

I Valid means that a radiation monitor reading has been confirmed to be correct. ,

This initiating condition (IC) addresses increased radiation levels that impede necessary access to i

operating stations, or other areas containing equipment that must be operated manually,in order to maintain safe operation or perform a 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. P2dir!r brii: &; fri!!r/ :r' $c tr4: :-- .r h ;: ' c;d C$r: =x:f!:; 5 P; pc y: "" ri!! '- ;:d: rrx de: :: $: xxd f= : P!rnd S;xid E:;x:= =

P!r -d ":.. - ; S;xn This situation is indicative of a significant radiological problem that warrants additional resources to assess and mitigate.

This IC is not intended to apply to anticipated temporary increases due to planned events (e.g.. incore

detector movement, radwaste container movement, depleted resin traasfers, etc.)

i The Control Room, CAS, and S AS are areas that require continuous occupancy. 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.

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,=

Catawba Nuclear Site Catawba has chosen to use a generic emergency action level of creater than or eaual to 5000 mrad /hr for areas in the olant that are normally accessible as low dose rate areas that have cauioment installed. operated. and used for safe operation or safe shutdown of the unit.

Radiation levels at or above this ranne may make it difficult to complete tasks necessary for safe operation of the olant or to establish or maintain cold shutdown without exceeding normal occupational dose limits of 5 Rem oer year TEDE. Enclosure 4.10 of RP/0/A/5000/01 provides the monitor number and the location of the area monitor.

REFERENCE:

NUMARC/NESP 007, REV. 2,0992, AA3 D 28

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Cataw ba Nuclear site ABNORMAL RAI) LEVELS / RADIOLOGICAL EFFLUENT SITE AREA EMERGENCY 4.3.S.1 Boundary Dose Resultl[g from an Actual or Imminent Release of Radioactivity Exceeds 100 mrem TEDE or 500 mrem CDE Adult Thyroid for the Actual or Projected Duration of the Release.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

l 4.3.S.I.1 A valid indication on radiation monitor EMF-36HL 2 6.53E:03 2.7E+06 cpm sustained for 215 minutes.

4.3.S.I.2 Dose assessment team calculations indicate dose consequences greater than 100 mrem TEDE or 500 mrem CDE Adult Thyroid at the site boundary.

4.3.S.I 3 Analysis of field survey results or field survey samples indicates dose consequences greater than 100 mrem TEDE or 500 mrem CDE Adult Thyroid at the site boundary.

NOTE 1: These EMF readings are calculated based on average annual meteorology, site boundary dose rate, and design unit vent flow rate. Calculations by the dose assessment team use actual meteorology, release duration, and unit vent flow rate.

Therefore, these EMF readings should not be used if dose assessment team calculations are available.

NOTE 2: If dose assessment team calculations cannot be completed in 15 minutes, then valid monitor readings should be used for emergency classification.

BASIS:

Valid means that a radiation monitor reading has been confirmed to be correct.

The 100 mrem integrated dose in this initiating condition is based on 10 CFR 20 annual average population exposure. This value also provides a desirable gradient (one order of magnitude) between the Alert, Site Area Emergency, and General Emergency classes. These values are 10% of the EPA Protective Action Guide (PAG) values given in EPA-400-R 92-001.

REFERENCE:

NUMARC/NESP 007, REV. 2. 01/92. AS) l D 2299

.m.

_- Cataw ba Nucicar Site ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Gl?NERAL EMERGENCY

)

4.3.G.1 Boundary Dose Resulting from an Actual or Imminent Release of Radioactivity that Exceeds 1000 mrem TEDE or 5000 mrem CDE Adult i

Thyroid for the Actual or Projected Duration of the Release.

OPERATING MODE APPLICABILITY: All l EMERGENCY ACTION LEVELS:

4.3.G.I.1 A valid indication on radiation monitor EMF-36H 26.53E:04 8.3E43 cpm l sustained for 215 minutes.

4.3.G.12 Dose assessment team calculations indicate dose consequences greater thaa 1000 l

mrem TEDE or 5000 mrem CDE Adult Thyroid at the site boundary. l 4.3.G.13 Analysis of field survey results or field survey samples indicates dose consequences greater than 1000 mrem TEDE or 5000 mrem CDE Adult Thyroid at the site boundary.

NOTE 1: These EMF readings are calculated based on average annual meteorology, site boundary dose rate, and design unit vent flow rate. Calculations by the dose assessment team use actual meteorology, release duration, and unit vent flow rate.

Therefore, these EMF readings should not be used if dose assessment team calculations are available.

NOTE 2: If dose assessment team calculations cannot be completed in 15 minutes, then valid monitor readings should be used for emergency classification.

BASIS:

Valid means that a radiation monitor reading has been confirmed to be correct.

The 1000 mrem TEDE and 3000 mrem CDE thyroid integrated doses are based on the EPA PAG values given in EPA-400-R-92-001, which indicat:s that public protective actions are indicated if doses exceed these values. This is consistent with the emergency class description af a general emergency.

REFERENCE:

NUMARC/NESP-007. REV. 2. 0182. AG1 D 3000 l

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Catow ba Nuclear Site

, LOSS OF SHUTDOWN FUNCTIONS l SITE AREA EMERGENCY 4.4.S.2 Complete Loss cf Function Needed to Achieve or Staintain Hot Shutdown.

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OPERATING MODE APPLICABILITY

Afode 1 (Power Operation)  !

Stode 2 (Startup)

Stode 3 (Hot Standby) hiode 4 (Hot Shutdown) l EhfERGENCY ACTION LEVELS:

a 4.4.S.21 Suberiticality CSF-RED 4.4 ". -; Cm Cuvim CSF C

^

4.4.S.2 9EHeat Sink CSF RED i  :

BASIS:

This EAL addresses complete lose of functions, including ultimate heat sink and reactivity control, required for hot shutdown with the reactor at pressure and temperature. Under these

! conditions, there is an actual major failure of a system intended for protection of the public.

Thus, decirration of a Site Area Emergency is warranted. Escalation to General Emergency j would be via Abnormal Rad Levels / Radiological Effluent Emergency Coordinator / EOF Director i Judgment, or Fission Product Barrier Degradation ICs.

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REFERENCE:

NUMARC/NESP 007, REV. 2,0182, SS4 t

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l ATTACHMENT 4 l

, Revised Catawba Emergency Plan Section "D"

] Pages WITHOUT Revision Marks

(Includes a complete copy of section D due to page number changes) 4

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4 Cmwba Nuclear Site ENCLOSURE 4.3 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT UNUSUAL EVENT 4.3.U.1 Any Unplanned Release of Gaseous or I ' quid Radioactivity to tlw Environment that Exceeds Two Times the SLC Limits for 60 Minutes or Longer.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.3.U.1 1 A valid Trip 2 alarm on radiation monitor EMF-49L or EMF 57 for 2 60 minutes or will likely continue for 260 minutes which indicates that the release inay have exceeded the initiating condition and indicates the need to assess the release with procedure HP/0/B/1009/14.

4.3.U.12 A valid indication on radiation monitor EMF 36L of2 5.4E+03 cpm for 2 60 minutes or will likely continue for 260 minutes which indicates that the telease may have exceeded the ma. ig condition and indicates the need to assess the release with procedure HPiO/B/1009/25.

4.3.U.1-3 Gaseous effluent being released exceeds two times SLC 16.11-1 for 2 60 minutes as determined by Radiation Protection (RP) procedure.

4.3.U.1-4 Liquid effluent being released exceeds two times SLC 16.11-6 for 2 60 minutes as determined by RP procedure. ,-

NOTE: If monitor reading is sustained for the time period indicated in the EAL and the required assessments (procedure calculations) cannot be completed within this time period, declaration must be made based on the valid radiation momtor reading.

BASIS:

The term " Unplanned", as used in this context, includes any release for which a liquid waste release (LWR) or gaseous waste release (GWR) package was not prepared, or a release thet exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm set points) on the applicable package.

Valid means that a radiation monitor readit.g has been confirmed *o be correct.

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, Cataw bc Nuclear Site ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT

i UNUSUAL EVENT 4.3.U.2 Unexpected Increase inhiant Radiation or Airborne Concentration.

OPERATING MODE APPLICABILITY: All

, EMERGENCY ACTION LEVELS:

4.3.U.21 Indication of uncontrolled water level decrease of greater than 6 inches in the reactor refueling cavity with all irradiated fuel assemblies remaining covered by water.

4.3.U.2 2 Uncontrolled water level decrease of greater than 6 inches in the spent fuel pool and fuel transfer canal with all irradiated fuel assemblies remaining covered by water.

4.3.U.2 3 Unplanned valid area radiation monitor (EMF) reading increases by a factor of 1000 over normal levels, as shown in Enclosure 4.10 of RP/0/A/5000/01.

BASIS:

Valid means that a radiation monitor reading has been confirmed to be correct.

All of the above events tend to have long lead times relative to potential for radiological

, release outside the site boundary; thus, impact to public health and safety is very low.

In li Fht of reactor cavity seal failure incidents, explicit coverage of these types of events via

EALs , md 2 is appropriate given their potential for increased doses to plant staff. A

! threshold value of 6 inches is used to allow time for mitigating actions to successfully terminate the inventory loss. Credit should not be taken for inventory additions to maintain level above the 6 inch threshold. Classification as an Unusual Event is warranted as a precursor to a more serious event.

EAL 3 addresses unplanned incr ases in in-plar:t radiation levels that represent a degradation in the control of radioactive material, and represent a potential degradation in the level of safety of the plant. The EMF readings for an Unusual Event are 1000 times the normal value.

Enclosure 4.10 of RP/0/A/5000/01 will provide the actual readings for these monitors. This EAL escalates to an Alert if the increases impair safe operation.

REFERENCE:

NUMARC/NESP 007. REV. 2. Oh92. AU2 D-22 1

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.- __ - --_ =_ - _ _ . . _ - - - . - - _ -__ - - _ _ . _ _ _

. Cctawba Nuclear Sue ABNORMAL RAD LFM/ RADIOLOGICAL EFFLU,gg

. ALERT 4.3.A.1 Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times the SLC limits for 15 hiinutes or Longer.

OPERATING N10DE APPLICABILITY: All Eh!ERGENCY ACTION LEVELS:

4.3.A.1 1 A valid indication on radiation monitor EMF-49L or EMF-57 of 21.2E+05 cpm for 215 minutes or will likely continue for 215 minutes which indicates that the release may have exceeded the initiating condition and indicates the need to assess the release with procedure HP/0/B/1009/14.

4.3.A.12 A valid indication on radiation monitor EMF-36L of 2. 5.4E+05 epm for 215 minutes or will likely continue for 215 minutes which indicates that the release may have exceeded the initiating condition and indicates the nee i to assess the release with procedure HP/0/B/1009/25, 4.3.A.13 Gaseous effluent being released exceeds 200 times the level of SLC 16.11-1 for g 15

minutes as determined by RP procedure, l 4.3.A.I.4 Liquid effluent being released exceeds 200 times the level of SLC 16.11-6 for 215 i

minutes as determined by RP procedure.

NOTE

If monitor reading is sustained for the time period indicated in the EAL Bild

! the required assessments (procedure calculations) cannot be completed within this time period, declaration must be made based on the valid radiation monitor reading.

l BASIS:

The term " Unplanned", as used in this context, includes any release for which a liquid waste release (LWR) or gaseous waste release (GWR) package was not prepared or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm set points) on the applicable package.

Valid means that a radiation monitor reading has been confirmed to be correct.

This event escalates from the Unusual Event by escalating the magnitude of the release by a factor of 100.

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ATTACHMENT 3 Revised Catawba Emergency Plan Section "D" Pages WITH Revision Marks i

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Cataw ba Nuclear Site ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ALERT 4.3.A.2 Major Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the Uncovering of hradiated Fuel Outside the Reacter Vessel.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.3.A.21 An unplanned valid trip 11 alarm on any of the following radiation monitors:

a. Spent Fuel Building Refueling Bridge IEMF 15 2 EMF-4

b. Spent Fuel Pool Ventilation 1 EMF-42 2 EMF-42

c. Reactor Building Refuelir.g Bridge IEMF-17 2 EMF-2

d. Containment Noble Gas Monitors IEMF-39 2 EMF-39 4.3.A.2 2 Plant personnel report that water level drop in reactor refueling cavity, spent fuel pool, or fuel transfer canal has or will exceed makeup capacity such that any irradiated fuel will become uncovered.

4.3.A.2 3 NC system wide range level < 95 % after initiation of NC system make up AND Any irradiated fuel assembly not capable of being lowered into spent fuel pool or reactor vessel.

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.- .- . . - . _ ~ _. - _ . - . - - - - - . - - . - . - . -

y Cctawba Nuclear Site 4.3.A.2-4 Spent Fuel Pool or Fuel Transfer Canal level decrease of >2 feet after initiation of make up AND Any irradiated fuel assembly not capable of being fully lowered into the spent fuel pool racks or transfer canal fuel transfer system basket.

BASIS:

This IC applies t i spent fuel requiring water coverage. There is time available to take corrective actions and there is little potential for substantial fuel damage. Thus, an Alert Classification for c:h event is appropriate. Escalation, if appropriate, would occur via Abnormal Rad Level / Radiological Effluent or Emergency Coordinator / EOF Director Judgmeat.

EAL 2: Due to concerns for ALARA and personnel safety, personnel should not remain in the area to observe that irradiated fuel is uncovered. Personnel should exit the area as quickly as possible and report the occurrence to the Control Room.

REFERENCE:

NUMARC/NESP 007, REV. 2. 0182, AA2 D 26

_ Cataw ba Nuclear Site ABNORMAL RAD LEVELS /RAnlOLOGICAL EFFLUENT ALERT 4.3.A.3 Release of Radioactive Material or Increases in Radiation Levels Within the Facility That Impedes Operation of Systems Required to Maintain Safe Operations or to Establish or Maintain Cold Shutdown.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.3.A.31 Valid reading on EMF-12 greater than 15 mR/hr in the Control Room.

4.3.A.3 2 Valid indication of radiation levels greater than 15 mR/hr in the Central Alarm

. Station (CAS) or Secondary Alarm Station (SAS).

. 4.3.A.3 3 Valid radiation monitor reading exceeds the limits shown in Enclosure 4.10 of

RP/0/A/5000/01.

j BASIS:

Valid means that a radiation monitor reading has been confirmed to be correct.

This initiating condition (IC) addresses increased radiation levels that impede necessary access to operating statioas, or other areas containing equipment that must be operated manually..in order to maintain safe operation or perform a 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. This situation is indicative of a significant radiological problem that warrants additional resources to assess and mitigate.

This IC is not intended to apply to anticipated temporary increases due to planned events (e.g., incore detecter movement, radwaste container movement, depleted resin transfers, etc.)

The Control Room, CAS, and SAS are ar. as that require continuous occupancy. 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.

D 27

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.. Cataw ba Nuclear site Catawba has chosen to use a generic emergency action level of greater than or equal to 5000 mrad /hr for areas in the plant thht are normally accessible as low dose rate areas that have equipment installed, operated, and used for safe operation or safe shutdown of the unit.

Radiation levels at or above this range may make it difficult to complete tasks necessary for safe operation of the plant or to establistior maintain cold shutdown without exceeding normal occupational dose limits of 5 Rem per year TEDE. Enclosure 4.10 of RP/0/A/5000/01 provides the monitor numbei and the location of the area monitor.

REFERENCE:

NUMARC/NESP 007, REV. 2, 0182, AA3 i

D-28

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Catawba Nuclear Site ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT SITE AREA EMERGENCY 4.3.S.1 Boundary Dose Resulting from an Actual or Imminent Release of Radioactivity Exceeds 100 mrem TEDE or 500 mrem CDE Adult Thyroid for the Actual or Projected Duration of the Release.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.3 S.1 1 A valid indication on radiation monitor EMF-36L 2 2.7E +06 cpai nstained ior 215 minutes.

4.3.S.I 2 Dose assessment team calculations indicate dose consequences greater than 100 mrem TEDE or 500 mrem CDE Adult Thyroid at the site boundary.

4.3.S.I 3 Analysis of field sucey results or field survey samples indicates dose consequences greater than 100 mrem TEDE or 500 mrem CDE Adult Thyroid at the site boundary.

NOTE 1: These EMF readings are calculated based on average annual meteorology, site boundary dose rate, and design unit vent flow rate. Calculations by the dose assessment team use actual meteorology, release duration, and unit vent flow rate.

Therefore, these EMF readings should not be used if dose assessment team calculations are available.

NOTE 2: If dose assessment team calculations cannot be completed in 15 minutes. then valid monitor readings should be used for emergency classification.

BASIS:

Valid means that a radiation monitor leading has been confirmed to be correct.

The 100 mrem integrated dose in this initiating condition is based on 10 CFR 20 annual average population exposure. This value also provides a desirable gradient (one order of magnitude) between the Alert, Site Area Emergency, and General Emergency classes. These values are 10% of the EPA Protective Action Guide (PAG) values given in EPA-400-R 92-001.

REFERENCE:

NUMARC/NESP 007, REV. 2. 01R2. ASI D 29

.R. '

Catam ba Nuclear Site ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT GENERAL EMERGENCY 4.3.G.1 Boundary Dose Resulting from an Actual or Imminent Release of Radioactivity that Exceeds 1000 mrem TEDE or 5000 mrem CDE Adult Thyroid for the Actual or Projected Duration of the Release.

1 OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

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4.3.G.1 1 A valid indication on radiation monitor EMF-36H 2:8.3E +03 cpm sustained for 215 minutes.

4.3.G.12 Dose assessment team calculations indicate dose consequences greater than 1000 mrem TEDE or 5000 mrem CDE Adult Thyroid at the site boundary.

4.3.G.13 Analysis of field survey results or field survey samples indicates dose consequences greater than 1000 mrem TEDE or 5000 mrem CDE Adult Thyroid at the site boundary.

NOTE 1: These EMF readir.gs are calculated based on average annual meteorology, site boundary dose rate, and design unit vent flow rate. Calculations by the dose assessment team use actual meteorology, release duration, and unit vent flow : tre.

Therefore, these EMF readings should not be used if dose assessment team calculations are available.

NOTE 2: If dose assessment team calculations cannot be completed in 15 minutes, then valid monitor readings should be used for emergency classification.

BASIS:

Valid means that a radit. tion monitor reading has been confirmed to be correct.

The 1000 mrem TEDE and 5000 mrem CDE thyroid integrated doses are based on the EPA PAG values given in EPA-400-R-92-001, which indicates that public protective actions are indicated if doses exceed these values. This is consistent with the emergency class description of a general emergency.

REFERENCE:

NUMARC/NESP-007, REV. 2. 01/92. AGI D 30

.A-

,,~ Catawba Nu:le:s Sne LOSS OF SHUTDOWN FUNCTIONS SlTE AREA EMERGENCY 4.4.S.2 Complete Loss of Function Need.d to Ach! eve or hiaintain Hot Shutdown.

OPERATING MODE APPLICABILITY: hiode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)

Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVELS:

4.4.S.2 1 Suberiticality CSF-RED 4.4.S.2 2 Heat Sink CSF RED BASIS:

This EAL addresses complete' loss of functions, including ultimate heat sink and reactivity control, required for hot shutdown with the reactor at pressure and temperature. 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. Escaletion to General Emergency would be via /.bnormal Rad Levels / Radiological Effluent, Emergency Coordinator / EOF Director Judgment, or Fission Product Barrier Degradation ICs.

REFERENCE:

NUMARC/NESP 007. REV. 2. 01192. SS4 D-34

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.. Catawba Nuclear Site D.

EMERGENCY CLASSIFICATION SYSTEM i

Regulatory Guide 1.101, Rev. 3, August 1992, approved the guidance provid NUMARC/NESP 007 Itevision 2, as an alterr. tive methodology for the deve!opment of Emergency Action Levels. Catawba Nuclear Site will use the NUMARC action levels. guidance for the,tfevelopment of initiating conditions and emergeny The emergency classification system utilizes four categories for classification of emergency events.

D.I.a 11NUSUAL EVENT l

Events are in process or has occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response occurs. or monitoriag are expected unless further degradation of safety systems The purpose of this class is to provide notification of the emergency to the station staff, State and Local Government representatives, and the NRC.

Specific initiating conditions and their corresponding emergency action levels are provided in the Basis Document beginning on page D-4.

D.I.b 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 of the EPA Protective Action Guideline exposure levels.

The purpose of this class is to assure that emergency personnel are readily available to:

1. Activate the onsite response centers 2.

Respond if the situation becomes more serious or to perform confirmatory radiation monitoring if required 3.

Provide offsite authorities current status information Specific initiating conditions and their corresponding emergency action levels are provided in the Basis Document beginning on page D-4.

D-1

Catawba Nuclear Site D 1. c. SITE AREA EMERGENCY

. Events are in process or have occurred which involve actus or likely major i, ,

failures of plant functions needed for protection of the public. Any releases are not i expected to result in exposure levels which exceed EPA Protective Action l

Guideline exposure levels except near the site boundary.

j The purpose of the Site Area Emergency is to:

1. Activate the offsite response centers

[ 2. Assure that monitoring teams are mobilized I 3. Assure that personne: required for taking protective actions of near site

areas are at duty stat'ons should the situation become more serious.

1

4. Provide current infonnation to the public and be available for consultation

I with offsite authorities

! Specific initiating conditions and their corresponding emergency action levels are I provided in the Basis Document beginning on page D-4.

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D.I.d. GENERAL EMERGENCY L

Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonaoly expected to exceed EPA Protective Action Guideline exposure levels offsla for more than the immediate site area. j The purpose of the General Emergency is to: .

1. Initiate predetermined protective actions for the public

2. Provide continuous assessment of information from onsite and offsite measurements

3. Initiate additional measures as indicated by event releases or potential releases

4. Provide current information to the public and be available for consultation with offsite authorities 3

Specific initiating conditions and their corresponding emergency action levels are provided in the Basis Document beginning on page D-4.

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. . . _ - . . _ - - . = - . . . - . . - . . . . . , . - - .

Catawba Nuclear Site l De27 INITIATING CONDITIONS The initiating conditions and their corresponding emergency actions levels are contained in the BASIS document beginning on page D-4. A classific tion F

procedure (RP/0/N5000/01) will be used to classify events as they w r, Specific response procedures are in place which delineate the required response e during the appropriate classification.

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. Cttawba Nuclear Site ENCLOSURE 4.1 BASIS INFORMATION FOD FISSION PRODUCT BARRIER REFEREN C6 TABLE CONTAINMENT BARRIER EALs

(C. l or C. 2 or C. 3 or C. 4 0r C. S or C. 6 er C. 7)

The Containment Barrier includes the containment building, its connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve.

Critical Safety Function (CSF) indications are not meant to include transient alarm conditions which may appear during the start-up of engineered safeguards equipment. A CSF condition is satisfied when the alarmed state is valid and sustained.

4.1.C.1 Critical Safety Function Status Containment - RED indicates containment conditions which may challenge the containment integrity. Therefore, this condition represents a potentialloss of the containment barrier.

There is no " Loss" EAL associated with this item.

i 4.1.C.2 Containment Conditions Containment pressure above 15 psig (the design pressure) indicates that the containment or its heat removal systems are not functioning as intended. This degradation of containment pressurc control represents a potential loss of containment integrity.

A containment hydrogen concentration of 9 volume percent is sufficient to expect that any ignition would result in complete combustion of the hydrogen in containment and a significant pressure rise. At some initial containment pressures, this pressure rise may exceed the capacity of the containment. Therefore, this level of hydrogen in the containment represents a potential loss of containment integrity.

Containment heat removal systems are actuated at the high-high containment pressure setpoint of 3 psig. At least one train of Containment Spray (NS) and one Containment Air (VX) Retu.n Fan (CARF) should be actuated at that time (the CARF with a 10 minute delay). A failure to actuate the design basis heat removal capability or assure proper containment mixing represents a degradation in the control of the D-4

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.. Catawba Nuclear Site containment cor.ditions. Therefore, this situation represents a potential loss of containment integrity. -

Rapid unexplained loss of pressure (i.e., not attributable to containment spray or condensation effects) following an initial pressure increase indicates a loss of containment integrity.

Containment pressure and sump levels should increase as a result of the mass and energy release into containment from a L.oss of Coolant Accident (LOCA). Thus, sump level or containment pressure not increasing indicates an interfacing systems LOCA which is a containment bypass and a loss of containment integrity, or some other containment pressure boundary failure.

4.1.C.3 Containment Isolation Valve Status After Containment Isolation Actuation Failure to isolate those containment pathways which would allow containment

! atmosphere to be released from containment is a loss of the containment barrier.

J

, There is no " Potential Loss" EAL associated with this item.

i 4.1.C.4 Steam Generator (SG) Secondary Side Release With Primary To Secondary Leakage Secondary side releases to atmosphere include those from the condenser air ejector, SG Power Operated Relief Valves (PORVs), atmospheric dump valves, faulted steam lines, and main steam safety valves. Steam releases, in combination with primary to 4

secondary leakage, constitute a bypass of the containment and, therefore, a loss of the containment barrier.

The appropriate classification can be determined in combination with the SG Tube Rupture EAL under the Reactor Coolant System (NCS) barrier.

There h no " Potential Loss" EAL associated with this item.

. 4.1.C.5 Significant Radioactive Inventory in Containment These values indicate significant fuel damage well in excess of the EALs associated j with both loss of Fuel Clad and loss of NCS Barriers. NUREG-1228, Source Estimations During incident Response to Severe Nuclear Power Plant Accidents, indicates that such conditions do not exist when the amount of clad damage is less D-5 S:

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J- Catswba Nuclear Site than 20%. 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.

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By treating the radioactive inventory in containment as a potential loss, a General Emergency will be declared when the conditions of the fuel clad and NCS barriers are included in the evaluation. This will allow the appropriate protective actions to be recommended.

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There is no " Loss" EAL associated with this item.

NOTE: If EMF-53A and EMF-53B are unavailable, readings can be calculated from

procedure HP/0/B/1009/06, " Alternative Method for Determining Dose Rates within

, the Reactor Building."

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i 4.1.C.6 Core Cooling i

Core Cooling - RED for greater than 15 minutes in this potential lou EAL represents imminent core damage that, if not terminated, could lead to restor vessel failure and an increased potential for containment failure. The potential for containment ,

challenge as a result of events at reactor vessel failure makes it prudent to consider an unmitigated core damage condition as a potential loss of the containment barrier.

Severe a::cident analyses (e.g., NUREG-1150) have concluded that function restoration procedures can arrest core degradation within the reactor vessel in a significant fraction of the core damage scenarios, and that the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide a reasonable period to allow function restoration procedures to arrest the core melt sequence. Whether or not the procedures will be effective should be apparent -

within 15 minutes. The Emergency Coordinator / EOF Director should make the declaration as soon as .t is (etermined that the procedures have been, or will be,

. ineffective.

There is no " Loss" EAL associated with this item.

4.1.C.7 . Emergency Coordinator / EOF Director Judgment This EAL addresses any other factors the are to be used by the Emergency Coordinator / EOF Director in determinmg whether the containment barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in Emergency Coordinator / EOF Director

. jt.dgment that the barrier may be considered lost or potentially lost.

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.I Catawba Nuclear Site REACTOR COOLANT SYSTEM (NCS) BARRIER EALs: (N.1 or N. 2 or N. 3 or N.4 or N.5)

The NCS Barrier includes the NCS ' primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

l 4.1.N.1 Critkal Safety Function Status NCS Integrity - RED indicates NCS pressure and temperature conditions which may challenge the Reactor Vessel integrity. Heat Sink - RED indicates the ultimate heat sink function is under extreme challenge. Either of these conditions indicate a i

potentialloss of the NCS Barrier.

2 There is no " Loss" EAL associated with this item.

4.1.N.2 NCS Leak Rate Small leaks may result in the inability to maintain normal liquid inventory within the NCS by operation of the Chemical and Volume Control System, which is considered as one centrifugal charging pump discharging to the charging header with the letdown line isolated. If letdown cannot be isolated, and a second charging pump is required, this is still considered a potential loss of the NCS barrier. The need for compensatory action to maintain normal liquid inventory is an indication of a degraded NCS barrier and is considered to be a potential loss of the barrier.

i The loss of subcooling is the fundamental indication that the inventory loss from the primary system exceeds the capacity of the inventory control systems. If the loss of subcooling is indicated, the NCS barrier is considered lost.

4.1.N.3 SG Tube Rupture Small Steam Generator tube leaks may result in the inability to maintain normal liquid inventory within the Reactor Coolant System (NCS) by operation of the Chemical and Volume Control System, which is considered as one centrifugal charging pump discharging to the charging header with the letdown line isolated. If letdown cannot be isolated, and a second charging pump is required, this is still considered a potential loss of the NCS barrier. The need for compensatory action to maintain normal liquid inventory is an indication of a degraded NCS barrier and is considered to be a potential loss of the barrier.

D-7

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I Catawba Nuclear Site A tube rupture with an unisolable secondary line fault is generally indicated by a reduction in primary coolant inventory, increased secondary radiation levels, and an uncontrolled or complete depressurization of the ruptured SG. This set of conditions represents a loss of the NCS and containment fission product barriers. In conjunction with containment barrier loss #4, this condition will result in the declaration of a Site Area Emergency. Escalation to a General Emergency would be indice.ted by at least a potential loss of the fuel clad barrier.

Secondary radiation increases should be observed via radiation monitoring of Condenser Air Ejector Discharge, SG Blowdown, Main Steam, and/or SG Sampling System. Determination of the " uncontrolled" depressurization of the ruptured SG

, should be based on indication that the pressure decrease in the ruptured steam

generator is not a function of operator action.' This should prevent declaration based on a depressurization that results from an EOP induced cooldown of the NCS that i

does not involve the prolonged release of contaminated secondary coolant from the l affected SG to the environment. This EAL should encompass steam breaks, feed breaks, and stuck open safety or relief valves. These conditions represents a loss of i- the NCS and containment fission product barriers, a

4.1.N.5 Emergency Coordinator / EOF Director Judgment This EAL addresses any other factors that are to be used by the Emergency Coordinator / EOF Director in determining whether the NCS barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in Emergency Coordinator / EOF Director judgment that the barrier may be considered lost or potentially lost.

1 D-8 em

Catawba Nuclear Site FUEL CLAD BARRIER EALs: (F.1 or F. 2 or F. 3 or F. 4)

The Fuel Clad Barrier is the zircalloy tubes that contain the fuel pellets.

4.1.F.1 Critical Safety Function Status Core Cooling - ORANGE indicates subcooling has been lost and that some clad damage may occur. Heat Sink - RED indicates the ultimate heat sink function is under extreme challenge. Either of these conditions indicate a potential loss of the Fuel Clad Barrier.

Core Cooling - RED indicates significant reactor coolant superheating and core uncovery. Clad damage under these conditions is likely; therefore, this is indication ofloss of the Fuel Clad Barrier.

4.1.F.2 Primary Coolant Activity Level The value of 300 Ciice 1131 equivalent coolant activity is well above that expected for iodine spikes and corresponds to about 2% to 5% fuel clad damage. This amount of clad damage indicates significant clad damage and thus the Fuel Clad Barrier is considered lost.

There is no equivalent " Potential Loss" EAL for this item.

4.1.F.3 Containment Radiation Monitoring A reading of i17 R/hr on EMF-53A or 53B is a value which indicates the release of reactor coolant, with elevated activity indicative of fuel damage, into the containment.

Rmetor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within technical specifications and are therefore indicative of fuel damage (approximately 5% clad failure depending on core inventory and NCS volume). This EAL indicates a loss of both the fuel clad barrier and a loss of NCS barrier.

There is no " Potential Loss" EAL associated with this item.

NOTE: If EMF-53A and EMF-53B are unavailable, readings can be calculated from procedure HP/0/B/1009/06. " Alternative Method for Determining Dose Rates within the Reactor Building."

D9

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, - _ _ - . _ _ . _ . . . - - ._ _ _ _ . . _ _ _ _ _ _ _ _ _ = _ _ _ _ _ . _ ..

Catawb2 Nuclear Site 4.1.F.4 Emergency Coordinator / EOF Director Judgment This EAL addresses any other factors that are to be used by the Emergency Coordinator / EOF Director in determining whether the Fuel Clad barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor in Emergency Coordinator / EOF Director judgment that the barrier may be considered lost or potentially lost.

REFERENCE:

NUMARC/NESP-007 REV. 2, 01/92, BASIS INFORMATION FOR TABLE 4 N

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Catawba Nuclear Site ENCLOSURE 4.2 ,

SYSTEM MALFUNCTION UNUSUAL EVENT 4.2.U.1 Inability to Reach Required Shutdown Within Technical Specification Limits.

OPERATING MODE APPLICABILITY: Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)

Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:

4.2.U.1-1. Plant is not brought to required operating mode within Technical Specifications LCO

. Action Statement Time.

BASIS:

Limiting Conditions of Operation (LCOs) require the plant to be brought to a required shutdown mode when the Technical Specification required configuration cannot be restored. Depending on the circumstances, this may or may not be an emergency or precursor to a more severe condition.

In any case, the initiation of plant shutdown required by the site Technical Specifications requires a one hour report under 10 CFR 50.72 (b) Non-emergency events. The plant is within its safety envelope when being shut down within the allowable action statement time in the 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 action statement time in the-Technical Specifications. Declaration of an Unusual Event is based on the time at which the LCO-specified action statement time period elapses under the site Technical Specifications and is not related to how long a condition may have existed. Other required Technical Specification shutdowns that involve precursors to more serious events are addressed by other System Malfunction, Hazards, or Fission Product Barrier Degradation ICs.

REFERENCE:

NUMARC/NESP-007, REV. 2, 0182, SU2 D 11

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Cuawba Nuclear Site 4

SYSTEM MALFUNCTION UNUSUAL EVENT 4.2.U.2- Unplanned Loss of Mo t or All Safety System Annunciation or Indication in the Control Room for Greater Than 15 Minutes.

OPERATING MODE APPLICABILITY: Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)

Mode 4 (Ilot Shutdown)

EMERGENCY ACTION LEVEL:

4.2.U.21 The following conditions exist:

a. Unplanned loss of most (>50%) annunciators associated with safety systems for greater than 15 minutes.

AND

b. In the opinion of the Operations Shift Manager / Emergency Coordinator / EOF Director, the loss of the annunciators or indicators requires additional personnel (beyond normal shift compliment) to safely operate the unit.

BASIS:

This Initiating Condition (IC) 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. " Unplanned" loss of annunciators or indicator excludes scheduled maintenance and testing activities. Quantification of "most" is arbitrary; however, this judgment is supported b~y the specific opinion of the Operations Shift Manager / Emergency 4

Coordinator / EOF Director that additional operating personnel will be required to provide increased monitoring of system operation to safely operate the unit. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

This Unusual Event will be escalated to an Alert if a transient is in progress during the loss of annunciation or indication.

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.

REFERENCE:

NUMARC/NESP-007, REV. 2, 0182, SU3 D-12

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Catawba Nudect Site SYSTEM hfALFUNCTION

• UNUSUAL EVENT I 4.2.U.3 Fuel Clad Degradation.

OPERATING MODE APPLICABILITY: hiode 1 (Power Operatior.)

Mode 2 (Startup)

Mode 3 (Hot Standby)

Mode 4 (Hot Shutdown)

Mode 5 (Cold Shutdown)

EMERGENCY ACTION LEVEL:

4.2.U.31 Dose Equivalent I-131 greater than the Technical Specification allowable limit.

BASIS:

This IC 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. The EAL addresses coolant samples exceeding coolant technical specifications for iodine spike. Escalation of this IC to the Alert level is via the Fission Product Barrier Degradation Monitoring ICs. This EAL applies in Modes 1,2,3,4, and 5 only because the Technical Specification applies only in these modes.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, SU4 D-13

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Cctawba Nuclear Site SYSTEM MALFUNCTION UNUSUAL EVENT 4.2.U.4 Reactor Coolant System (NCS) Leakage.

OPERATING MODE APPLICABILITY: hiode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot S indby)

Mode 4 (Hot S .utdown)

EMERGENCY ACTION LEVELS:

4.2.U.41 Unidentified leakage 210 gpm 4.2.U.4-2 Pressure boundary leakage 210 gpm 4.2.U.4-3 Identified leakage 2 25 gpm BASIS:

This IC is included as an Unusual Event because it may be a precursor of more serious conditions and, as a 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. In either case, escalation of this IC to the Alert level is via Fission Product Barrier Degradation ICs or IC, " Inability to Maintain Plant in Cold Shutdown."

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, SUS D-14

Catawba Nuclear Site SYSTEM MALFUNCTION UNUSUAL EVENT 4.2.U.S Unplanned Loss of All Onsite or Offsite Communications.

- OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.2.U.51 Loss of all onsite communications capability (internal phone system, PA system, onsite radio system) affecting the ability to perform routine operations.

)

4.2.U.5-2 Loss of all offsite communications capability (Selective Signaling, NRC FTS lines, offsite radio system, commercial phone system) affecting the ability to communicate

with offsite authorities.

BASIS:

The purpose of this IC and its associated EALs is to recognize a loss of communications capability that either defeats 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 comprehensive than the condition addressed by 10 CFR 50.72.

This EAL is intended to be used only when extraordinary means are being utilized to make communications possible (relaying ofinformation from radio transmissions, individuals being sent to offsite locations, etc.).

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, SU6 D-15

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. Catawba Nuclear Site SYSTEM MALFUNCTION '

ALERT 4.2.A.1 Unplanned Loss of Most or All Safety System Annunciation or Indication in Control Room With Either (1) a Significant Transient in Progress, or (2) i Compensatory Non Alarming Indicators Unavailable.

OPERATING MODE APPLICABILITY: Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)

Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:

. 4.2.A.1-1 The following conditions exist:

a. Unplanned loss of most (>50%) annunciators associated with safety systems for greater than 15 mmutes.

AND

b. In the opinion of the Operations Shift ManagerEmergency CoordinatorEOF Director, the loss of the annunciators or indicators requires additional personnel (beyond normal shift compliment) to safely operate the unit.

AND e -

c. Either of the following:

. A significant plant transient is in progress.

. Loss of the Operator Aid Computer (OAC).

BASIS:

This IC 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. Quantification of "Most" is arbitrary; however, this judgment is supported by the specific opinion of the Operations Shift ManagerEmergency CoordinatorEOF Director that additional operating personnel will be required to provide increased monitoring of system operation to safely operate the unit. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

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Catawba Nuclear Site

Refer to Operations Procedure OP/l(2)/A/6700/03, " Operating with OAC Out of Service."

"Significan: Transient" includes response to automatic or manually initiated functions such as 4

reactor trips, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10% or greater.

Significant indication is available from the OAC. Loss of the OAC in conjunction with the loss

, of other indications would further impair the ability to monitor plant parameters.

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

- This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress.

i

REFERENCE:

NUMARC/NESP-OO7, REV. 2, 0182, SA4 I

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Cuawba Nuclear Site SYSTEM MALFUNCTION '

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SITE AREA EMERGENCY 4.2.S.1 Inability to Monitor a Significant Transient in Progress.

OPERATING MODE APPLICABILITY: Mode 1 (Power Operation)

Mode 2 (Startup)  :

Mode 3 (Hot Standby) l Mode 4 (Hot Shutdown)

EMEltGENCY ACTION LEVEL:

4.2.S.1-1 The following conditions exist:

a. Loss of most (>50%) annunciators associated with safety systems.

AND

b. A significant plant transient is in progress.

4 AND

c. Loss of the OAC.

AND

d. Inability to provide manual monitoring of any of the following Critical Safety Functions:

e subcriticality

. core cooling 1

• heat sink e containment 4

BASIS:

This IC and its associnted EAL are intended to recognize the inability of the control room staff to monitor the plant response to a transient. A Site Area Emergency is considered to exist if the control room staff cannot monitor safety functions needed for protection of the public.

D-18

. 4 Cuzwta Nuclear Site "Significant Transient" includes response to automatic or manuallf initiated functions such as trips, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10% or greater. '

REFERENCE:

NUMARC/NESP-007, REV. 2, 0182, SS6 i

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D-19 4  %

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Cmwba Nucl:ar Site ENCLOSURE 4.3 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT UNUSUAL EVENT 4.3 U.1 Any Unplanned Release of Ga::aous or Liquid Radioactivity to the Environment that Exceeds Two Times the SLC Limits for 60 Minutes or Longer.

OPERATING MODE APPL'iCABILITY: All EMERGENCY ACTION LEVELS:

4.3.U.1-1 A valid Trip 2 alarm on radiation monitor EMF-49L or EMF-57 for 2 60 minutes or will likely continue for 260 minutes which indicates that the release may have exceeded the initiating condition and indicates the need to assess the release with procedure HP/0/B/1009/14.

4.3.U.1-2 A valid indication on radiation monitor EMF-36L of 2 5.4E+03 cpm for 2 60 minutes or will likely continue for 2 06minutes which indicates that the release may have exceeded the initiating condit. ion and indicates the need to assess the release with procedure HP/0/B/1009/25.

4.3 U.1-3 Gaseous effluent being released exceeds two times SLC 16.11-1 for 2 60 minutes as determined by Radiation Protection (RP) procedure.

4.3.U.1-4 Liquid effluent being released exceeds two times SLC 16.11-6 for 2 60 minutes as determined by RP procedure.

NOTE: If monitor reading is sustaine'd for the time period indicated in the EAL and the required assessments (procedure calculations) cannot be completed within this time period, declaration must be made based on the valid radiation monitor reading.

BASIS:

The term " Unplanned", as used in this context, includes any release for which a liquid waste release (LWR) or gaseous waste release (GWR) package was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm set points) on the applicable package.

Valid means that a radiation monitor reading has been confirmed to be correct.

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cr Catzwba Nuclear Site i

" Unplanned releases in excess of two times the site Selected Licensee Commitments (SLC) that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. It is not intended that the release be averaged over 60 minutes.

The event should be declared as soon as it is determined that the release duration has or will j likely exceed 60 minutes.

! The gaseous release rate SLC are based on limiting gaseous releue rates to the SITE

BOUNDARY to 500 mr/ year total body.

}.

!- The liquid release rate SLC are based on limiting liquid release rates to the UNRESTRICTED AREA to 10 times the Effluent Concentration (EC) valves given in 10CFR20.1001-20.2401, Appendix B Table 2, Column 2. Radiation Protection will use HP/0/B/1009/14, " Radiation Protection Actions Following An Uncontrolled Release of Liquid Radioactive Material" to

quantify a release.

i

{ Monitor setpoints are based on the methodology of the site Offsite Dose Calculation Manual

, (ODCM) using annual average meteorology dispersion coefficient of 3.51E-5 sec/m3 . Radiation

! Protection will use HP/0/B/1009/25, " Emergency Response Off-Site Dose Projections" to

[ quantify a release.

REFERENCE:

NUMARC/NESP-007, REV. 2,0182, AUl 1

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Cetawba Nuclear Site ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT

, UNUSUAL EVENT 4.3.U.2 Unexpected Increase i Plant Radiation or Airborne Concentration.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.3.U.2 1 Indication of uncontrolled water level decrease of greater than 6 inches in the reactor refueling cavity with all irradiated fuel assemblies remaining covered by water.

4.3.U.2-2 Uncontrolled water level decrease of greater than 6 inches in the spent fuel pool and fuel transfer canal with all irradiated fuel assemblics remaining covered by water.

4.3.U.2-3 Unplanned valid area radiation monitor (EMF) reading increases by a factor of 1000 over normal levels. as shown in Enclosure 4.10 of RP/0/A/5000/01.

BASIS:

Valid means that a radiation monhor reading has been confirmed to be correct.

All of the above events tend to have long lead times relative to potential for radiological release outside the site boundary; thus, impact to public health and safety is very low.

In light of reactor cavity seal failure incidents, explicit coverage of these types of event via EALs 1 and 2 is appropriate given their potential for increased doses to plant staff. A threshold value of 6 inches is used to allow time for mitigat:ng actions to successfully terminate the inventory loss. Credit should not be taken for inventory additions to maintain level above the 6 inch threshold. Classifiation as an Unusual Event is warranted as a precursor to a more serious event.

EAL 3 addresses unplanned increases in in-p..mt radiation levels that represent a degradation in the control of radioactive material, and represent a potential degradation in the level of safety of the plant. The EMF readings for an Unusual Event are 1000 times the normal value.

Enclosure 4.10 of RP/0/A/5000/01 will provide the actual readings for these monitors. This EAL escalates to an Alert if the increases impair safe operation.

REFERENCE:

NUMARC/NESP-007, REV. 2,01/92. AU2 D-22

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Citawbs Nuclear Site ABNORMAL RAD LEVELS /RADIOLOGICAi/ EFFLUENT ALERT 4.3.A 1 Any Un%anned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times the SLC limits for 15 Minutes or Longer.

OPER? TING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.3 A.1 1 A valid indication on radiation monitor EMF-49L or EMF-57 of21.2E+05 cpm for 215 minutes or will likely continue for 215 minutes which indicates that the release may have exceeded the initiating condition and indicates the need to assess the release with procedure HP/C/B/1009/14.

4.3.A.12 A valid indication on radiation monitor EMF-36L of > 5.4E45 cpm for 215 minutes or will likely continue for 215 minutes which indicates that the release may have exceeded the initiating condition and indicates the need to assess the release with procedure HP/0/B/1009/25.

4.3.A.1-3 Gaseous effluent being released exceeds 200 times the level of SLC 16.11-1 for 215 minutes as determined by RP procedure.

4.3.A.1-4 Liquid effluent being released exceeds 200 times the level of SLC 16.11-6 for 215 minutes as determined by RP procedure.

NOTE: If monitor reading is sustained for the time period indicated in the EAL and i

the required assessments (rmcedure calculations) cannot be completed within this time period, declaration must be made based on the valid radiation monitor reading.

BASIS:

The term " Unplanned", as used in this context, includes any release for which a liquid waste release (LWR) or gaseous waste release (GWR) package was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm set points) on the applicable package.

Valid means that a radiation monitor reading has been confirmed to be correct.

This event escalates from the Unusual Event by escalating the magnitude of the release by a factor of 100.

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. 1 Catawba Nuclear Site It is not intended th.t the release be averaged over 15 minutes. Th'e event should be declared as soon as it is determined that the release duration has or will likely exceed 15 minutes.

The gaseous release rate SLC are based on limiting gaseous release rates to the SITE BOUNDARY to 500 mr/ year total body.

The !! quid release rate SLC are based on limiting liquid release rates to the UNRESTRICTED AREA to 10 times the Effluent Concentration (EC) valves given in 10CFR20.1001-20.2401, Appendix B, Table 2 Column 2. Radiation Protection will use HP/0/B/1009/14, " Radiation Protection Actions Following An Uncontrolled Release of Liquid Radioactive Material" to quantify a release.

Monitor setpoints are based on the methodology of the site Offsite Dose Calculation Manual

. (ODCM) using annual average meteorology dispersion coefficient of 3.51E 5 sec/m3 . Radiation Protection will use HP/0/B/1009/25, " Emergency Response Off-Site Dose Projections" to

. quantify a release.

REFERENCE:

NUMARC/NESP-007, REV. 2, 0182, AA1 D-24

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l Cutwba Nuclear Site i ABNORMAL RAD LEVEISRADIOLOGICAL EFFLUENT  !

ALERT 43.A.2 Major Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS.

43.A.21 An unplanned valid trip II alarm on any of the following radiation monitors:

a. Spent Fuel Building Refueling Bridge 1 EMF-15 2 EMF-4

b. Spent Fuel Pool Ventilatian IEMF-42 2 EMF-42

c. Reactor Building Refueling Bridge IEMF-17 2 EMF-2

d. Containment Noble Gas Monitors 1 EMF-39 2 EMF-39 43.A.2-2 Plant personnel report that water level drop in reactor refueling cavity, spent fuel pool, or fuel transfer canal has or will exceed makeup capacity such that any irradiated fuel will become uncover.:d.

43.A.2-3 NC system wide range level < 95 % after initiation of NC system make-up AND Any irradiated fuel assembly not capable of being lowered into spent fuel pool or reactor vessel.

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Cuawba Nuclear Site 4.3.A.2-4 Spent Fuel Pool or Fuel Transfer Canal level decrease o'f >2 feet after initiation of make-up

) AND Any irradiated fuel assembly not capable of being fully lowered into the spent fuel pool racks or transfer canal fuel transfer system basket.

. BASIS:

1

. This IC applies to spent fuel requiring water coverage. There is time available to take corrective actions, and there is little potential for substantial fuel damage. Thus, an Alert l Classification for this event is appropriate. Escalation, if appropriate, would occur via Abnormal Rad Level / Radiological Effluent or Emergency Coordinator / EOF Director Judgment.

l h EAL 2: Due to concerns for ALARA and personnel safety, persor.nel should not remain in j the area to observe that irradiated fuel is uncovered. Personnel should exit the area as quickly

) as possible and report the occurrence to the Control Room.

REFERENCE:

NUMARC/NESP-007, REV. 2, 0182, AA2 1

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Cttawbt. Nuclear Site ABNORMAL RAD LEVELS / RADIOLOGICAL' EFFLUENT ALERT 43.AJ Release of Radioactive faterial or Increases in Radiation Levels Within the Facility That Impedes Operation of Systems Required to Maintain Safe Operations or to Establish or Maintain Cold Shutdown.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

43.AJ-1 Valid reading on EMF-12 greater than 15 mR/hr in the Control Room.

4.3.AJ-2 Valid indication of radiation levels greater than 15 mR/hr in the Central Alann Station (CAS) or Secondary Alarm Station (S AS).

43.AJ-3 Valid radiation monitor reading exceeds the limits shown in Enclosure 4.10 of RP/0/A/5000/01.

BASIS:

Valid means that a radiation monitor reading has been confirmed to be e' cect.

This initiating condition (IC) addresses increased radiation levels that impede necessary access to operating stations, or other areas containing equipment that must be operated manually, in order to maintain safe operation or perform a 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. This situation is indicative of a significant radiological problem that warrants additional resources to assess and mitigate.

This IC 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.)

The Control Room, CAS, and SAS are areas that require continuous c,ccupancy. 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.

D-27

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Catawba Nuclear Site Catawba has chosen to use a generic emergency action level of greater than or equal to 5000 mR:.d/hr for areas in ' the plant that are normally accessible as low dose rate areas that have equipment installed. operated, and used for safe operation or safe shutdown of the unit.

Radiation levels at or above this range may make it difficult to complete tasks necessary for safe operation of the plant or to establish or maintain cold shutdown without exceeding normal occupational dose limits of 5 Rem per year TEDE. Enclosure 4.10 of RP/0/A/5000/01 provides the monitor number and the location of the area monitor.

ldFERENCE: NUMARC/NESP-007, REY. 2, 01B2, AA3 D-28

Catawba Nuclear Site ABNORMAL RAD LEVELS /RADIOLOGICAI/ EFFLUENT SITE AREA EMERGENCY 4.3.S." Boundary Dose Resulting from an Actual or Imminent Release of Radioactivity Exceeds 100 mrem TEDE or 500 mrem CDE Adult Thyroid for the Actual or Projected Duration of the Release.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.3.S.1 1 A valid indication on radiation monitor EMF-36L 2 2.7E+06 cpm sustained for

tl5 minutes.

4.3.S.1-2 Dose assessment team calculations indicate dose consequences greater than 100 mrem TEDE or 500 mrem CDE Adult Thyroid at the site boundary.

4.3.S.1-3 Analysis of field sury. ; results or field survey samples indicates dose consequences greater than 100 mrem TEDE or 500 mrem CDE Adult Thyroid at the site boundary.

NOTE 1: These EMF readings are calculated based on average annual meteorology, site boundary dose rate, and design unit vent flow rate. Calculations by the dose assessment team use actual meteorology, release duration, and unit vent flow rate.

Therefore, these EMF readings should not be used if dose ass,essment team calculations are available.

NOTE 2: If dose assessment team calculations cannot be completed in 15 minutes, then valid monitor readings should be used for emergency classification.

BASIS:

Valid means that a radiation monitor reading has been confirmed to be correct.

The 100 mrem integrated dose in this initiating condition is based on 10 CFR 20 annual average population exposure. *n.4s value also provides a desirable gradient (one order of magnitudc) between the Alert, Site Area Emergency, and General Emergency classes. These values are 10% of the EPA Protective Action Guide (PAG) values given in EPA-400-R 001.

REFERENCE:

NUMARC/NESP-007, REV. 2,01/92, ASL D-29

Catawba Nuclear Site ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT GENERAL EMERGENCY 4.3.G.1 Boundary Dose Resulting from an Actual or Imminent Release of Radioactivity that Exceeds 1000 mrem TEDE or 5000 mrem CDE Adult Thyroid for the Actual or Projected Duration of the Release.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.3.G.1-1 A valid indication on radiation monitor EMF-36H 2 8.3E+03 cpm sustained for 215 minutes.

4.3.G.1-2 Dose assessment team calculations indicate d.ose consequences greater than 1000 mR. :a TEDE or 5000 mrem CDE Adult Thyroid at the site boundary.

4.3.G.1-3 Analysis of field survey results or field survey samples indicates dose consequences greater than 1000 mrem TEDE or 5000 mrem CDE Adult Thyroid at the site boundary.

NOTE 1: These EMF readings are calculated based on average annual meteorology, site boundary dose rate, and design unit vent flow rate. Calculations by the dose assessment team use actual meteorology, release duration, and unit vent flow rate.

Therefore, these EMF readings should not be used if dose assessment team calculations are available.

NOTE 2: If dose assessment team calculations cannot be complete ( in 15 minutes, then valid monitor readings should be used for emergency ebssification.

BASIS:

Valid means that a radiation monitor reading has been confirmed to be correct.

The 1000 mrem TEDE and 5000 mrem CDE thyroid integrated doses are based on the EPA PAG values given in EPA-400-R-92-001, which indicates that public protective actions are indicated if doses exceed these values. T1.is is consistent with the emergency class description of a general emergency.

REFERENCE:

NUMARC/NESP-007. REV. 2, 01/92, AGI D-30

Cciasba Nuclear Site ENCLOSURE 4.4 I LOSS OF SilUTDOWN FUNdTIONS ALERT

. 4.4.A.) Failure of Reactor Protection Sptem Instrumentation to Complete or Initiate an

) Automatic Reactor Trip Once a Reactor Protection, system Setpoint Has Been Exceeded and Manual Trip Was Successful.

4 j OPERATING 510DE APPLICABILITY: Afode 1 (Power Operation)

, hiode 2 (Startup)

hfode 3 (Hot Standby) a Eh1ERGENCY ACTION LEVEL

4.4.A.1 1 The following conditions exist:

a. Valid reactor trip signal received or required and automatic reactor trip was not l successful.

AND

b. Manual reactor trip from the control room is successful and reactor power is less than 5% and decreasing.

HASIS:

This condition indicates failure of the automatic protection system to trip the reactor. This ,

condition is more than a potential degradation of a safety system in th.J 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 b!cause conditions exist that lead to potential loss of fuel clad or NCS. Reactor protection sysiem setpoint being exceeded (rather than hmiting 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) at the reactor control console which causes control rods to be RAPIDLY inserted into the core and brings the reactor suberitical. Operator action to drive rods does NOT constitute a reactor trip, i.e. does not meet the rapid insenion criterion.

Failure of manual trip would escalate the event to a Site Area Emergency.

REFERENCE:

NUhtARC/NESP 007. REY. 2, 01/92, SA2 D 31

.-~.

Cciawba Nuclecs Site LOSS OF SHUTDOWN FUNf TIONS ALERT 4

l 4.4.A.2 Inability to Maintain l iant i in Cold Shutdown.

I i

OPERATING MODE APPLICABILITY: Mode 5 (Cold Shutdown) i

Mmie 6 (Refueling)

)

EMERGENCY ACTION LEVELS:

4.4.A.21 Total loss of Residual lient Remoni (ND) and/or Navicar Service Water (RN) and/or  !

Component Cooling (KC) l l

AND

. One of the following:

. Inability to maintain reactor coolant temperature below 200 F.

• Uncontrolled reactor coolant temperature rise to >l80*F BASIS:

This EAL addresses loss of functions required for core cooling during cold shutdown and refueling conditions. This IC and associated EALs are based on concerns raised by Generic Letter 88-17 " Loss of Decay lleat Removal." A number of phenomena such as pressurization, vortexing, steam generator U tube drainli.g. NCS level differences when operating at a mid loop condition, decay heat removal system design, and level instrumentation problems can lead to 4

conditions where decay heat removal is lost and core uncovery can occur. NRC analyses show i

that sequences that can cause core uncovery in 15 to 20 minutes and severe core damage within an hour efter decay heat removal is lost.

Escalation to the Site Area Emergency is by, " Loss of Water Level in the Reactor Vessel That lias or Will Uncover Fuel in the Reactor Vessel," or by Abnormal Rad Levels / Radiological Effluent ICs.

REFERENCE:

NUbfARC/NESP.007, REV, 2, 01/92, SA3 D 32

i l

Cataa ha Nuclear Site l

l LOSS OF SHUTDOWN FUNCTIONS SITE AREA EMERGENCY 4.4.S.1 Failure of Reactor Protection System Instrumentation to Complete or Initiate an Automatic Reactor Trip Once a Reactor Protection System Setpoint Has Been Exceeded and Manual Trip WAS NOT Successful.

OPERATING MODE APPLICABILITY: Mode 1 (Power Operation)

EMERGENCY ACTION LEVEL:

4.4.S.1 1 The following conditions exist:

a.

Valid reactor trip signal received or required and automatic reactor trip was not successful.

AND

b. Manual reactor trip from the control room was not successful in reducing reactor power to less than 5% and decreasing.

BASIS:

Automatic and manual trip are not considered succenful if action away from the reactor control console is required to trip the reactor. This EAL is equivalent to the Subcriticality CSF-RED.

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 NCS. Although this IC nay be viewed as redundant to the Fission Product Barrier Degradation IC, its inclusion is necessary to better assure tanely recognition and emergency response. Escalation of this event to a General Emergency would be via Fission Product Barrier Degradation or Emergency Coordinator / EOF Director Judgment ICs.

REFERENCE:

NUMARC/NESP-007, REV 2. 01/92, SS2 D-33 r

"s

Cctawba Nuclear Site LOSS OF SIIUTDOWN FUNCTIONS SITE AREA EMERGENCY 4.4.S.2 Complete Loss of Function Needed to Achieve or Maintain liot Shutdown.

OPERATING MODE APPLICABILITY: Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Ilot Standby)

Mode 4 (110t Shutdown)

EMERGENCY ACTION LEVELS:

4.4.S.2 1 Suberiticality CSF RED 4.4.S.2 2 llent Sink CSF RED HASIS:

This EAL addresses complete loss of functions, including ultimate heat sink and reactivity control, required for hot shutdown with the reactor at pressure and temperature. Under these conditions, there is an actual major railure of a system intended for protection of the public.

Thus, declaration of a Site Area Emergency is warranted. Escalation to General Emergency would be via Abnormal Rad Levels / Radiological Effluent, Emergency Coordinator / EOF Director Judgment, or Fission Product Barrier Degradation ICs.

REFERENCE:

NUMARC/NESP-007, REV. 2. 01/92, SS4 D 34

I Cutwbs Nuclear Site LOSS OF SHUTDOWN FUNCTIO'NS l

SITE AREA Eh1ERGENCY 4.4.S.3 Loss of Water Level in the Reactor Vessel That Has or Will Uncover Fuel in the Reactor Vessel. l OPERATING h10DE APPLICAHILITY: Afode 5 (Cold Shutdown)

Afode 6 (Refueling)

EhfERGENCY ACTION LEVELS:

4.4.S.31 a. Failure of heat sink causes loss of cold shutdown conditions.

AND

b. Lower range Reactor Vessel Level Indication System (RVLIS) decreasing after initiathn of NC system makeup.

4.4.S.32 a. Failure of heat sink causes loss of cold shutdown conditions.

AND

b. Reactor Coolant (NC) system narrow range level less thaa 11% and decreasing after initiation of NC system makeup.

4 4.4.S.3 3 a. Failure of heat sink causes loss of cold shutdown conditions.

AND

b. Either train ultrasonic level indication less than 7.25% and decreasing after initiation of NC system makeup.

I HASIS:

Under the conditions specified by this IC, severe core damage may be imminent due to prolonged boiling following loss of decay heat removal.

o Thus, declaration of a Site Area Emergency is warranted under the conditions specified by the IC. Escalation to a General Emergency is via radiological effluent IC.

REFERENCE:

NUMARC/NESP-007, REV. 2, 0182, SSS D-35

s. %

Cotawba Nuclear Sue LOSS OF SHUTDOWN FUNCTIO'NS GENERAL EMERGENCY 4.4.G.1 Failure of the Reactor Protection System to Complete an Automatic Trip and Manual Trip was NOT Successful and There is Indication of an Extreme Challenge to the Ability to Cool the Core.

OPERATING MODE APPLICABILITY: Mode 1 (Power Operation)

EMERGENCY ACTION LEVEI, 4.4.G.1 1 The following conditiore dit

a. Valid reactor trip signa! recived or required and automatic reactor trip was not successful.

AND

b. Manual reactor trip from the control room was not successful in reducing reactor power to less than 5% and decreasing.

AND

c. Either of the following conditions exist:

• Core Cooling CSF RED

• Heat Sink CSF-RED HASIS Automatic and manual trip are not considered successful if action away from the reactor control console is required to trip the reactor.

Under the conditions of this IC and its associated EALs, the efforts to bring the tractor 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.

The extreme challenge to the ability to cool the core is intended to mean that the core exit temperatures are at or approaching 1200 F or that the reactor vessel water level is below the top of active fuel. This equates to a Core Cooling RED condition.

D-36

Cotowba Nuclear Site Another consideration is the inability to initially remove heat duririg the early stages of this sequence. If emergency feedwater flow is insufficient to remove the amount cf heat required by design from at least one steam generator, an extreme challenge should be considered to exist.

This equates to a lleat Sink RED condition.

In the event either of these challenges occurs during or following a time that the reactor has not been brought below the power associated with the safety system design, core damage may be imminent. For this reason, the General Emergency declaration is intended to be anticipatory of the fission product barrier matrix declaration to permit maximum offsite intervention time.

REFERENCE:

NUMARC/NESP 007, REV. 2, 0182, SG2 D 37

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Cctaw ba Nuclear Site ENCLOSURE 4.5 LOSS OF POWER UNUSUAL EVENT 4.5.U.1 Loss of All Offsite Power to Essential Busses for Greater Than 15 Minutes.

EMERGENCY ACTION LEVEL:

4.5.U.11 OPERATING MODE APPLICABILITY: Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)

Mode 4 (Hot Shutdown)

The following conditions exist:

a. Loss of offsite power to essential buses ETA and ETB for greater than 15 minutes.

AND

b. Both emergency diesel generators are supplying power to their respective essential busses.

4.5.U.12 OPERATING MODE APPLICABILITY: Mode 5 (Cold Shutdown)

Mode 6 (Refueling)

No Mode (Defueled)

The following conditior.s exist:

a. Loss of offsite power to essential buses ETA and ETB for greater than 15 minutes.

AND

b. One emergency diesel generator is supplying power to its respective essential bus.

D-38

~,

Cataw ba Nucleat Site 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). When in cold shutdown, refueling,'or defueled mode the event can be classified as an Unusual Event, because of the significantly reduced decay heat, lower temperature and pressure, increasing the time to restore one of the essential busses, relative to that specified for the Alert EAL. The event will escalate to an Alert in these modes if both essential busses are lost. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.-

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, Sul D ~,

-- . _ - - _ _ - _ ._ ._ ~_ - ._- - - ..-_._ - - .

Cttawba Nuclear Site I.OSS OF POWER UNUSUAL EVENT 4.5.U.2 Unplanned Loss of Required DC Power During Cold Shutdown or Refueling hiode for Greater than 15 Minutes.

OPERATING MODE APPLICABILITY: h1 ode 5 (Cold Shutdown) hiode 6 (Refueling)

Eh!ERGENCY ACTION LEVEL:

4.5.U.21 The folloveing conditions exist:

a. Unplanned loss of both unit related busses: EBA and EBD both < 112 VDC, and EBB and EBC both < 109 VDC AND

b. Failure to restore power to at least one required DC bus within 15 minutes from the time ofloss.

BASIS:

The purpose of this IC and its associated EALs is to recognize a loss of DC power compromising the ability to monitor and control the removal of decay heat during Cold Shutdown or Refueling operations. This EAL is intended to be anticipatory in as much as the operating crew may not have necessary indication and control of equipment needed to rerpond to the loss.

" Unplanned" is included in this IC and EAL to preclude the declaration of an emergency as a result of planned maintenance activities.

If this loss results in the inability to maintain cold shutdown, the escalation to an Alert is via

" Inability to Maintain Plant in Cold Shutdown."

REFERENCE:

NUMARC/NESP-007, REV. 2, 0182, SU7 l

D-40

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Cctaw ba fluclear Site LOSS OF POWER ,

ALERT 4.5.A.1 Loss of All ONsite Power and Loss of All Onsite AC Power to Essential Busses During Cold Shutdown Or Refueling hiode.

OPERATING h10DE APPLICABILITY: hiode 5 (Cold Shutdown) 51 ode 6 (Refueling)

No hiode (Defueled)

EMERGENCY ACTION LEVEL:

4.5.A.1 1 Loss of all offsite and onsite AC power as indicated by:

. a. Loss of power on essential buses ETA and ETB.

AND

b. Failure to restore power v; at least one essential bus within 15 minutes.

BASIS:

Loss of all AC power comprondses all plant safety systems requiring electric pover including Residual Heat Removal (RHR), Emergency Core Cooling Systems (ECCS), Containment 1k at Removal, Spent Fuel Heat Removal and the Ultimate Heat Sink. When in cold shutdown, refueling, or defueled mode the event can be classified as an Alert, because of the significantly reduced decay heat, lower temperature and pressure, increasing the time to restore one of the essential busses, relative to that specified for the Site Area Emergency EAL. Escalating to Site Area Emergency,if appropriate,is by Abnormal Rad Levels / Radiological Effluent, or Emergency Coordinator / EOF Director Judgment ICs. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

REFERENCE:

NUMARC/NESP 007, REV. 2. OH92. SA)

D 41

Catowbo Nuclear Site LOSS OF POWER ALERT 4.5.A.2 AC power to essential usses reduced to a single power source for greater than 15 minutes such that an additional single failure could result in station blackout.

OPERATING MODE APPLICABILITY: Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)

Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:

4.5.A.21 The following condition exists:

AC power capability has been degraded to one essential bus powered from a single power source for > 15 min, due to the loss of all but one of:

SATA SATB ATC ATD D/G A D/G B BASIS:

This IC w.d the associated EAL is intended to provide an escalation from IC, " Loss of All Offsite Power To Essential Busses for Greater Than 15 Minutes." The condition indicated by this IC is the degradation of the offsite and onsite power systems such that an additional single failure could result in a station blackout. This condition could occur due to a loss of offsite power with a concurrent failure of one emergency generator to supply power to its essential busses. Another related condition could be the loss of all offsite power and loss of onsite emergency diesels with only one train of essential busses being back fed from the unit main generator, or the loss of onsite emergency diesels with only one train of essential busses being back fed from offsite power. The subsequent loss of this single power source would escalate the event to a Site Ama Emergency in accordance with IC, " Loss of All Offsite and Loss of All Onsite AC Power to Essential Busses."

REFERENCE:

NUAfARC/NESP 007, REV. 2. 0182. SAC D-42

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Catawba Nuclear Site i

LOSS OF POWER .

SITE AREA EMERGENCY 4.5.S.1 Loss of All Offsite Power and Loss of All Onsite AC Power to Essential Busses.

i OPERATING MODE APPLICABILITY: Mode 1 (Power Operation) ,

Mode 2 (Startup)

Mode 3 (Ilot Standby) a Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:

4.5.S.I 1 Loss of all offsite and onsite AC power as indicated by:

i

. a. Loss of power on essential buses ETA and ETB.

AND j b. Failure to restore power to at least one essential bus within 15 minutes.

BASIS:

^

Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prolonged loss of all AC power will cause core uncovering and loss of containment integrity; thus, this event can escalate 4

to a General Emergency.

Escalation to General Emergency is via Fission Product Barrier Degradation or IC, " Prolonged Loss of All Offsite Power and Prolonged lass of All Onsite AC Power."

REFERENCE:

NUMARC/NESP-007, REV. 2, 0182, SS) 9 D-43 m

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Cuawba Nuclear Site LOSS OF POWER SITE AREA Eh1ERGENCY l

4.5.S.2 Loss of All Vital DC Power. l I

OPERATING A10DE APPLICABILITY: Afode 1 (Power Operation) 51 ode 2 (Startup) hiode 3 (Hot Standhy) hiode 4 (Hot Shutdown) l Eh!ERGENCY ACTION LEVEL:

4.5.S.21 The following conditions exist:

[' a. Loss of both unit related busses: EBA and EBD both < 112 VDC, and EBB and EBC both <109 VDC.

l.

AND

b. Failure to restore power to at least one required DC bus within 15 minutes from the time ofloss.

4 BASIS:

Loss of all DC power compromises ability to monitor and control plant safety functions.

Prolonged loss of all DC power will cause core uncovering and loss of containment integrity when there is significant decay heat and sensible heat in the reactor system. Escalation to a General Emergency would occur by Abnormal Rad Levels / Radiological Effluent, Fission Product Barrier Degradation, or Emergency Coordinator / EOF Director Judgment ICs. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

REFERENCE:

NUMARC/NESP 007, REV. 2, 0182, SS3 4

4 D-44

Cctawba Nuclear i te ,

LOSS OF POWER GENERAL EMERGENCY 4.5.G.1 Prolonged Loss of All(Offsite and Onsite) AC Power.

j OPERATING MODE APPLICABILITY: Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)

Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:

4.5.G.1 1 Prolonged loss of all offsite and onsite AC power as indicated by:

. a. Loss of power on essential buses ETA and ETB for greater than 15 minutes.

AND

b. Standby Shutdown Facility (SSF) fails to supply NC pump seal injection OR CA supply to steam generators.

AND

c. At least one of the following conditions exist:

• Restoration of at least one essential bus within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is NOTlikely.

• Indication of continuing degradation of core cooling based on Fission Product Barrier monitoring.

BASIS:

Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prolonged loss of all those functions necessary to r;.;.latain hot shutdown will lead to loss of fuel clad, NCS, and containment.

The SSF is capable of providing the necessary fuactions (reactor caolant pump seal injection and auxiliary feedwater supply to the steam generators) to maintain a hot shutdown condition for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. No fission product barrier degradation would be expected if the SSF is functioning as intended.

D-45

.~,

~

i Catawbo Nuclear Site Analysis in support of the station blackout coping study indicates tliat the plant can cope with a station blackout for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> without core damage.

The likelihood of restoring at least one essential 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.

In addition, under these conditions, fission product barrier monitoring capability may be degraded. Although it may be difficult to predict when power can be restored, it is necessary to give the Emergency Coordinator / EOF Director a reasonable idea of how quickly (s)he may need ,

to declare a General Emergency based on two major considerations l

1, Are there any present indications that core cooling is already degraded to the point that Loss or Potential Loss of Fission Product Barriers is IMMINENT 7

2. If there are no present indications of such core cooling degradation, how likely is it that power can be restored in time to assure that a loss of two barriers with a potential loss of the third barrier can be prevented?

Thus, indication of continuing core cooling degradation must be based on Fission Product Barrier monitoring with particular emphasis on Emergency Coordinator / EOF Director judgment as it relates to IMMINENT Loss or Potential Loss of fission product barriers and degraded ability to monitor fission product barriers.

REFERENCE:

NUMARC/NESP 007, REV. 2, 01/92, SGI 4

h 9

D 46

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Cuawto Nuclear Site ENCLOSURE 4.6 .

FIRF/ EXPLOSION AND SECURITY EVENTS UNUSUAL EVENT 4.6.U.1 Fire Within Protected Area Boundary Not Extinguished Within 15 Minutes of Detection or Explosion Within the Protected Area Boundary.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVEL:

4.6.U.1 1 Fire in any of the following areas not extinguished within 15 minutes of control room notification or verification of a control room fire alarm.

. . Reactor Building

. Auxiliary Building

. Diesel Generator Rooms

. Control Room

. RN Pumphouse

. Standby Shutdown Facility (SSF)

Central Alarm Station (CAS)

. Secondary Alarm Station (SAS)

. Doghouses

. Refueling Water Storage Tank (FWST)

. Turbine Building

. Service Building *

. Interim Radwaste Building 4.6.U.12 Report by plant personnel of an unanticipated explosion within protected area boundary resulting in visible damage to per:nanent structure or equipment.

BASIS:

EAL 1: The purpose of this EAL is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. Fire is combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical

. equipment do noi constitute fires. Observation of flames is preferred but is NOT required if large quantities of smoke and heat are observed. This excludes such items as fires within administration buildings outside the protected area. Waste-basket fires, and other small fires of no safety consequence should easily be extinguished within 15 minutes of detection. This IC 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 to determine that the control room alarm is not spurious.

D 47 g

Cuawbs Nudear Site EAL 2: Only those explosions of sufficient force to damage pennanent structures or equipment within the protected area should be considered. As used here, an explosion is a rapid, violent,

• unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to near by stmetures and materials. 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. The Emergency i Coordinator / EOF Director also needs to consider any security aspects of the explosion, if applicable. '

Escalation to a higher emergency class is by, " Fire or Explosion Affecting the Operability of Plant Safety Systems Required to Establish or Maintain Safe Shutdown". ,

REFERENCE:

NUMARC/NESP 007 REV. 2,01/92, HUI & HU2 l

/  ;

I i

L

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4 D 48

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Cet:wba Nuclear Site FIRF/ EXPLOSION AND SECURITY EVENTS UNUSUAL EVENT 4.6.U.2 Connrmed Security Event Which Indicates a Potential Degradation in the Level of Safety of the Plant.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.6,U.21 Security confinned bomb device discovered within plant Protected Area and outside Vital Areas.

4.6.U.2 2 liostage situation /extonion 4.6.U.2 3 A violent civil disturbance within the owner controlled area.

BASIS:

The above situations represent a potential degradation in the level of safety of the plant.

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

REFERENCE:

NUMARC/NESP 007, REV. 2, 01/92, HU4 D 49

..~.

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Cataoba Nuclear Site FIRF/ EXPLOSION AND SECURITY EVENTS ALERT 4.6.A.1 Fire or Explosion Affecting the Operability of Plant Safety Systems Required to Establish or hialntain Safe Shutdown.

OPERATING MODE APPLICABILITY: hiode 1 (Power Operation) blode 2 (Startup)

Mode 3 (Ilot Standby)

Mode 4 (flot Shutdown)

Moos 5 (Cold Shutdown)

Mode 6 (Refueling)

EMERGENCY ACTION LEVEL:

4.6.A.1 1 The following conditions exist:

a. Fire or explosion in any of the following areas:

. Reactor Building

. Auxiliary Building

. Diesel Generator Rooms

. Control Room

. RN Pumphouse

. SSF

. CAS

. SAS

. IM'ST

. Doghouses (Applies In Mode 1,2,3,4 only)

AND

b. One of the following:

• Affected safety system parameter indications show degraded performance

• Plant personnel report visible damage to permanent structures or equipment within the specified area.

Note: Only one train of a system needs to be affected or damaged in order to satisfy this condition.

D 50

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Cctawba Nuclear Site BASIS:

• With regard to explosions, only those explosions of sufficient force to damage permanent structures or equipment required for safe operation within the identified plant area should be considered. As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts signincant energy to near-by structures and materials. Fire is combustion characterized by heat and light. Sources o'.'

i smoke such as slipping drive belts or overheated electrical equipment do not constitute fi'es.

Observation of flames is preferred but is NOT required iflarge quantitles of smoke and heat sre observed. The inclusion of a " report of visible damage" should not be interpreted as mandatitg a lengthy damage assessment prior to classification.

The key to classifying fires / explosions as an Alert is the damage as a result of the incident. The fact that safety-related equipment required for safe shutdown of the unit has been affected or damaged as a result of the fire / explosion is the driving force for declaring the Alent. It is important to note that this EAL addresses a fire / explosion and not just the degradation of a safety system. The reference to damage of the systems is used to identify the magnitude of the nre/ explosion and to discriminate against minor fires / explosions.

Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Levels / Radiological Effluent, or Emergency Coordinator / EOF Director Judgment ICs.

REFERENCE' NUMARC/NESP 007, REV. 2, 01/92, HA2 o

1 1

, D 51

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Curwb2 Nuclear Site FIRF/ EXPLOSION AND SRCURITY EVENTS ALERT 4.6.A.2 Fire or Explosion Affecting the Operability of Plant Safety Systems Required to Establish or Maintain Safe Shutdown.

OPERATING MODE APPLICABILITY: No Mode (Defueled)

EMERGENCY ACTION LEVEL: 4 4.6.A.21 The following conditions exist:

a. Fire or explosion in any of the following areas:

. Spent Fuel Pool

. Auxiliary Building

. RN Pumphouse AND

b. One of the following:

Spent Fuel Pool level and/or temp:rature show degraded perfonnance.

Plant personnel report visible damage to pennanent structures or equipment supporting Spent Fuel Pool cooling.

Note: Only one train of a system needs to be affected or damaged in order to satisfy this condition.

BASIS:

In a Defueled condition, the plant safety systems of interest are those that supr.si 6, :nt Fuel Poolinventory and cooling.

With regard to explosions, only those explosions of sufficient force to damage permanent structures or equipment required for safe operation within the identified plant area should be

. considered. As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to near-by structures and matc. itis. Fire is combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires.

Observation of flames is preferred but is NOT required if large quantities of smoke and heat are observed. The inclusion of a " report of visible damage" should not be interpreted as mandating a lengthy damage assessment nrior to classificati' D 52

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Caawba Nuclear Site The key to classifying fires /expidstons as an Alert is the damage as a result of the incident. The fact that safety-related equipment required for safe shutdown of the unit has been affected or damaged as a result of the fire / explosion is the driving force for declaring the Alert. It is important to note that this EAL addresses a fire / explosion and not just the degradation of a safety system. The reference to damage of the systems is used to identify the magnitude of the Gre/ explosion and to discriminate against minor fires / explosions.

Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Levels / Radiological Effluent, or Emergency Coordinator / EOF Director Judgment ICs.

REFERENCE:

NUhfARC/NESP 007, REV. 2, 0182, HA2 D-53 m

Cctawba Nuclear Site FIRF/ EXPLOSION AND SECURITY EVENTS ALERT 4.6.A.3 Security Event in a Plant Protected Area.

{ OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVEL:

4.6.A.31 Intrusion into plant protected area by a hostile force.

t BASIS:

This class of security events represents an escalated threat to plant safety above that contained in the Unusual Event. A civil disturbance which penetrates the protected area boundary can be considered a hostile force. Intrusion into a vital area by a hostile force will escalate this event to

, a Site Area Emergency.

REFERENCE:

NUhfARC/NESP-007, REV. 2, 0182. HA4 1

4 D-54

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I Catawbe Nuclear Site

,ElBJ&XPLOSION AND SECURITY EVENTS SITE AREA EMERGENCY 4.6.S.1 Security Event in a Plant Vital Area.

OPERATING MODE APPLICABILITY: All i EMERGENCY ACTION LEVELS:

4.6.S.I.I Intrusion into any of the following plant areas by a hostile force:

. Reactor Building

. Auxiliary Building

. Diesel Generator Rooms

. Control Room

. . RN Pumphouse

. SSF

. Doghouses

. CAS

. SAS 4.6.S.I 2 Security confirmed bomb discovered / exploded in a vital area.

4.6.S.I 3 Security confirmed sabotage in a plant vital area.

BASIS:

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

REFERENCE:

NOMARC/NESP 007, REV. 2, 0182, HS1 D 55

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Catav ba Nuclear Site FIRF/ EXPLOSION AND SECURITY EVENTS GENERAL EMERGENCY 4.6.G.I Security Event Resulting in Loss Of Ability to Reach and Maintain Cold Shutdown.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.6.G.1 1 Loss of physical control of the control room due to security event.

4.6.G.12 Loss of physical control of the SSF and Auxiliary Shutdown Panel (ASP) due to security event.

BASIS:

This IC encompasses conditions under which a hostile force has taken physical control of vital area required to reach and mabeds safe shutdown.

REFERENCE:

NUMARC/NESP-051, REV. 2, 01/92, HG1 D 56

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Caaw ba '4uclear Site ENCLOSURE 4.7 .

NATURAL DISASTERS. HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY UNUSUAL EVENT l 4.7 U.1 Natural and Destructive Phenomena Affecting the Protected Area.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.7.U.1 1 Tremor felt and valid alarm on the " strong motion accelerograph".

4.7.U.12 Tremor felt and valid alarm on the " Peak shock annunciator".

4.7.U.13 Report by plant personnel of tomado striking within protected area boundary.

4.7.U.14 Vehicle crash into plant structures or systems within protected area boundary. l 4.7.U.15 Report of turbine failure resulting in casing penetration or damage to turbine or generator seals.

BASIS:

The protected area boundary is typically that part within the security isolation zone and is defined in the site security plan. -

EALs 1&2: Damage may be caused to some portions of the site, but should not affect ability of safety functions to operate. Method of detection can be 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 vibratary ground motion is felt at the nuclear plant site and recognized as an carthquake based on a consensus of control room operators, and (b) valid alarm on seismic instrumentation occurs.

EAL 3:' A tornado striking (touching down) within the protected boundary may have potentially damaged plant stmetures 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 Alert.

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Cu2wbs Nuclear Site EAL 4: Addresses such items as a car, truck, plane, helicopter, or train crash that may potentially damage plant structures containirig functions and systems required for safe shutdown of tim plant.

If the crash is confirmed to affect a plant vital area, the event may be escalated to Alert.

EAL 5: Addresses main turbine rotiting component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Of major concern is the potential for leakage of cornbustible fluids (lubricating oils) and gases (hydrogen coohng) to the plant environs. Actual fires and flammable gas build up are appropriately classified via other EALs. This EAL is consistent with the definition of an Unusual Event while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment. Escalation of the emergency classification is based on potential damage done by the missiles generated by the failure or by the radiological releases in conjunction with a steam generator tube rupture. These latter events would be classified by the Radiological ICs or Fission Product Barrier ICs.

REFERENCE:

NUMARC/NESP 007, REV. 2, 0182, HU1 NOTE: NUMARC EAL #S moved to Fire / Security Recoinition Category J

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Catawba Nuclear Site NATURAL DISASTERS. HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY UNUSUAL EVENT 4

4.7.U.2 Release of Toxic or Flammable Gases Deemed Detrimental to Safe Operation of the Plant.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.7.U.21 Report or detection of toxic or flam.nable gases that could enter within the site area boundary in amounts that can aff:ct safe operation of the plant.-

J 4.7.U.2 2 Report by Local, County or State Officials for potential evacuation of site personnel

, based on offsite event.

BASIS:

This IC is based on releases in concentrations within the site boundary that will affect the health of plant personnel or the safe operation of the plar.t with the plant being within the evacuation area of an offsite event (i.e., tanker tmck accident releasing toxic gases, etc.).

C ses within the owner ccatrolled area that are below life threatening or flammable concen' rations do not meet this EAL.

REFERENCE:

NUMARC/NESP 007, REV. 2, 01/92, HU3 ,

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Catawba Nuclear Site i NATURAL DISASTERS. HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY UNUSUAL EVENT I 4.7.U.3 Other Conditions Existing Which in the Judgment of the Emergency Coordinator / EOF Director Warrant Declaration of an Unusual Event.

OPERATING MODE APPLICABILITY: All l EMERGENCY ACTION LEVEL:

4.7.U.31 Other conditions exist which in thejudgment of the Emergency Coordinator / EOF Director indicate a potential degradation of the level of safety of the plant.

BASIS:

This EAL is intended to cddress unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the

, Emergency Coordinator / EOF Director to fall under the Unusual Event emergency class.

REFERENCE:

NUbfARC/NESP-007. REV. 2, OUL2, HUS l

l D-60 l l

Cetawba Nuclear Site i

NATURAL DISASTERS. HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY  !

l ALERT i 4.7.A.1 Natural and Destructive Phenomena Affecting the Plant Vital Area.

OPERATING MODE APPLICABILITY: All e

EMERGENCY ACTION LEVELS:

4.7.A.1-1 Valid "OBE Exceeded" Alarm on I AD-4.B/8 4.7.A.12 Tornado or high winds:

Tornado striking plant structures within the vital area:

. Reactor Building

. Auxiliary Building

. Refueling Water Storage Tank (RVST)

. Diesel Generator Rooms

. Control Room

. RN Pumphouse

. Standby Shutdown Facility (SSF)

. Doghouses Central Alarm Station (CAS)

. Secondary Alarm Station (SAS)

OR sustained winds 2 74 mph for > 15 minutes.

4.7.A.1-3 Turbine failure generated missiles, vehicle crashes or other catastrophic events causing visible structural damage on any of the following plant structures:

. Reactor Building

. Auxiliary Building

. Refueling Water Storage Tank (BVST)

. Diesel Generator Rooms

. Control Room

. RN Pumphouse

. Standby Shutdown Facility (SSF)

. Doghouses Central Alarm Station (CAS)

. Secondary Alarm Station (SAS)

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- Cctawba Nuclear Site i-

- BASIS:

EAL 1: Based on the FSAR design basis. Seismic events of this magnitude (> OBE) can cause l- damage to safety functions.

EAL 2: Based on the available instrumentation'( 90 mph maximum range) and the FSAR design

! basis which is 95 mph Wind loads of this magnitude (74 mph hurricane force winds) are i

approaching speeds that could cause damage to safety functions.

. EAL 3: This EAL is intended to address the threat to safety related structures or equipment from uncontrollable and possibly catastrophic events. This list of areas includes areas containing ,

i safety-related equipment, their controls, and their power supplies. This EAL is, therefore, consistent with the definition of an ALERT in that if events have damaged areas containing safety-related equipment the potential exists for substantial degradation of the level of safety of

. the plant.

E i

REFERENCE:

NUMARC/NESP-OO7, REV. 2, 0182, HA1 4

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D-62 "g

Cctawba Nuclear Site NATURAL DISASTERS. HAZARDS AND OTHER CONDITIONS A'FFECTING PLANT SAFETY ALERT 7

- 4.7.A.2 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.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVELS:

4.7.A.2-1 Report or detection of toxic gases within a Facility Structure in concentrations that will be '.ife threatening to plant personnel.

4.7.A.2 2 Report or detection of flammable gases within a Facility Stmeture in concentrations that will affect the safe operation of the plant.

Structures for above E ALs:

. Reactor Building

. Auxiliary Building

. Diesel Generator Rooms

. RN Pumphouse

. Control Room

. SSF

. CAS

. SAS BASIS:

This IC is based on gases that have entered a plant structure affecting the safe operation of the plant. Safe operations are affected when the area can not be accessed by plant personnel to ensure continued operability or availability of safety systems / components. This IC applies to buildings and areas contiguous to plant Vital Areas cr other significant buildings or areas. The intent of this IC is not to include buildings (i.e., warehouses) or other areas that are not contiguous or immediately adjeco .t to plant Vital Areas. It is appropriate that increased monitoring be done to ascertain Rether consequential damage has occurred. Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Levels / Radioactive Effluent, or Emergency Coordinator / EOF Director Judgment ICs.

REFERENCE:

NUMARC/NESP-007, REV. 2. 01/92, HA3 D-63

l Cettwba Nuclear Sit:

i NATURAL DISASTERS, HAZARDS AND OTHER CONDITIONS l AFFECTING PLANT SAFETY l

ALERT 4.7.A.3 Control Room Evacuation IIas Been Initiated.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVEL:

4.7.A.31 Control Room evacuation has been initiated per AP/l(2)/A/5500/17.

BASIS:

With the control room evacuated, additional support, monitoring and direction through the Technical Support Center and/or Emergency Operations Facility is necessary. Inability to establish plant control from outside the entrol room, as evidenced by the inability to maintain NCS or SG inventories, will escalate this event to a Site Area Emergency.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, HAS J

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Catowbc Nuclear Site 1

l NATURAL DISASTERS. HAZARDS AND OTHFR CONDITIONS AFFEUnNG PLANT SAFETY ALERT l

1 4.7.A.4 Other Conditions Existing Which in the Judgment of the Emergency Coordinator / EOF Director Warrant Declaration of an Alert.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVEL:

4.7.A.41 Other conditions exist which in the Judgment of the Emergency Coordinator / EOF Director indicate that plant safety systems may be degraded and that increased monitoring of plant functions is warranted.

BASIS:

This EAL is i .aded to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergety because conditions exist which are believed by the Emergency Coordinator / EOF Director to fall under the Alert emergency class,

REFERENCE:

NUMARC/NESP 007, REV. 2, 0182, HA6 D-65

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Catawb1 Nuclear Site NATURAL DISASTERS. HAZARDS AND OTHEit CONDITIONS AFFEciING PLANT SAFETY SITE AREA EMERGENCY 4.7.S.1 Control Room Evacuation Has Been Initiated and Plant Control Cannot Be Established.

1 OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVEL:

I 4.7.S.1-1 The following conditions exist:

a. Control room evacuation has been initiated per AP/l(2)/A/5500/17.

AND

b. Control of the plant cannot be established from the ASP or the SSF within 15 minutes.

BASIS:

The timely transfer of control to alternate control areas has not been accomplished. This failure to transfer control would be evidenced by deteriorating reactor coolant system or steam generator parameters. For purposes of classification, the 15 minutes begins at the time that the determination to staff the alternate location is made. For most conditions, Reactor Coolant Pump seal LOCAs or steam generator dryout would be indications of failure to accomplish the transfer in the necessary time.

Escalation of this event,if appropriate, would be by Fission Product Barrier D,: gradation, Abnormal Rad Levels / Radiological Effluent, or Emergency Coordinator / EOF Director Judgment ICs.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, HS2 D-66

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CcAawba Nuclear Site 1

NATURAL DISASTERS. HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY I SITE AREA EMERGENCY 4.7.S.2 i Other Condit ons Existing Which in the Judgment of the Emergency i Coordinator / EOF Director Warrant Declaration of Site Area Emergency.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVEL:

4.7.S.21 Other conditions exist which in the Judgment of the Emergency Coordinator / EOF Director indicate actual or likely major failures of plant functions needed for 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 co- litions exist which are believed by the Emergency Coordinator / EOF Director to fall undc- emergency class description for Site Area 4 Emergency.

4

REFERENCE:

NUMARC/NESP-007, REV. 2, 0182 HS3 D-67

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Catawba Nuclear Site i

NATURAL DISASTERS. HAZARDS AND OTHER CONDITIONS 1

AFFECTING PLANT SAFETY GENERAL EMERGENCY  ;-

4.7.G.1 Other Conditions Existing Which in the Judgment of the Emergency Coordinator / EOF Director Warrant Declaration of General Emergency.

OPERATING MODE APPLICABILITY: All EMERGENCY ACTION LEVEL:

4.7.G.1 1 Other conditions exist which in the Judgment of the Emergency Coordinator / EOF Director indicate:

Actual or imminent substantial core degradation with potential for loss of containment OR e

Potential for uncontrolled radionuclide releases. These releases can reasonably be expected to exceed Environmental Protection Agency Protective Action Guideline levels outside the site boundary.

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 / EOF Director to fall under the General Emergency class.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, HG2 i

1 2

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ATTACHMENT 5 Revised Catawba Procedure RP/0/A/5000/01,

" Class;fication of Emergency With Revision Mars k"

(Includes a copy of RP/0/A/5000/01 Revised pages)

J 4

RP/0/A/5000/01 Page 2 of 2 2.0 -IMMEDIATE ACTIONS 2.I Determine operating mode that existed at the time the event occurred prior to any protection system or operator action initiated in response of the event.

2.2 If the plant was in Mode 1-4 and a valid condition affects fission product barriers, then proceed to Enclosure 4.1. l l

2.3 If the condition does not affect fission product baniers, then review the listing of enclosures to determine if the event is applicable to one of the categories shown.

2.4 Compare actual plant conditions to the Emergency Action Levels listed, i then declare the appropriate Emergency Class as indicated.

. 2.5 Implement the :.pplicable Emergency Response Procedure (RP) for that i

classification and continue with subsequent steps of this procedure.

2 Notification of Unusual Event RP/0/A/5000/02 Alert RP/0/A/5000/03 Site Area Emergency RP/0/A/5000/04 General Emergency RP/0/A/5000/05

3.0 SUBSEOUENT ACTIONS 3.1 To escalate, de-escalate, or terminate the Emergency, compare plant

, conditions to the Initiating Conditions of Enclosures 4.1 through 4.7.

1 3.2 Refer to enclosure 4.9, Emergency Declaration Guidelines, as needed.

4.0 ENCLOSURES 4.1 Fission Product Barrier Matrix 4.2 Systems Malfunctions 4.3 Abnormal Rad Levels / Radiological Effluent 4.4 Loss of Shutdown Functions 4.5 Loss of Power 4.6 Fires / Explosions and Security Events 4.7 Natural Disasters, Hazards and Other Conditions Affecting Plant Safety 4.8 Defm' itions/ Acronyms 4.9 Emergency Declaration Guidelines 4.10 Radiation Monitor Readines for Enclosure 4,3 Emercency Action Levels n

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ENCLOSURE 4.1 Catawba Nuclear Site FISSION PRODUCT BARRIER MATRIX Use EALs to determine Fission Product Barrier status (Intact, Potential Loss, or Loss). Add poirits for a!! 3 barriers. Classify according to the table below.

Note 1: This table is only applicabie in Modes 1-4. I Note 2: Also, an event (or multiple events) could occur which results in the conclusion that exceeding the Loss or Potential Loss threshoi% is IMMINENT (i.e., within 1-3 hours). In this IMMINENT loss situation, use judgernent and classify as if the thresholds are exceeded.

Note 3: When determining Fission Product Barrier status, the Fuel Clad Barrier should be considered to be lost or potentially lost if the conditions for the Fuel Clad Barrier loss or poter.tlel loss EALs were met previously during the event, even if the conditions do not currently exist Unusuei E Snt II - 3 Points) Alert (4 - 6 Points) Site Aree Emoroency f7 Generet Emeroency (11 - 13 Points)

- 10 Points)

. Any Potential Loss of Cwdal nent . Any Potential Loss or Loss of the . Loss of both NCS . Loss of an three barriers NCS and Fuel Clad

. Any Loss of Cudi#.6,ent

. Any Potential Loss or Loss of Fuel . Potential Loss of . Loss of any two barriers and the Potential Loss of the Clad both NCS and Fuel third barrier Ctad

. Potenial Loss of either the NCS or Fuel Ctad and Loss of any additional barrier CONTAINMENT BARRIER NCS BARRIER FUEL CLAD BARRIER POTENTIAL LOSS - LOSS -(3 Point (s)) POTENTIAL LOSS - LOSS-(5 Point (s)) POTENTIAL LOSS-(5 Point (s))

(1 Point (s)) (4 Point (s)) LOSS-(4 Point (s))

• t CMecalSafetyfunceen Samus t CrtscalSaint Functon Saba L falcalSafety Funcuen Status

. Carwarvne vRED . Nat apptcatdo . NCsintsytyeed . Nat appicatdo . Core Co*9 . CaeCo*9 Aed Orange

. Hem se*M

. Heat sireand 2fah Cordeone 1 NCStankRats 1 % h AcWVRF1 m f t

RP/OfA/500041 Enclosure 4.1.

Page 1 of 3 - -

CATAWBA NUCLEAR S!TE EMERGENCY ACTION LEVELS FISSION PRODUCT BARRIER MATRIX '

Use EALs to determine Fission Product Barrier stetus (intact, Potential Loss, or Loss). Add points for all 3 berriers. Classify according to the ['

table below.

i Note 1: This table is only applicable in Modes 1-4.

Note 2: Also, an event (or multiple events) could occur which results in the conclusion that exceeding the Loss or Potential Loss thresholds is ,

IMMINENT (i.e., within 1-3 hours), in this IMMINENT Less Situation, use judgement and classify as if the thresholds are exceeded. j Note 3: When determining Fission Product Barrier status, the Fuel Clad Barrier should be considered to be lost or potentially lost if the conditions for the Fuel Clod Barrier loss or potential lose EALs were met previously during the event, even if the conditions do not currently [

exist. -

Unusual Event i1 - 3 Pointal Alert (4 - 6 Points) Stee Aree Emoroency (7-10 Points) General Emergency (11 -13 Points) {

. Any Potential Loss of Containment . Any Potential Loss or Loss of the . Loss of both NCS and Fuel Clad . Loss of aR three beniers NCS

. Any Loss of CwJa..e.t . Any Potential Loss or Loss of Fuel . Potential Loss of both NCS and Fuel . Loss of any two barriers and the Clad Clad Potential Loss of the third benier [

i

. Potenial Loss of erther the NCS or [

Fuel Clad and Loss of any additional barrier C

i NOTE: Take highest points for each barrier and add together in chart below. Do not take more than one number for each barrier. "Not applicables" are included in this table as place holders only, and no points are assigned.

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Containment TOTAL POINTS ,

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l NCS 1-3 Unusual Event t 4-6 Alert v

Fuel Clad 7-10 Site Area Emergency ,

i 11-13 GeneralEmergency l Total Points i

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CATAWBA NUCLEAR SITE RPNA/500041 EMERGENCY ACTION LEVELS Enclosura 4.3 l ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Page j,4 of 3 ,

UNUSUAL EVENT ALERT SITE AREA ESERGENCY GENERAL EIERGENCY

?

1. Any Unplanned Release of Geseous or 1. Any Unplanned Release of Geseous or 1. Boundary Does 7 _ _N.g from 1. Boundary Dose Resulting from Liquid Radioactivity to the Environment Liquid Radioectivity to the en Actuel or Imminent Release an Actual or Imminent Release i that Encoeds Two Times the SLC Limits Environment that Exceeds 200 Times of Redlooctivity Exceeds 100 of 7 - r" , that Enosede

'^

f for 60 Minutes or Longer. the SLC limits for 15 Minutes or mRom TEDE or 500 mRom CDE 1000 mRom TEDE or 5000 mRom Longer. Adult Thyroid for the Actuel or CDE Adult Thyroid for the Actual ,

OPERATING MODE: ALL Projected Duration of the or Projected Durellon of the OPERATING MODE. ALL Releese. Release. i e A valid Trip 2 alarm on radiation monitor I EMF-49L a _MF-57 for a 60 minutes or . A valid indicahon on radiation monitor EMF- OPERATING MODE: ALL OPERATING MODE: ALL wiu hkely continue for 260 minutes which 49L or EMF-57 of z 12E+05 cpm for 21 5 indicates that the release may have minutes or will Nkely continue for 215 minutes . A valid indica 6er,on radiation . A valid indication on radioton exceeded the initiating condition and which bdicates that the release r * / have morutor EMF-36H-124.63E-+03 monitor EMF-36H 2 M L indicates the need to assess the release exceeded the initiating condition and indicates 2 jet 06 cpm sustained for z15 8.3E +03cddsustained for2 5 1 with procedure HP/0/B/1009/14. the need to assess the release with procedure minutes. minutes [

HP/OS/1009/14.

. A valid indication on radiation monitor . Dose assessment team . Dose assessment team EMF-36L of n 4-08E+44 5.4E+03 cpm for . A valid indication on radiation rnonitor EMF- calculations indicate dose calculetons indicate dose z 60 minutes or will hkely contmue for g60 36L of z 4,085+06 5.4E+05 cpm for a 15 consequences greeter then 100 consequences greater then 1000 minutes which indicates that the release minutes or will likely continue for 215 minutes mReta TEDE or 500 mrem CDE mrem TEDE or 5000 mrem CDE may have exceeded the initiatmg condition which indicates that the release may have Adult Thyrcmd at the elle Adult Thynnd at the also and indicates the need to assess thc exceeded the initiating condenon and indicates boundary boundary rsiease with procedure HP/0/Bf1009/25. the need to assess the release with procedure HP10/B/1009/25. . Analysis of field survey results or . Analysis of field survey results or

.. Gaseous effluent being released exceeds field survey samples indicates field survey samples indicates two times SLC 16.11-1 for z 60 minutes . Gaseous effluent being released exceeds 200 dose consequences greater than dose consequences greater than t as determined by Radiation Protection times the level of SLC 16.11-1 for 215 100 mrem TEDE or 500 mrem 1000 mrem TEDE or 5000 mrem

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(RP) procedure. minutes as detemuned by RP procedure. CDE Adu!t Thyroid at the elle boundary CDE Aduft Thynnd at the alte boundary ,

. Liquid effluent being released exceeds two . Liquid effluent being released exceeds 200 times SLC 16.11-6 for z 60 rrwrpes as times the level of SLC 16.11-6 for z 15 Note 1: These EMF readings are calculated Note 1:These EMF readings are calculated determined by RP procedure. minutes as determmed by RP procedure. based on average annual meteorology, site based on average annual meteorology. site boundary dose rate, and design unit werd bounde*y dose rate, and design unit vent [

Note: Note: flow rate. Calculegons by the dose now rate Calculatons by the dose 'i If the monitor reading is sustained for the time if the monitor readng ;s sustained for the t~r assessment team use actual meteorology, assessment team use actual meteorology '

period indicated in the EAL and the required pedod indicated in the EAL and the required release duramon. and unit vent flow rate. release duraton. and unit vent flow rate. L assessments (procedure calculations) cannot assessments (procedure calculations) cannot be Therefore, tnese EMF readogs should not be Therelore these EMF readings should not be be completed within this time period, completed within this time period, declaration must used if dose a..c.aa at team calculations used if dose assessment team calculabons declaraten must be made based on the valid be made based on the valid radiation monitor are available. are avaslable radiation rnorutor reading. reading. .

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CATAWBA NUCLEAR SITE RP/0/A/500041 EMERGENCY ACTION LEVELS Enclosure 4.3 ,

ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Pageitof 3 [

UNUSUA1. EVENT AUMT SITE AREA EMERGENCY GENSUW. EMERGENCY  :

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2. Unexpected incrosse in Plant Radletion 2. Maior Demoge to Irradioted Fuel or Note 2: Note 2:  ;

or Airborne Concentration. Loss of Water Level that Hoe or Will if dose assessment team calculations cannot if dose assessment team calculamons cannot Result in the Uncovering of irradiated be completed in 15 minoles, then valid a.%ir;in 15 rrunutes, then vend OPERATING MOOE: ALI. Fuel Outelde the Reactor Vessel. monitor readings should be used for mono raeongs 2ould be used for emergency classificabon. emergency classificason=

• !~94 tion of uncontrolled water level OPERATING MODE: ALL decrease of g< eater than 6 inches in the EE reactor refueling cavity with an irradiated e An unplanned valid trip 11 alarm on any gg fuel assemblies remammg covered by of the foRowing radiabon monitors:

water.

Spent Fuel Buddog Refueling Bridge e Uncontrolled water level decrease of 1 EMF-15 greater than 6 mches in the spent fuel pool 2 EMF-4 and fuel transfer canal wtth aH irradiated fuel assemblies remaming covered by Spent Fuel Pool Ventilation water. 1 EMF-42 2 EMF-42

. U.:ptanned valid area EMF readmg increases by a factor of 1000 over normal Reactor Budding Refuelop Bridge levels as shown in Enclosure 4.10 of 1 EMF-17 RP/0/A/500001 2 EMF-2 E.sg containment Noble Gas Morntor 1 EMF-39 2 EMF-39

}

• Plant personnel report that water level drop in reactor refueling cavity, spent fuel t pool, or fuel transfer canal has or wie exceed makeup capacity such that any irradiated fuel wdl become uncovered.

CATAWBA NUCLEAR SITE RPAWA/500001 EMERGENCY ACTK)N LEVELS Enclosup 4.3

\ ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT PageRof 3 ,

T UNUSUAL EVENT ALERT SITE AREA DIERGENCY GEpKRAL DERGENCY t

. NC system wide range level <95 %

ofter initietKm of NC system make-up AND Any irradiated fuel assembly not capable of being lowered into spent fuel pool or reactor vessel I m mm

. Scent Fuel Pool or Fuel Transfer Canal level decrease of >2 foot after trunation of huo

.4!E j Any irradseted fuel assemth not capable of beina fully lowered hto spent fuel ooot racks or transfer canal fuel transfer system basket i

3. Rolenes of Radioactive Meterial or increases in Radiation Lowels Within the Facility That Impedes Operation of Systems Required to Molnteln Safe Operations or to Establish or Molnteln Cold j

Shutdown.

i i

OPERATING MOOE. ALL

. Valid reading on EMF-12 greater than 15 mR/hr in the Control Room.

. Vand indicatio:1of radiationlevels greater than 15 mR/hr in the Central Alarm Station (CAS) or Secondary  ;

Alarm Sta6on (SAS).

i

CATAV e. A NUCLEAR STTE RPAl/AniO0001 EMERGL JCY ACTION LEVELS Enclosure 4.3 AENORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT PaQof3 J UNUSUAL EVENT ALERT SITE AREA EMERGENCY GEfERAL EMERGENCY

• Vahd radiaton monitor readino onceeds he bmns shown in Enclosure 410.

• Radiagonlevels in areas roouwino /

infreauant access are such M tanks needed b Maale operations or to M or maintain cold cannot be ceriormed e odimar -% .xoosure dof 5 Rem oor wear TEDE.

E!E 9

6

,1 i

l i

,_.________-________-__-_______________-___t

m . . . _ . . ._

CATAWBA NUCLEAR SITE RP/OfA/500001 EMERGENCY ACTION LEVELS Enclosure 4.4 l LOSS OF SHUTDOWN FUNCTIONS Page14of 2 '

UNUSUAL EVENT ALERT SITE N EM8NY N MY ,

EHE

1. Fellure of Reactor Protection System 1. Fellure of Reactor Protection System 1. Failure of the Reactor Protection i instrumentation to Complete or initlete Instrumentation to Complete or initlete System to Complete en Athmetic Trip on Automatic Reactor Trip Once e en Automatic Reector Trip Once a and Manuel Trip wee NOT Successful Reactor Protection System Setpoint Reactor Protection System Setpoint and There le Indicadon of an Estreme Hee Been Escoeded and Manuel Trip Hee Been Escoeded and ManuelTrip Chellenge to the Ability to Coolthe MSuccessful. WAS NOT Successful Core.

OPERATING MODE: 1,2,3 OPERATING MODE: 1 OPERATING MODE: 1

. The folkmng corufstions exist . The following conditions exist . The following condsons exist '

Valid reactor trip signal received Valid reactor trip signal Valid reactor trip signal recerved or or required and automenc reactor received or required and automatic required and automatic reactor trip was not successful. reactor trip was not successful. trip was not successful.

AND AND AND y Manual reactor trip from the control Manual reactor trip from the control Manual reactor trip from the control  ;

roomig successful and reactor roorn was not successfulin reducing room was not successfulin reducing i power is less than 5% and reactor, sower to less than 5% and reactor power toless than 5% and  ;

decreasing. decreasing. decreasing.

2. Complete Loos of Function Nooded to AND Achieve or Maintain Hot Shutdown. .

ElTHER of the following mnditions

,. OPERATING MODE: 1.2,3,4 exist

.i

. Suberiticality CSF-RED . Core Cooling CSF-RED  ;

l . Cr "- ; CCF "50 . Heat SirA CSF-RED r

. Heat Sink CSF-RED

RPMA/500001- .

ENCLOSURE 4.10'

• Page1of 1 Radiation Monitor Readings for Enclosure 4.3 Emergency Action Levels  ?

Note: . These values are not intended to apply to anticipated temporary increases due to planned events (e.g. incore detector movement, radwaste container movement, depleted resin transfers, etc.)

j- l Detector Elevation Column Identifier Unusual Event Alert mrad /hr mrad /hr IEMF-1 522' FF,57 Au~ijiary Building Corridor 500 5000 lEMF-3 543' GG,55 Ur . Charg,;ng Pump Area 100 5000 1 EMF-4 543' GG,59 - Unit 2 Charging Pump Area 100 5000 .

1E M F-7 560' NN,55 Unit 1 Aux. Bldg. Corridor 1500 5000 ..

I EMF-8 560' NN,59 Unit 2 Aux. Bldg. Corridor 500 5000 I IEMF-9 577' LL,55 Unit 1 Aux. Building Filter Hatch 100 5000 ,

IEMF-10 577* LL,58 Unit 2 Aux. Building Filter Hatch 100 5000 t IEMF-22 594' KK,53 Containment Purge Filter Area 100 5000 2 EMF-9 594* KK.61 Containment Purge Filter Area 100 5000 ,

I r

i b

e + w

_ . _ ~ . _ - . -

RP/0/N5000/01 -

Page 2 of 2

!- 2.0 IMMEDIATE ACTIONS i .

f 2.1 Determine operating mode that existed at the time the event occurred prior i

to any protection system or operator action initiated in response of the l event.

l 2.2 If the plant was in Mode 1-4 and a valid condition affects fission product

barriers, then proceed to Enclosure 4.1.

L l 2.3 If the condition does not affect fission product barriers, then review the i

listing of enclosures to determine if the event is applicable to one of the categories shown.

2.4 Compare actual plant conditions to the Emergency Action Levels listed,

!. then declare the appropriate Emergency Class as indicated.

{ ,

2.5 Implement the applicat le Emergency Response Procedure (RP) for that

classification and continue with subsequent steps of this procedure.

1 j Notification of Unusual Event RP/0/N5000/02

Alert RP/0/N5000/03

} Site Area Emergency RP/0/N5000/04 I j General Emergency RP/0/N5000/05

[

4 3.0 SUBSEOUENT ACTIONS 3.1 j To escalate, de-escalate, or terminate the Emergency, compare plant j conditions to the Initiating Conditions of Enclosures 4.1 through 4.7.

[ 3.2 Refer to enclosure 4.9, Emergency Declaration Guidelines, as needed.

4.0 ENCLOSURES J

4.1 Fission Proc

uct Barrier Matrix

[ 4.2 - Systems "

• I 4.3 e smal Raa l averuL. ilogical Effluent

{ ,.* kw cf Shuid mn Fus:tio: ,

, 4.5 Lw uiPowr 1 46 Fi,es!L h. es and Securi' Events 4 41 h n w

can, Waards e i Other Conditions l Alfechy P!zitt Safey J8 t%5hriore/Acronyns

<t.9 Eme:p,cy TA . .on Guidelines 4J' R uli o , .aor Readings for Enclosure 4.3 Emergency Action Levels f

m

ENCLOSURE 4.1 Catawba Nuclear Site FISSION PRODUCT BARRIER MATRIX Use EALs to determine Fission Product Barrier status (Intact, Potential Loss, or Loss). Add points for all 3 barriers. Classify according to the table below.

Note 1: This table is only applicable in Modss 1-4. 3 Note 2 Also, an event (or multiple events) could occur which results in the conclusion that exceeding the Loss or Potential Loss thresholds is IMMINENT (i.e., within 1-3 hours). In this IMMINENT loss situation, use judgement and classify as if the thresholds are exceeded.

Note 3: When determining Fission Product Barrier status, the Fuel Clad Barrier should be considered to be lost or potentially lost if the conditions for the Fuel Clad Barrier loss or potential loss EALs were met previously during the event, even if the conditions do not currently exist unusual Event (1 - 3 Points) Alert (4 - 6 Points) site Aree EU-is,6c, (7 General Emeroency (11 - 13 Points)

- 10 Points)

. Any Potential Loss of Containment . Any Potentlaf Loss or Loss of the . Loss of both NCS . Loss of all three barriers NCS and Fuel Ctad

. Any Loss of Containment . Any Potential Loss or Loss of Fuel . Potential Loss cf . Loss of any two barriers and the Potential Loss of the Ctad both NCS and Fuel third banier Ctad

. Potenial Loss of either the NCS or Fuel Ctad and Loss of anyadditional barrier l

4,aTAINMENT BARRIER NCS BARRIER FUEL CLAD BARRIER POTENTIAL LOSS- LOSS -(3 Point (s)) POTENTIAL LOSS - LOSS-(5 Point (s)) POTENTIAL LOSS-(5 Point (s))

(1 Point (s)) (4 Point (s)) LOSS-y _ _

(4 Point (s))

, 1. Cducsf Esfsty Funeden Samsus 1.Crliled $dety Fisicean Status 1, Crtscar Safuey Fwnilon Status

. Conusarnere4ED e Nat appicable

• NCsInteyty4ed . Ncs appicable

• Core Coolrg-

• Core CocEngBed orange

. Hem setaed

• Hast sirtend LContaktment CondGons 1MCS t.adLBe 1 Primary C6 Level

RP/OfA/500041 Enclosure 4.1

- Page 1 of 3 -

CATAWBA NUCLEAR SITE ,

EMERGENCY ACTION LEVELS Y

FISSION PRODUCT BARRIER MATRIX Use EALs to determine Fission Product Barrier status (Intact, Potential Loss, or Loss). Add points for all 3 barriers. Classify according to the table below.

Note 1: This table is only applicable in Modes 1-4.

Note 2: Also, an event for multiple events) could occur which results in the conclusion that exceeding the Loss or Potential Loss thresholds is 1

IMMINENT (i.e., within 1-3 hours). In this IMMINENT Loss Situation, use judgement and classify as if the thresholds are exceeded.

l Note 3: When determining Fission Product Barrier status, the Fuel Clad Barrier should be cor.:Idered to be lost or potentially lost if the conditions for the Fuel Clad Barrier loss or potential loss EALs were met previously during the twent, even if the conditions do not currently -

exist.

Unusual Event (1 - 3 Points) Alert f4 -6 Points) page Aree Emergency f7-10 Pointel General Emereency i11 - 13 Points)

. Any Potential Loss of Cmdiidr.T.ent . Any Potential Loss or Loss of the . Loss of both NCS and Fuel Clad . Loss of a!! three barriers NCS

. Any Loss of Containment . Any Potential Loss or Loss of Fuel . Potential Loss of both NCS and Fuel . Loss of any two beniers and the Ctad Clad Potential Loss of the third banier

. Potenial Loss of either the NCS or Fuel Clad and Loss of any additional barrier NOTE: Take highest points for each barrier and add together in chart below. Do not take more than one number for each barrier. *Not applicables" are included in this table as place holders only, and no points are assigned.

l

}

Containment TOTAL POINTS .

i NCS 1-3 Unusual Event  ;

4-6 Alert Fuel Clad 7-10 Site Area Emergency t

~

11-13 General Emergency Total Points t i

-m_--- d * - A _ . _ . - - _ .___.m_....__-__

i CATAWBA NUCLEAR SITE -

RP/0/A/5000m1 EMERGENCY ACTION LEVELS , Enclosure 4.3 ABNORMAL RAD LEVELS /RADIOLOG; CAL EFFLUENT Page 1 of 3 .

UNUSUAL EVENT ALERT SITE AREA EMERGENCY GEffERAL EMERGENCY

?

1. Any Unplanned Release of Gaseous or 1. Any Unplanned Release of Geseous or 1. Boundary Dose Resulting from 1. Boundary Dose T ~-4 from Liquid Radioactivity to the Environment Liquid Radioactivity to the a- Actuoiorimminent Relenos en Actuel orimminent Reisese that Exceeds Two Times the SLC Limits Environment that Exceeds 200 TisNs or Radiosctivity Exceeds 100 of Radioactivity that Exceeds for 60 Minutes or Longer. the SLC limits for 15 Minutes or mRom TEDE or 500 mrem CDE 1000 mrem TEDE or 5000 mRom Longer. Adult Thyroid for the Actuelor CDE Adult Thyroid for the Actuel OPERATING MODE: ALL Projected Duration of the or Projected Duration of the OPERATING MODE: ALL Release. Release.

. A valid Trip 2 alarm on radiation monitor EMF-49L or EMF-57 for160 rninutes or . A valid indication on radiation monitor EMF- OPERATING MODE: ALL OPERATING MODE: ALL j wiu likely continue for 160 minutes which 49L or EMF-57 of g 1.2E+05 cpm for z15 indicates that the release may reve minutes or will likely continue for 215 minutes . A valid indication on radiation . A valid indicat6on on radiation exceeded the initiating condition and which indicates that the release may have monitor EMF-36 L2 2.7E+06 cpm monitor EMF-36H 2 8.3E +03 cpm indicates the need to assess the release exceeded the initiating condition and indicates sustained for2 15 minutes. sustained fo/z15 minutes.

with procedure HP/0/B/1009/14. the need to assess the release with procedure HP/0/B/1009/i4. . Jose assessment team . Dose assessment team I

f . A valid indcation on radiation monitor calculaticos indicate dose calculations indicate dose EMF-36L of m SAE+03 cpm for 160 . A vetid indication on radiation monitor EMF- consequences greater than 100 consequences greater than 1000 minutes or will tilcely continue for g60 36L of a SAE+05 cpm for g 15 minutes or wiu mrem TEDE or 500 mrem CDE mrem TEDE or 5000 mrem CDE minutes which indcates that the release likely continue for215 minutes which indicates Aduft Thyroid at the site Adult Thyroid at the site may have exceeded the initiating condition that the release may have exceeded the boundary. boundary and indicates the need to assess the initiating condition and indicates the need to release with procedure HP/0/B/1009/25. assess the release with procedure . Analysis of field survey results or . Analysis of field survey results or HP/0/B/1009/25 field survey samples ir41icates fie8d survey samples indicates

.. Gaseous effluent being released exceeds dose consequences greater than dose consequences greater than two times SLC 16.11-1 for a 60 minutes . Gaseous effluent being released exceeds 200 100 mrem TEDE or 500 mrem 1000 mrem TEDE or 5000 mrem as determined by Radiation Protection times the level of SLC 16.11-1 for 2 5 1 CDE Adult Thyroid at the site CDE Aduft Thyroid at the site (RP) procedure. minutes as determined by RP procedure. boundary. boundary

. Liquid effluent being released exceeds two . Liquid effluent being released exceeds 200 Note 1: These EMF readings are calculated Note 1:These EMF readings are caculated times SLC 16.11-6 for160 minutes as times the levelof SLC 16.11-6 for115 based on average annual meteorology, site based on average annual meteorology, site determined by RP procedure. minutes as determined by RP procedure, boundary dose rate, and design unit vent boundary dose rate, and design unit vent flow rate. Calculations by the dose flow rate. Calculations by the dose Note. Note: assessment team uae eaual meteorology, assessment team use actual meteorology.

If the monitor reading is sustained for the time if the monitor reading is sustained for the time release duration, and unit vent few rate. release duration, and unit vent flow rate.

penod indcated in the EAL iLnd the required period indicated in the EAL gn!! the required Therefore, these EL ' readings should not be Therefore, these EMF readings should not be assessments (procedure calculations) cannot assessments (procedure calculations) cannot be used if dose assessment team calculations used if dose assessment team calculations be completed within this time period, completed within this time period, declaration must are available. are availatde.

declaration must be made based on the valid be made based on the valid radiation monitor radiation monitor reading. reading. '

- - - . ~ . . .~ . . . . . . . . - - - . . . . - - . . . . . . _ . . . - . . - -- .. .. --

CATAWBA NUCLEAR SITE RP/OfA/500041 EMERGENCY ACTION LEVELS ' Enclosure 4.3 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Page 2 of 3 ,.

UNUSUAL EVENT M.ERT SRE AREA EMERGENCY GENERM.EMERGDCY

2. Unexpected increces in Plant Radletion 2. Major Damage toirrediated Fuel or Note 2: . Note 2- .

or Airborne Concentration. . Loss of Water Level that Hee or Will if dose ::n_. .1 team calculations cannot if dose asseeement team e=h'dadans caret s Result in the Uncovering of irredleted be w.-f _ ^ed in 15 minutes, then valid be w.-f- _1 in 15 minutes. men valid OPERATING MODE. -ALL Fuel Outelde the Reactor Vessel monnor readings should be used for rnorntor readngs should be used for L.

emergency classification. emoigency claseMicabon.  ;

• Indication of uncontrolled waterlevel OPERATING MODE: ALL decrease of greater than 6 inches in the gtg reactor refueling cavity with aH irradiated e Ar tmplanned valid trip li alarm on any ggg fuel assembhes remarung covered by of the ionowing radiation monitors.

water. i Spent Fuel Buading Refueling Bridge +

e Uncontrolled water level decrease of 1 EMF-15 greater than 6 inches in the spent fuel pool 2 EMF-4 '

and fuel transfer canal with aR irradiated fuel asse:hblies remaming covered by Spent Fuel Pool Ventitation >

water. 1 EMF-42 '

~

2 EMF-42

• Unplanned valid area EMF reading hereases by a factor of 1000 over normal Reactor Building Refueling Bridge levels as shown in Enclosure 4.10 of 1 EMF-17 RP/0/A/5000/01. 2 EMF-2 E!E Contamment Noble Gas Monitor 1 EMF-39

. EMF-39

}

• Plas 1 personnet report that water level dersp in reactor refueling cavity, spent fuel rool. or fuel transfer canal has or wis exceed makeup M such that any =

8 radiated Mel wEl become uncovered.

l i

+

y a

h

CATAWBA NUCLEAR SITE RP/OfA/500041 EMERGENCY ACTION LEVELS Enclosure 4.4 LOSS OF SHUTDOWN FUNCTIONS Page 1 of 2 '

UNUSUAL EVENT MT SITE MEA MRGEM GEM N 1 E!@

1. Folhere of Reactor Protection System 1. Failure of Reactor Protection System 1. Failure of the Reactor Protection instrumentation to Complete or initlete Instrumentation to Complete or initlete System to Complete en Automatic Trip en Automatic Reactor Trip Once a en Automatic Reactor Trip Once e and Manuel Trip was NOT Successful '

Reactor Protection System Setpoint Reactor Protection System Setpoint and There is Indication of an Extreme Hee Been Exceeded and Manuel Trip Has Been Exceeded and Manuel Trip Chellenge to the AblIIey to Coot the E83. Successful WAS NOT Successful Core.

OPERATING MODE: 1,2.3 OPERATING MODE: 1 OPERATING MODE: 1

. The fonowing conditions exist . The following conditons exist . The following condsons exist Valid reactor trip signal received Valid reactor trip signal Valid reactor trip signal received or !

or required and automatic reactor received or required and automatic required and automatic reactor trip was not successful. reactor trip was not successful. trip was not successful.

AND AND AND Manual reactor trip from the control Manual reactor trip from the control Manual reactor trip from the control roomig successful and reactor room was not successfulin reducing room was not successfulin reducing power is less than 5% and reactor power to less than 5% and reactor power to less than 5% and decreasing. decreasing. decreasing.

2. Co@lete Loss of Function Needed to AND Achieve or Maintain Hot Shutdown.

EITHER of the following constions OPERATING MODE: 1,2,3,4 exist i

.l

. SubenticalityCSF-RED . Core Cooling CSF-RED

. Heat Sink CSF-RED . Heat Sir

• CSF-RED t

E!E  !

t i

CATAWBA NUCLEAR SITE RP/0/A/5000/01 EMERGENCY ACTION LEVELS Enclosure 4.3 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Page 1 of 3 .

UNUSUAL EVENT ALERT SITE AREA EMERGENCY GENERAL EMERGENCY

)

1. Any Unplanned Release of Geseous or 1. Any Unplanned Release of Geseous or 1. Boundary Dose Resulting from 1. Boundary Dooo Resulting from Liquid Radioactivity to the Environment Liquid Radioactivity to the en ActualorImminentRelease en Actual or Imminent Release j that Exceeds Two Times the SLC Limits Environment that Exceeds 200 Times of Radioactivity Exceeds 100 of Radioectivity that Exceeds ,

for 60 Minutes or Longer. the SLC limits for 15 Minutes or mRom TEDE or 500 mRom CDE 1000 mRom TEDE or 5000 mRom

! Longer. Adult Thyroid forthe Actualor CDE Adult Thyroid for the Actuel ,

OPERATING MODE: Al.L Projected Duration of the or Projected Duration of the I OPERATING MODE: ALL Rooseso. Release.

. A valid Trip 2 alarm on radiation monitor EMF-49L or EMF-57 for z 60 minutes or . A valid indication on radiation monitor EMF- OPERATING MODE: ALL OPERATING MODE: ALL will likely continue for 160 minutes which 49L or EMF 57 of z 1.2E+0S cpm for 215 indicates that the release may have minutes or wiB likely conthue for 215 minutes . A valid indication on radiation . A valid indication on radiation exceeded the initiating condition and which indicates that the release may have rnonitor EMF-36 L2 2.7E+06 cpm monitor EMF-36H 2 8.3E +03 cpm indicates the need to assess the release exceeded the iritiating conditbn and indicates sustained for z15 minutes. sustained for z15 minutes.

with procedure HP/0/B/1009/14. the need to assess the release with procedure HP/0/B/1009/14. . Dose assessment team . Do.e assessment team

. A valid indication on radiation monitor calculations indicate dose calculations indicate dose

EMF-36L of a SAE+03 cpm for a 60 . A va!ld indication on radiation monitor EMF- consequences greater than 100 consequences greater than 1000 minutes or willlike;y continue for 160 36L of z 5AE+05' cpm for z 15 minutes or will mrem TEDE or 500 mrem CDE mrem TEDE or 5000 mrem CDE minutes which indicates that the release likely continue for 215 minutes which indicates Adu't Thyroid at the site Adu!t Thyroid at the site may have exceeded the initiating condition that the release may have exceeded the boundary. boundary.

and indicates the need to assess the initiating condition and indicates the need to release with procedure HP/0/B/1009/25. assess the release with procedure . Analysis of field survey results or . Analysis of field survey results or HP/0/B/1009/25. field survey sarnples indicates field survey samples indicates

.. Gaseous effluent being released exceeds dose consequences greater than dose consequences greater than two times SLC 16.11-1 for z 60 minutes . Gaseous effluent being released exceeds 200 100 mrem TEDE or 500 mrem 1000 mrem TEDE or 5000 mrem as determined by Radiation Protection times the level of SLC 16.11-1 for z 15 CDE Adult Thyro 6d at the site CDE Adult Thyroid at the vie (RP) procedure. minutes as determined by RP procedure. boundary. boundary.

e Liquid effluent being released exes 1s two . Liquid effluent being released exceeds 200 Note 1: These EMF reehs are calculated Note 1: These EMF readings are calculated times SLC 16.11-6 for z 60 minutes as times the level of SLC 16.11-6 for z 15 based on average anry n "eteorology, site based on average annual me'eorology, site determined by RP procedure. minutes as determrned by RP procedure. boundary dose rate, ar. 0 -Jgn unit vent boundary dose rate, and design unit vent i flow rete. Calculations by the dose flow rate. Calculations by the dose Note: Note: assessment team use actual meteorology, assessment team use actual meteorology, if the monitor reading is sustained for the time if the monitor reading is sustained for the time release duration, and unit vent flow rate. release duration, and unit vent flow rate.

period indicated in the EAL d the required period indicated in the EAL 3r.d the required Therefore, these EMF readh;s should not be Therefore. these EMF readings should not be assessments (procedure calculations) cannot assessments (procedure calculations) cannot be used if dose assessment team calculations ut ed if dose assessment team calculations be completed within this time period. completed within this time period, declaration must are available. art available.

declaration must be made based on the valid be made based on the volld radiation monitor ras stion monitor reading. reading.

CATAWBA NUCLEAR SITE RP/0/A/500041 EMERGENCY ACTION LEVELS Enclosure 4.3 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Page 2 of 3 UNUSUAL EVENT ALERT SITE AREA EMEROENCY GENERAL EMERGENCY

2. Unexpected increase in Plant Radiation 2. Major Damage to Irradiated Fuel or Note 2: Note 2:

or Airborne Concentration. Loss of Water Level that Has or Will if dose assessment team calculations carmot if dose assessrnent team calculacons cannot Result in the Uncovering of Irradiated be completed in 15 rninutes, then valid be completed in 15 minutes, then valid OPERATING MODE: ALL Fuel Cutelde the Reector Vessel rnonitor readings should be used for monstor readings should be used for emergency classification. emergency classification.

. Indution of uncontrolled waterlevel OPERATING MODE: ALL decrease of greater than 6 inches in the ENQ reactor refueting cavity with aR irradiated . An unplanned valid inp 11 alarm on any ENQ fuel assemblies rernaining covered by of the foRowing radiation monitors:

water.

Spent Fuel Buading Refueling Bridge

. Uncontrolled water level decrease of 1 EMF-15 greater than 6 inches in the spent fuel pool 2 EMF 4 and fuel transfer canal with a8 irradiated fuel assemblies remaining covered by Spent Fuel Pool Ventilation water. 1 EMF 42 2 EMF-42

. Unptanned valid area EMF reading increases by a factor of 1000 over normal Reactor Building Refuehng Bddge levels as shown in Enclosure 4.10 of 1 EMF-17 RP/0/A/5000/01. 2 EMF-2 ENR Containment Noble Gas Monitor 1 EMF-39 2 EMF-39

}

. Plant personnel report that water level drop in reactor refueling cavity, spent fuel pool, or fuel transfer canal has or wiR exceed makeup capacity such that any irradiated fuel wiR become uncovered.

CATAWBA NUCLEAR SITE RPAFA/5000Rn EMERGEP'CY ACTION LEVEL 3 Enclosure 4.3 i ABNORMAL RAD LEVELS / RADIOLOGICAL EFFL'KMT Pege 3 M 3 ,j UNUSUM EVENT ALEPT SITE AREA EtERGESCY M

• NC system wide range level <95 % ,

after N of NC system make-up i

Afe Any irradiated fuel assemtdy not capable of being lowered em spent fuel pod er reactor vessel

. Spent Fuel Pool or Fuel Transfer Canal level decrease of >2 feet aner initason of mole g AND '

Any irradiated fuel assemtdy not capable of being fusy lowered into spent fuel pool L

rocks or transfer canal fuel transfer q system basket t

3. Roteese of Redlooctive Moto fel or Increases in RedleSon Levole

\

Wtihin the Feesity That Impedes i opereuen of systenn Required to Meintain sole operseens ce to  !

Establish o- Maintain Cold ^

l

• % : _^ - .

I OPERATING MODE: ALL [

. Volid reading on EMF-12 greater then 15 mR/hrin the Control Room.

. Valid indcation of radiaton teweis greater then 15 mRhr in the Cereal Alarm Stenon (CAS) er Secondary Alarm Staton (SAS).

. Valid radeton morutor reading exceeds the limits shown in ,

Enclosure 4.10 ram I

RP/OfA/50004)I ENCLOSURE 4.10

Page1of 1 i

Radiation Monitor Readings for Enclosure 4.3 Emergency Action Levels Note: These values are not intended to apply to anticipated temporary increases due to planned events (e.g. incore detector movement, radwaste cotstainer movement, depleted resin transfers, etc.)

l Detector Elevation Column Identifier Unusual Event Alert

,, mrad /hr mrad /hr 1 EMF-1 522' ' FF.57 Auxiliary Building Corrider 500 5000  ;

IEMF-3 543' GG 55 Unit 1 Charging Pump Area 100 5000 IEMF-4 543' GG.59 Unit 2 Charging Pump Area 100 5000 1 EMF-7 560* NN,55 Unit 1 Aux.Bidg. Corridor 1500 5000 ,

1 EMF-8 560' NN.59 Unit 2 Aux. Bldg. Corridor 500 5000 1 EMF-9 577' LL.55 Unit 1 Aux. Building Filter Hatch 100 5000 1 EMF-10 577' LL.58 Unit 2 Aux. Building Filter Hatch 100 5000 594' 4

1 EMF-22 KK,53 Containment Purge Filter Area 100 5000 2 EMF-9 594* KK.61 Containment Purge Filter Area 100 5000 t

I l

l j o  !

i 1

F l

,--