ML20217E318

Forwards EALs Developed for Permanently Shutdown Maine Yankee Plant to Facilitate NRC Staff Review of Defueled Emergency Plan & Attendant Exemption Request to 10CFR50.54(q) Submitted in Nov 1997

ML20217E318
Person / Time
Site:	Maine Yankee
Issue date:	03/25/1998
From:	Zinke G Maine Yankee
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GAZ-98-16, MN-98-18, NUDOCS 9803310005
Download: ML20217E318 (8)

Text

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MaineYankee i

P.O. BOX 408 = WISCASSET. MAINE 04578 a (207) 882-6321 March 25,1998 MN-98-18 GAZ-98-16 l

UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, D.C. 20555

References:

(a) License No. DPR-36 (Docket No. 50-309)

'(b) Letter: Maine Yankee to USNRC, Defueled Emergency Plan and 10CFR50.54 (q) -

Exemption Request dated 6 November 1997 (MN-97-119)

Subject:

Emergency Action Levels for the Maine Yankee Defueled Emergency Plan Gentlemen:

Maine Yankee is pleased to submit with this letter the Emergency Action Levels (EALs) developed for the permanently shutdown Maine Yankee plant. These EALs are submitted to facilitate NRC l stafTreview of the Defueled Emergency Plan and the attendant exemption request to 10CFR50.54(q) i submitted in November 1997 (Reference b). We have discussed these EALs for the Defueled '

Emergency Plan during meetings with State and local governmental authorities conducted during December 1997 and February 1998, respectively, and obtained consensus on these EALs.

The EALs are administratively controlled by Maine Yankee's Defueled Emergency Plan implementing procedures. Future changes to the EALs made to reflect the changes to the facility as applicable structures, systems and components are abandoned during decommissioning will be performed in accordance with the provisions of 10CFR50.54(q).

Maine Yankee anxiously awaits NRC staff review of the Defueled Emergency Plan and the expedient approval of the previously submitted exemption requests to 10CFR50.54(q) (Reference b).

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, I 9803310005 980325 PDR ADOCK 05000309 F pop

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MaineYankee UNITED STATES NUCLEAR REGULATORY COMMISSION MN-98-18 Attention: Document Control Desk Page Two l

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' Should you have any questions on the enclosed, please contact us.

Very truly yours, George A. Zinke, Direc 6 Nuclear Safety & Regulatory Affairs

Attachment:

A. Maine Yankee Emergency Classification Matrix c: Mr. Samuel Collins l Mr. Hubert Miller Mr. Michaai Webb Mr. Micht.. i Masnik J Mr. Ron Bellamy Mr. R. A. Rasmussen

. Mr. Dan Barss Mr. Clough Toppan Mr. Patrick J. Dotsie Mr. Uldis Vanags Mr. John W. Libby, State Director, MEMA l l l

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, Proc. No. 2-50-Od Rev.No. 0 l

Page 5 of 22 ATTACHMENTA (Sheet 1 of 6)

EMERGENCY CLASSIFICATION MATRIX DEFINITIONS AND ACRONYMS BOMB - An explosive device (See EXPLOSION).

CIVIL DISTURBANCE - A group of approximately 20 or more persons violently protesting station activities.

EXPLOSION - A rapid, violent unconfined combustion or catastrophic failure of pressurized equipment that 1 imparts energy of sufficient force to potentia!!y damage permanent plant structures.

FIRE - Combustion typically characterized by heat and light. Source of smoke from slipping drive belts or 1 overheated electrical components do not constitute fires. Observation of flame is preferred, but is not required if I large amounts of smoke and heat are observed.

FLAMMABLE GAS - Any gas which will burn in the normal concentration of oxygen in air.

IMMEDIATELY DANGEROUS TO LIFE AND HEALTH (IDLH) - The maximum concentration from which one could escape within 30 minutes without any escape-impairing symptoms or irreversible health effects.

INDUSTRIAL AREA - The ovmor controlled area outside of the Protected Area.

LOWER EXPLOSIVE LIMIT _L) - The lowest concentration of a gas that burns or explodes if an ignition source is present at ambient tempt. .res.

PROJECTILE - An object ejected, thrown, dropped or launched towards a plant structure. The source of the projectile may be on-site or off-site. Damage is sufficient to cause concern regarding the integrity of the effected i structure or the operability or reliability of equipment contained therein. I PROTECTED AREA - The area that is encompassed by the Security Fence.

SABOTAGE - Deliberate damage, mis-alignment, or mis-operation of plant equipment with the intent to render the equipment or the plant inoperable or in an otherwise unsafe condition.

TOXIC GAS - A gas that is dangerous to life or limb by reason of inhalation or injection (e.g. chlorine).

UNPLANNED - An event or action that is not the expected result of normal operations, testing or maintenance.

Events that result in corrective or mitigative actions being taken in accordance with abnormal or emergency procedures are UNPLANNED.

UNPLANNED (with respect to release of radioactive material)- An unplanned release of radioactive material, in gaseous and/or liquid state, that causes a valid alarm on radiation monitoring effluent instrumentation and is directly attributable to the event or is a result of intentional venting, to the environment, of structures, systems or components (e.g. Spent Fuel Pool) containing radioactive materici from the event.

VALIDNERIFIED - An indication, report or condition is considered to be VALID when it is conclusively determined by (1) an instrument channel check; (2) indications on related or redundant indicators; or (3) direct observation by plant personnel. Implicit in this definition is the need for timely assessment, i.e. within 15 minutes.

VEHICLE - In the context of these EALs, vehicles include automobiles, trucks, motorcycles, watercraft, aircraft and other similar devices.

VISIBLE DAMAGE - Damage to equipment that is readily observable without measurements, testing, or analysis.

Damage is sufficient enough to cause concern regarding the continued operability or reliability of effected safety structure, system or component. Example damage includes: deformation due to heat or impact, dentirig, penetration, rupture, cracking, blistering paint. Surface blemishes (e.g. paint chipping, scratches) should NOT be included.

l VITAL AREA: Not Applicable in the defueled condition.

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ATTACHMENT A (Sheet 2 of 6) Proc. 2-50-Od EMERGENCY CLASSIFICATION MATRIX Rev.0 Page 6 of 22 VE NI 1.1 - LOSS OF INSTRUMENTATION 1.2'- LOSS OF SPENT FUEL POOL COOLING 2 ASS ALERT NOTAPPLICABLE NOTAPPLICABLE UNUSUAL UNPLANNED loss of All Spent Fuel Pool Inability to maintain Spent Fuel Pool EVENT instrumentation or alarms in the Control Room temperature within specified temperature limits for greater than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (1 AND 2) (1 AND 2 AND 3)

1. UNPLANNED loss of allinstrumentation or 1. An UNPLANNED complete loss of Spent Fuel alarms that provide indication of Spent Fuel or Pool cooling capability.

Spent Fuel Pool status for greater than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

AND AND

2. Inability to restore Spent Fuel Pool cooling within

2. Spent Fuel or Spent Fuel Pool cannot be 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

monitored locally without significant increased risk to station personnel. AND

3. VALID indication of Spent Fuel Pool Temperature greater than 180 F.

ALERT NOTAPPLICABLE Major damage to Irradiated fuel or loss of water level that has or will uncover spent fuel in the Spent Fuel Pool (1 AND 2) ,

1. VALID alarm on Spent Fuel Pool area radiation monitor.

AND 1

2. One of the following conditions exists:(a OR b)

a. Plant personnel report an event that has caused damage to stored spent fuel resulting in ruptured fuel rod (s).

OR

b. Spent Fuel Poolleakage exceeding makeup capacity such that irradiated fuel will be uncovered. .

UNUSUAL UNPLANNED loss of In-plant or Offsite UNPLANNED loss of water level in the Spent EVENT Communications Capability (1 OR 2) Fuel Pool, with fuel remaining covered (1 AND 2 AND 3)

1. UNPLANNED loss of allin-plant communications capabilities (a AND b AND c) 1. VALID " Fuel Pool Level - LO" alarm in the

a. All telephones. Control Room, level is less than or equal to 43'.

b.FEMCO.

c. All radios (portable and base stations). AND OR 2. Plant personnel report a VALID, UNPLANNED water level drop greater than 3 feet below

2. UNPLANNED loss of all offsite normal level (44') in the Spent Fuel Pool (i.e.

communications capabilities (a AND b AND c level is less than 41').

AND d)

a. All telephones. AND

b. All Radios (portable and base stations).

c. All dedicated State hotlines. 3. Fuel remains covered with water, with NO

d. All ENS telephones (NRC Emergency -

VISIBLE DAMAGE.

Notification System).

ATTACHMENT A (Sheet 3 of 6) Proc.2-50-Od EMERGENCY CLASSIFICATION MATRIX Rev. 0 Page 7 of 22 e- - e e -

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a I e ALERT FIRE or EXPLOSION affecting the operability of Natural and Destructive Phenomena Affecting Spent Fuel Pool Cooling systems or the PROTECTED AREA and Spent Fuel Building associated auxiliary systems (1 AND 2) Integrity (1 OR 2 OR 3)

1. VALID indication of a Seismic Event as

1. FIRE or EXPLOSION in any of the areas listed indicated by reports from plant personnel of in Table 2-1 (page 5 of this attachment). ground movement sufficient to cause VISlBLE DAMAGE to the Spent Fuel Building or buildings AND containing SFP support systems.

2. One of the following conditions exists: (a OR b) OR j

a. VISIBLE DAMAGE affecting Spent Fuel i

Pool Cooling components or auxiliary 2. Hurricane, Tornado or sustained High Winds systems listed in Table 2-2 (page 5 of causing significant damage to structures or this attachment) or the Spent Fuel systems listed in Table 2-1 or 2-2 (page 5 of this Pool / Building. attachment) and Control Room indications of degraded Spent Fuel Pool system function or OR component response due to the event.

b. Control Room indications of degraded OR Spent Fuel Pool Cooling components or auxiliary system component response 3. VEHICLE or PROJECTILE crash confirmed to due to the FIRE or EXPLOSION. impact structures or systems listed in Table 2-1 or 2-2 (page 5 of this attachment) and Control Room indications of degraded Spent Fuel Pool system function or component response due to the event.

UNUSUAL FIRE or EXPLOSION within the INDUSTRIAL Natural and Destructive Phenomena Affecting EVENT AREA (1 OR 2) the Site (1 OR 2 OR 3)

1. FIRE reported by plant personnel affecting 1. VALID indication of an earthquake as indicated structures or equipment within the by reports from plant personnel of ground INDUSTRIAL AREA, Fire Pump House, or motion on site. ,

LL Waste and Equipment Storage Building 4 NOT extinguished within 15 minutes of Control OR l Room notification or verification of a Control i Room alarm. 2. VEHICLE or PROJECTILE crash into plant i structures within the INDUSTRIAL AREA which OR may impact Spent Fuel Pool Cooling capabilities.

2. Report by plant personnel of an UNPLANNED or unanticipated EXPLOSION within the OR '

INDUSTRIAL AREA, Fire Pump House, or LL Waste and Equipment Storage Building 3. Hurricane or tornado in close proximity to the resulting in VISIBLE DAMAGE to structures or site as evidenced by: (a OR b OR c) equipment.

a. Notification by CMP Dispatcher of a {

hurricane or tornado which has disrupted i offsite power supplies to the facility or l present hazards to station facilities.

OR )

b. Weather Service verification of hurricane force winds in close proximity to the site AND i sustained wind speeds > 50 mph on site meteorological instrumentation coincident  ;

with an official severe weather warning for '

the site area by the NWS. i OR

c. Station personnel report tornado sighting on or near the site perimeter. l

ATTACHMENTA(Sheet 4 of 6) Proc. 2-50-Od EMERGENCY CLASSIFICATION MATRIX Rev.0 Page 8 of 22

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ALERT UNPLANNED release of TOXIC or FLAMMABLE Security Event inside the Spent Fuel Building or GAS within a plant structure which jeopardizes Control Room (1 OR 2 OR 3) storage of Spent Fuel or Spent Fuel Pool cooling as indicated by:

(1 OR 2)

1. CIVIL DISTURBANCE ongoing in the

1. Report or detection of TOXIC GAS within an INDUSTRIAL AREA.

area necessary for safe spent fuel storage integrity / cooling, in concentrations greater than OR 10% of the immediately dangerous to life and health (IDLH) limit. 2. INDUSTRIAL AREA has been penetrated by a i hostile armed force. f OR l OR I

2. Report or detection of FLAMMABLE GAS in concentrations greater than 25% Lower 3. BOMB discovered within the Spent Fuel Explosive Limit (LEL)in areas necessary for Building or the Control Room.

safe spent fuel storage integrity / cooling.

UNUSUAL UNPLANNED release of TOXIC or FLAMMABLE Confirmed Security Event which indicates a EVENT GAS within the PROTECTED AREA that is potential degradation in the level of security of deemed to be detrimental to safe operation of the facility (1 OR 2)

SFP Cooling systems (1 OR 2 OR 3)

1. SFP Cooling System operation is impeded due 1. BOMB discovered inside the INDUSTRIAL to access restrictions caused by TOXIC GAS AREA.

within a plant structure.

OR

2. Security Alert declared in accordance with the

2. Report or detection of FLAMMABLE GAS Security Plan.

within the PROTECTED AREA (gas concentration in excess of 25% Lower Explosive Limit (LEL)) that can affect SFP cooling operations.

OR

3. Report by Local, County or State Officials for a potential evacuation of site personnel due to an offsite event.

ALERT Other conditions exist which in the judgement of the Shift Manager / Emergency Director indicate facility safety / spent fuel integrity may be degraded or compromised AND that increased monitoring of  !

system functions warrant declaration of an Alert. l UNUSUAL Other conditions exist which in the judgement of EVENT the Shift Manager / Emergency Director indicate facility safety / spent fuel integrity may be degraded or compromised AND that increased monitoring of system functions warrant declaration of an Unusual Event. I

1 f ,

ATTACHMENT A(Sheat 5 of 6) Proc. 2-50-Od EMERGENCY CLASSIFICATION MATRIX O g

1 TABLE STRUCTURES ASSOCIATED WITH HAZARDS, SECURITY AND

! 2-1 ED JUDGEMENT EALs Fuel Building Control Room

Primary Aux Building l Turbine Hall l Fire Pump House TABLE SYSTEMS ASSOCIATED WITH HAZARDS, SECURITY AND ED l 2-2 JUDGEMENT EALs SFP Cooling and Auxiliaries PVS or SFP Rad Monitoring System Fire Detection or Suppression l

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ATTACHMENT A(Sheet 6 of 6) Proc.2-50-Od EMERGENCY CLASSIFICATION MATRIX Rev.O i Page 10 of 22 WEE  :... .. . . .. ,, , .

ALERT UNPLANNED increases in radiation levels Any UNPLANNED release of gaseous or liquid within the facility that impedes safe operations radioactivity that exceeds 200 times the ODCM or spent fuel monitoring capabilities (1 OR 2) limit for >15 minutes (1 OR 2 OR 3 OR 4)

1. VALID general area survey results in the Control 1. VALID RHS indication that exceeds the values listed Room or Security areas that require 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing under ALERT in Table 3-1 for greater than that exceed 15 mR/hr. 15 minutes, unless dose assessment within this time period confirms that the 200 times ODCM limit OR criterion HAS NOT been exceeded.

2. Access restrictions impede operation of systems OR necessary for maintaining spent fuelintegrity as indicated by a VALID reading of greater than 1 R/hr 2. Confirmed sample results exceed 200 times,the S ent Fuel Pool area radiation monitor fa i ci for gre t hanbntIte u ion.

OR (Items 3 and 4 are for GASEOUS releases only)

3. Confirmed field survey results indicate >10 mR/hr (whole body) at 0.5 mile for greater than 15 minutes.

OR

4. Dose projection results indicate 0.5 mile dose

>10 mR Equivalent Whole Body Dose for the duration of the release.

UNUSUAL UNPLANNED event increases radiation levels Any UNPLANNED release of gaseous or liquid EVENT within the plant radioactivity that exceeds 2 times the ODCM limit for >60 minutes (1 OR 2 OR 3 OR 4)

1. VALID area radiation monitor readings increase by 1. VALID RMS indication that exceeds the values listed a factor of 1000 over normal levels (nonnal levels under UNUSUAL EVENT in Table 3-1 for greater can be considered as the average reading in the than 60 minutes, unless dose assessment within this past 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, as read on the Control Room log or time period confirms that the 2 times ODCM limit historical computer data, excluding the current peak critenon HAS NOT been exceeded, value).

OR

2. Confirmed sample results exceed 2 times the ODCM limit for a release of gaseous or liquid radioactivity for greater than 60 minutes duration.

OR (Items 3 and 4 are for GASEOUS releases only)

3. Confirmed field survey results indicate >0.1 mR/hr (whole body) at 0.5 mile for greater than 60 minutes.

OR

4. Dose projection results indicate 0.5 mile dose

>0.1 mR Equivalent Whole Body Dose for the duration of the release.

TABLE 3-1 EFFLUENT MONITOR EALS NOTE: The values listed below, if exceeded, indicate the need to perform the specified assessment if the assessment can not be completed within 15 minutes, the declaration shall be made based on the VALID reading.

MONITOR UNITS UNUSUAL EVENT VALUE ALERT VALUE PVS High Range (RM-3903) m R/hr N/A 10 PVS Gas (RM-3902Y) CPM 400,000 Off Scale - High Liquid Waste (RM-3801) CPM Off Scale - High N/A