ML20217P319

Rev 7 to Ccnpp Emergency Action Levels Technical Basis Document

ML20217P319
Person / Time
Site:	Calvert Cliffs
Issue date:	01/28/1998
From:	Grooms J, Huber J, Rudigier G BALTIMORE GAS & ELECTRIC CO.
To:
Shared Package
ML20217P312	List: ML20217P308 ML20217P319
References
NUDOCS 9805060233
Download: ML20217P319 (181)

Text

ENCLOSURE I

CALVERT CLIFFS NUCLEAR POWER PLANT EMERGENCY ACTION LEVELS TECHNICAL BASIS DOCUMENT REVISION 7

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F PM Baltimore Gas and Electric Company Docket Nos. 50-317 and 50-318 Independent Spent Fuel Storage Facility Docket No.72-8 April 29,1998

CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 & 2 EMERGENCY ACTION LEVELS TECHNICAL BASIS DOCUMENT I

REVISION 7 l PREPARED: m/

Y~ DATE:

/2)/7/77 Eniergency Planning - G'C. Rudigier i k DATE: /E!ZB[9 7 P1 Operations - J. V. Grooms REVIEWED:

Operatio ' raining - J. T. Huber e DATE: /J[/f/97 U DATE: 7 ChcIktfiytedhnical s - C4 K. Barley /

REVIEWED:

OL00ALI N I DA'IE: N N O Radiatiort Safety E. H. Roach REVIEWED: . /

N b 4.0 DATE: /7 [11/97 Dpsi ngi ring-Mechanical- C. J. Ludlow REVIEWED:

N/ DATE: /2/b4/ h Desth rin lectrical - J. C. Kilpatrick / /

REVIEWED: -

<:. .' -- 4 DATE: /Z 29l97 clear Enginee ' g . A. ry REVIEWED: 1 I V

~

Security - D. M. Dean W DATE: 'f f7

/ k. DATE: I2_ -/2 4 )N Ya '

l APPROVED:

d DATE: // 2/ N DirectorI8mer'geix@ Planning Unit - T. E. Forgette j SRC IM 98-0/2 Meeting No.

DATE: [*c2b fb I

DATE: / Af 17 Pla neral Manager

/ /

l Effective Datr with ERPIP 3.0, Redsion

. Change Calven Cliffs EAL Basis Document Rev.7

TABLE OF CONTENTS ADMINISTRATIVE CONTROL OF THE EAL TECHNICAL BASIS ........................................ .... A:1 GENERAL NOTES FOR EAL TECHNI CAL B ASIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .G:1 .........

RADIOACTIVITY RELEASE 1

RUI Unplanned Radioactive Release Exceeding 2 X Tech Spec Limits for AT LEAST 60 Minutes . R:1 '

RU2 Unexpected Increase in Plant Radiation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . R:5 RU3 Potential Degradation of Containment of Dry Stored Spent Fuel .................................... R:7 RAI Unplanned Radioactive Release Exceeding 200 X Tech Spec Limits for AT LEAST15 min. R:9 -

RA2 Damage OR Uncovery of Single Irradiated Fuel Assembly Outside the Reactor Vessel ......... R:13 RA3 Radiation Increases That Impede Safe Plant Operation ............................................. R:15

{

RS1 Off Site Dose of AT LEAST 0.1 Rem (EDE + CEDE) Or 0.5 Rem CDE Thyroid ............... R:18 1 RG1 Off-Site Dose of AT LEAST 1 Rem (EDE + CEDE) Or 5 Rem CDE Thyroid .................. R:22 FISSION PRODUCT BARRIER DEGRADATION BU I Loss OR Potential Loss of CNTMT Barrier . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:1 BU2RCSLeakage................................................................................................ B:2 BU3 Fuel Clad Degradation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:6 BA1 Loss OR Potential Loss of EITHER Fuel Clad Barrier OR RCS Barrier ............ ... ........ B:9 BS ! Loss Or Potential Loss of ANY Two Barriers ... . . . . . . ... ..... .. . . . . .. .. . . . . . . . . . . . . .... . . ... .. ... . . B:10 BGl Loss of Two Barriers AND Potential Loss of Third Barrier ............... ....................... .. B:13 FUEL CLAD B ARRIER EALs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:14 FCB1 Safety Function Status / Functional Recovery ........................................... .... B:15 FCB 2 Tem perature . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:17 l

FCB 3 Radiati o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:18 ............

FCB4 Reactor Vessel Water Level . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:20 FCB S S EC J udgement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:21 R C S B ARRIER E ALs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:22 .................

RCB I Safety Function Status / Functional Recovery. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:23 RCB 2 Te mperature . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:25 RCB 3 Radiation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:27 RCB4 Coolant Leakage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:28 RCB S S EC J udgeme nt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:35 CONTAINMENT B ARRIER EALs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B :3 6 CNB l Safety Function Status / Functional Recovery. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B: 37 CNB 2 Tem pe rature . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:38 CNB 3 Radiation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:

CNB4 Coolant Leakage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B:42 CNB 5 Pressure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B : 4 4 CNB6 SEC Judgement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B : 46 EQUIPMENT FAILURE QUI Unplanned Loss of Any Function Needed to Maintain Cold Shutdown ........................... Q:1 QU2 Unplanned Loss of Most or All Safety System Annunciators for GREATER THAN 15 Minutes....................................................................................................... Q:3 QU3 Unplanned Loss of All On-Site or Off Site Communications Capabilities ........................ Q:S QU4 Inability to Reach Required MODE Within Technical Specification Limits............ ... Q:7 QU5 Secondary Depressurization.. . . . . . . . . . ............ .... .. Q:8 Q A l Failure of Automatic Reactor Trip . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Q:10 Q A2 Inability to Maintain Plant in Cold S hutdown . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Q:12 QA3 Unplanned Loss of Safety System Annunciators With Transient In Progress ............ ........ Q:14 Q A4 Station Blackout While Defueled . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Q:1 QS1 Failure of BOTH Automatic AND Manual Reactor Trip . .................... ...................... Q:17 QS2 Complete Loss of Function Needed to Achieve or Maintain Hot Shutdown ..... ..... ............ Q:18

/

Calvert Cliffs EAL Basis Document i Rev.7

i TABLE OF CONTENTS EQUIPMENT FAILURE (Cont'd)

QS3 Loss of Water Level That Can Uncover Fuel in the Reactor Vessel ................ ......... ...... Q:20 j QG1 Failure of BOTH Automatic AND Manual Reactor Trip -AND- Extreme Challenge i to the Ability to Cool the Core . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Q:22 ELECTRICAL EU 1 Loss of Off S ite Power . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E:!

EU2 Loss of Vital 125 Volt DC Power for GREATER THAN 15 Minutes ............... .............. E:3 EA 1 Station Blackout While On S hutdown Cooling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E:7 EA2 Only One AC Power ::ource Available to Supply 4 kV Emergency Buses ........................ E:8 EA3 Loss of 125 Volt DC Power AND Reactor Trip ... .. .. ... .... . .. . ..... ...... .. . . .. . . . ... . . . . .... . .... E:10 ES I S tation B lackou t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E:11 ES2 Loss of All 12 5 Volt DC B uses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E:12 ,

EG I Prolonged Station Blackout . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E:14 l

SECURITY TUI Confirmed Security Event With Potential Degradation in the Level of Safety of the Plant ................ ......................................................................... T:1 TA l Security Event in the Plant Prot ected Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . T:3 TS I Security Event in a Plant Vital Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . T:4

)

TG1 Security Event Resulting in Loss of Ability to Reach AND Maintain Cold Shutdown ......... T:6 l FIRE IUl Fire Within Protected Area Boundary "ot Extinguished Within 15 Minutes of Detection ...... 1:1 I A I Fire or Explosion Affecting Safe S hutdown . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1:3 NATURAL PHENOMENA NU 1 Natural Phenomena . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . N:1 NA l Natural Phenomena Affecting Safe S hutdown . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . N:5 OTHER HAZARDS O U 1 S E C Judgement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . O:1 OU2 Toxic or Flammable Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...... . O:3 OU3 Destructive Phenomena . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . O:4 O A l S E C J ud gement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . O:10 OA2 Toxic or Flammable Gases Affecting Safe Shutdown ............. ...... ........................... O:11 OA3 Destructive Phenomena Affecting Safe S hutdown . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . O:13 OA4 Control Room Being Evacuat ed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . O:17 O S I S E C J ud ge me n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . O:18 OS2 Control Room Has Been Evacuated AND Timely Plant Control Can NOT Be Established ...... O:19  !

OG 1 S E C J udge ment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . O:21 j l

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Calvert Cliffs EAL Basis Document ii Rev.7

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TABLE OF CONTENTS l

l TABLES l l

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l Table G-1: Comparison of NUMARC Guidelines to BGE ICs NUMARC Abnormal Radiation Levels / Radiological Effluent Category ......................... ....... G:7 Table G-2: Comparison of NUMARC Guidelines to BGE ICs NUMARC Hazards and Other Conditions Affecting Plant Safety Category .. ...... .................... G:8 l Table G-3: Comparison of NUMARC Guidelines to BGE ICs l

NUMARC System Malfunction Category . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . G:9 Table G-4: Comparison of NUMARC Guidelines to BGE ICs NUMARC Fission Product Barrier Degradation Category ............................ ................... G:10 Table G 5: Comparison of NUMARC Guidelines to BGE EALs NUMARC Fission Product Barrier Degradation Category .................. ............................. G:11 Table B.1: SAE Barrier Loss / Potential Loss Combinations for CCNPP Logic .................... ... B:11 Table B-2: SAE Barrier Loss / Potential Loss Combinations for NUMARC Logic ..................... B:12 Table E-1: Effects of Lost 125 Volt DC Buses 1 1, 21, 12 and 2 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E:5 l Calvert Cliffs EAL Basis Document iii Rev.7

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ADMINISTRATIVE CONTROL OF THE EAL TECHNICAL BASIS

1. PURPOSE The purpose of this part is to delineate the administrative controls for revising the EAL Technical Basis.

II. DOCUMENT FORMAT The Emergency Action Level (EAL) Technical Basis document format (outline, topics, page numbering, etc.) is established with revision 0. Revisions to the document will be consistent with this format unless authorized by the Director-Emergency Planning. Authorized format changes will be recogmzed by the Director's approval of the revision that implements the format alteration.

III. COMMITMENT TRACKING The EAL Technical Basis document is the commitment tracking mechanism for ERPIP 3.0, ,

Immediate Actions, Attachment 1, Emergency Action Levels. Everything in the Basis constitutes a commitment therefore it is not necessary to highlight or otherwise annotate commitments.

IV. REVISION _S l

A. Preparation

1. Anyone may submit a revision proposal for the Technical Basis. Proposals may be submitted in any form to any member of Emergency Planning, attention: Director- )

Emergency Planning. I

2. Rejected revision proposals will be returned to the originator with an explanation for the rejection.

3. Accepted revision proposals will be prepared as a revision for processing. I

a. The revision will be assigned the next sequential revision number. A record will be kept of revisionsin process.

b. Margin indication will be used to identify sections that are affected by the i revision.

c. New wording introduced by a technical revision will be printed in bold to facilitate review. Deleted words will be struck through. Bolding and strike through are not required for administrative resisions.

B. Processing

1. Administrative revision.

a. Revisions processed to implement administrative changes (reference and/or typographical corrections, wording corrections, etc.) shall be reviewed by Emergency Planning. The revision will be annotated as an administrative revision. No other reviews are required. Administrative revisions shall not change the intent of the Basis AND shall not cause a wording difference with ERPIP 3.0, Attachment 1.

Calvert C*iffs EAL Basis Document A:1 Rev.7

f ADMINISTRATIVE CONTROL OF THE EAL TECHNICAL BASIS IV.B. I .b. Administrative revisions shall be approved by the Director-Emergency Planning.

c. Administrative revisions approved by the Director-Emergency Planning will be i

l distributed in accordance with PR-2-100, Document and Drawing Control.

l 2. Technical resision.

l

a. Technical rnisions shall be reviewed by:

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

b. The Emergency Planning reviewer will collect and reconcile resiew comments.

Reviews will be documented on the Basis review / approval sheet.

c. Technical revisions shall be approved by the Director Emergency Planning.

The Director will consider resiew comments and their reconciliation.

d. Technical rnisions shall be submitted to POSRC and the Plant General Manager in accordance with NS-2-101, Conduct of the Plant Operations and Safety Review Committec/ Procedure Review Committee / Qualified Reviewer.

e. Technical revisions approved by the Plant General Manager shall be submitted to the NRC for information in accordance with CCI-154, Preparation of NRC Correspondence. This submittal shall specify that a resision to ERPIP 3.0, Attachment 1, Emergency Action Levels, to implement the Basis document change, will be processed in forty-five (45) days.

f. After action IV.B.2.e. is complete (i.e., the correspondence is mailed) then a revision to ERPIP 3.0, Immediate Actions, Attachment 1, Emergency Action Levels may be initiated in accordance with ERPIP 900, Preparation of Emergency Response Plan and Emergency Response Plan Implementation Procedures. The effective date of the ERPIP 3.0 revision may nct precede the forty-five (45) days afforded to the NRC.

g. When the ERPIP 3.0 revision is approved by the Plant General Manager then:

(1) The bold print and strike throughs associated with the resision in the Basis document shall be removed.

(2) An effective date will be assigned the Basis document. This date shall coincide with the effectiveness date of the respective 3.0 resision.

(3) The Basis revision will be distributed in accordance with PR-2-100, l Document and Drawing Control.

Calvert Cliffs EAL Basis Document A:2 Rev.7

ADMINISTRATIVE CONTROL OF THE EAL TECHNICAL BASIS V. RECORDS A. Basis document rnisions will be retained in accordance with ERPIP 902, Records, for six years after issue of the next resision.

B. There are no retention requirements for resision tracking documentation.

VI. IMPLEMEffrATION This section, Administrative Control of the EAL Technical Basis, may be implemented as an administrative revision to the Basis document. It shall be effective with Basis resision 1.

Calvert Cliffs EAL Basis Document A:3 Rev.7

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GENERAL NOTES FOR EAL TECHNICAL BASIS Calvert Cliffs EAL Basis Document Rev.7

GENERAL NOTES FOR EAL TECHNICAL TASIS GENERAL NOTES FOR EAL TECHNICAL BASIS The following general notes apply to the Calvert Cliffs EAL Technical Basis information:

1. The format of the EAL Technical Basis information was developed to address training needs, to facilitate NRC approval, and to facilitate future resisions and 10 CFR 50.54(q) evaluations.

2. NUMARC generic information is quoted directly from NUMARC/NESP-007, Revision 2, dated January 1992. Changes from the NUMARC text are denoted by caret marks (< >). Such changes are based on the following criteria:

To put the NUMARC generic information in its proper context such as when it refers to a section of the NUMARC document.

To rename Initiating Conditions (ICs) from their NUMARC designation to the corresponding Calvert Cliffs designation.

To delete information that does wt apply suc h as reference to BWR information.

3. The EAL Technical Basis information is organized by Event Category which is shown by the Title on each page:

Badioactivity Releases (R)

Fission Product Barrier Degradation (B)

SecuriIy (T)

Equipment Failure (Q)

Fire (1)

Natural Phenomena (N)

Electrical (E)

Qther Hazards (O)

Calvert Cliffs designations use two letters followed by one number. The identifier numbers were selected so that they would not overlap with NUMARCIC designators and thereby cause confusion. The first letter corresponds to the event category as shown above. The second letter corresponds to the emergency classification level for the IC:

'O -(Notification of) Unusual Event A - Alert S - Site Emergency G -General Emergency The number designates whether the IC is the first, second, third, etc., IC for that event category under that emergency classification. For example, BU2 is the identifier number for the second Fission Product Barrier Degradation category IC in the Unusual Event classification, EGI is the first Electrical category IC in the General Emergency classification, etc.

Similarly, Calvert Cliffs Fission Barrier EALs also use different designators than NUMARC. They are:

FCB -Euct Clad Barrier RCB -R_CS Barrier CNB -Containment Barrier Calvert Cliffs EAL Basis Document G:1 Rev.7

GENERAL NOTES FOR EAL TECHNICAL BASIS j

4. Calvert Cliffs Operational Modes are referred to by the corresponding Improved Technical Specification ,

Table 1.1-1 numbers. These are:  !

Mode 1 - Power Operation Mode 4 - Hot Shutdown Mode 2 - Startup Mode 5 - Cold Shutdowti I Mode 3 - Hot Standby Mode 6 - Refueling Please refer to the Tech Spec table for the corresponding temperature, pressure, and reactivity parameters for each of these operational modes Operational modes applying to ICs'EALs are based on the i operational mode that the plant was'in immediately before the event sequence leading to entry into the emergency classification.

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For example, events / conditions addressed by ICs applicable to Mode 1 (Power Operation) are expected to lead to reactor trip which should bring the plant to Mode 3 (Hot Standby). However, the appropriate I emergency classification would still be based on the applicable ICs for Mode 1 operation for these events / conditions.

5. The " Plant Specific Basis" section for each IC/EAL provides the description of how NUMARC generic information was applied to develop Calvert Cliffs EALs. Supporting procedures, calculations, their underlying bases and assumptions, and their results are fully described in the Plant-Specific Basis" section, as appropriate.

6. Frequently used terms are defined below:

AC- Alternating Current 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.

All- Applies to Operational Modes 1 through 6 (listed above) plus defueled mode.

ATLEAST- Greater than or equal to ATHS- Anticipated Transient Without Scram Barrier - Same as Fission Product Barrier below.

BarrierMonitoring Ability - This must be considered as an SEC judgement factor in determining whether a fission product barrier is lost or potentially lost. Decreased ability to monitor a barrier results from a loss of/ lack of reliable indicators, including inst.umentation operability concerns, readings from portable instrumentation, and consideration for offsite monitoring results.

Can NOT - The final safety function status is of concern, not merely the inability to meet certain intermediate status check conditions.

CDE - Committed Dose Equivalent as defined in 10 CFR 20.1003 CEA -Control Element Assembly CEDE - Committed Effective Dose Equivalent as defined in 10 CFR 20.1003 CEDM- Control Element Drive Mechanism Calvert Cliffs EAL Basis Document G:2 Rev.7

GENERAL NOTES FOR EAL TECHNICAL CASIS CET-Core Exit Thermocouple CFM-Cubic Feet per Minute CNTMT- Containment .

Compensatory non-alarming indications - Includes computer based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits.

CPM- Counts Per Minute

- CSFST- Critical Safety Function Status Tree CST- Condensate Storage Tank DAC-Derived Air Concentration DC- Direct Current Dominant accident seguences - These will lead to degradation of all fission product barriers. They include ATWS and Station Blackout sequences that are separately addressed under the Equipment Failure and Electrical categories, respectively, as well as by the Fission Product Barrier Degradation EAL Tables.

ECCS-Emergency Core Cooling System EDE- Effectisc Dose Equivalent as defined in 10 CFR 20.1003 Emergency Action Levels (EAI) - A pre-determined, site-specific, obsenable threshold for a plant Initiating Condition that places the plant in a given Emergency Class. An EAL can be: an instrument reading, an equipment status indicator, a measurable parameter (on-site or off-site), a discrete obsemible event, results of analyses, entry into specific emergency operating procedures, or another phenomenon which, if it occurs, indicates entry into a particular Emergency Class.

Emergency Classification Level - These are taken from 10 CFR 50, Appendix E. They are, in escalating order: (Notification of) Unusual Event (UE), Alert, Site Emergency, and General Emergency (GE).

Fission Product Barrier - One of the three principal barriers to uncontrolled release of radionuclides: Fuel Clad, Reactor Coolant System (RCS), and the Contamment building (CNTMT)

FOST-Fuel Oil Storage Tank Fuel Clad- The zirconium alloy tubes that contain the fuel pellets.

General Emergency (GE) - Events are in process or have occurred which involve actual or imminent substantial core degradatson or melting with potential for loss of containment integrity. Releases can reasonably be expected to exceed EPA Protective Action Guide (PAG) exposure levels off-site for more

' than the imFWimte site area.

GPM-Gallons PerMinute Inadvertent - Accidental or unintentional, e.g., the event occurred because procedures were not strictly adhered to.

Calvert Cliffs EAL Basis Document G:3 Rev, 7

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i GENERAL NOTES FOR EAL TECHNICAL EASIS

- Imminent - Refers to anticipated degradation of any fission product barrier within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> based on a projection of current safety system performance Implementation / implement - conscious use of a procedure with the intention of executing the steps or action there-in.

In service - A component or system in the appropriate configuration for normal operation and is considered " operable" as defined in the Calvert Cliffs Improved Technical Specifications Section 1.1.

. Initiating Condition (IC) - One of a predetermined subset of nuclear power plant conditions where either f

the potential exists for a radiological emergency or such an emergency has occurred l KV(k0 - Kilovolts, i.e., thousand volts LOCA -Loss of Coolant Accident Loss (of a fission product barrier) - A severe challenge to a fission product barrier exists such that the banier is considered incapable of performing its safety function.

Afillirem - One thousandth of a rem AIPH-Miles Per Hour

- NOT E.gective - Corrective actions do not yield appropriate or satisfactory results based on available operable instrumentation readings.' '

1 Notification of Unusual Event (NOUE) - Same as Unusual Event below. 1 Planned - Loss of a component or system due to expected events such as scheduled maintenance and testing actisities.

Potential Loss (of a fission product barrier) A challenge to a fission product barrier exists such that the barrier is considered degraded in its ability to perform its safety function.

PSIG-Pounds per Square Inch Gauge PTS-Pressurized Thermal Shock PWST-Pretreated Water Storage Tank PZR - Pressunzer RCS- Reactor Coolant System RCP - Reactor Coolant Pump Rem - Unit of radiation dose as defined in 10 CFR 20.1004 Required - Entry into a given procedure is neither optional nor merely suggested; rather, it is imperative based on existing conditions.

RFP-Refueling Pool Cal ert Cliffs EAL Basis Document G:4 Rev.7

GENERAL NOTES FOR EAL TECHNICAL EASIS RTP-Rated Thermal Power RVLMS - Reactor Vessel Level Monitoring System RHT-Refueling Water Tank SDC- Shutdown Cooling SDCS- Shutdown Cooling System SEC-Site Emergency Coordinator SG - Steam Generator Sievert (Sv) - Unit of radiation dose equivalent to 100 rem Significant trans/ent - (See also, " Transient", below.) Includes response to automatic or manually initiated functions such as scrams, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10% or greater.

S/T - Safety injection Tank Site Area Emergency (SAE) - Events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guide (PAG) exposure levels except near the site boundary Site Emergency - Same as Site Area Emergency above.

TEDE - Total Effective Dose Equivalent as defined in 10 CFR 20.1003 Transient - A condition that is:

Beyond the expected steady state fluctuations in temperature, pressure, power level, or water level, and Beyond the normal manipulations of the Control Room operating crew, and Expected to require actuation of fast-acting automatic control or protection systems to bring the reactor to a new safe, steady-state condition.

Uncontrolled means that given condition is not the result of planned actions by the plant staff.

Unisolable means that actions taken from the Main Control Board or locally are not successful in eliminating the leakage path.

Unplanned is used to preclude the declaration of an emergency where a component or system has been removed intentionally from service (e.g., for maintenance and/or testing activities). As used in the context of rad releases, " unplanned" includes any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.

UnusualEvent (UE) - Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring off-site response or monitoring

! are expected unless further degradation of safety systems occurs Calvert Cliffs EAL Basis Document G:5 Rev.7

GENERAL NSTES FOR EAL TECHNICAL BASIS Valid means that the indication is from instrumentation determined to be operable in accordance with the Technical Specifications or has been verified by other independent methods such as indications displayed on the control panels, reports from plant personnel, or radiological suncy results.

HRNGM- Wide Range Noble Gas Monitor e

Calvert Cliffs EAL Basis Document G:6 Rev.7

GENERAL NOTES FOR EAL TECHNICAL BASIS Table G-1: Comparison of NUMARC Guidelines to BG&E ICs NUMARC Abnormal Radiation Levels / Radiological Effluent Category Emergency Class Generic NUMARC IC Calvert Cliffs IC Unusual Event AUI Any Unplanned Release of Osacous or Uquid RUI - Unplanned Radioactive Release Exceedmg 2 X Radioactivity to the Environment nat Exceeds Two Tech Spec Umits for AT LEAST 60 Minutes Times the Radiological Tedmical Specifications for 60 Minutes or imaer AU2 - Unexpected increase in Plant Radiation <> RU2 - Unexpected increase in Plant Radiation RU3 - Potential Degradation of Contamment of Dry Stored Spent Fuel Alert AAI Any Unplanned Release of Oaseous or Liquid RAI - Unplanned Radioactive Release Exceeding 200 Radioactivity to the Environment hat Exceeds 200 X Tech Spec Unuts for AT LEAST 15 Minutes Times Radiological Technical Specifications for 15 Minutes or Imger AA2 - Major Damage to Inadiated Fuct or Loss of RA2 Damage OR Urx:overy of Single Irradiated Water level That Has or Will Result in the Fuel Assembly Outside the Reactor Vessel Uncovering ofIrradiated Fuel Outside the Reactor Vessel AA3 - Release of Radicactive Material or increases RA3 Radiation increases hat Impede Safe Plant  ;

in Radiation levels Within the Facility Rat Impedes Operation i Operation of Systems Required to Maintain Safe  !

Operations or to Establish or Maintain Cold Shutdown Site Emergency ASI Boundary Dose Resulting From an Actual or RS! Off-Site Dose of AT LEAST 0.1 Rem (EDE +

Immment Release of Oaseous Radioactivity Exceeds CEDE)Or 0.5 Rem CDE Thyroid 100 mR Whole Body or $00 mR Child Byroid for the Actual or Projected Duration of the Release General Emergency A01 Boundary Dose Resulting From an Actual or ROI - Off-Sne Dose of AT LEAST 1 Rem (EDE Inuninent Release of Oaseous Radioactivity Exceeds + CEDE) Or 5 Rem (CDE)Dyroid 1000 mR Whole Body or $000 mR Child Dyroid for the Actual or Projected Duration of the Release ,

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l Calvert Cliffs EAL Basis Document G:7 Rev.7

GENERAL NOTES FOR EAL TECHNICAL CASIS Table 0-2: Cornparison of NUMARC Ouidelines to BO&E ICs NUMARC Hazards and Other Conditions Affecting Plant Safety Category Emergency Class Generic NUMARC IC Cahut Cliffs IC Unusual Event HUI Natural and Destructive Phenomena Affecting OU3 Destructive Phenornena the Protected Area NU1. Natural Phenomena HU2 Fire Within Protected Area Boundary Not IUI Fire Within Protected Area Boundary Not Extinguished Within 15 Minutes of Detection Extinguished Within I $ Minutes of Detection HU3 Release of Toxic or Hammable Gases Deemed OU2. Toxic or Hammable Oases Detnmental to Safe Operation of the Plant HU4 - Confirmed Security Event Which Indicates a TUI . Confirmed Secunty Event With Potential Potential Degradation in the level of Safety of the Degradation in the level of Safety of the Plant Plant HUS Other Conditions Existing Which in the OU1.SEC Judgement Judgement of the Emergency Director Warrant Declaration of an Unusual Event Alert HAl . Natural and Destructive Phenomena Affecting OA3 - Destructive Phenomena Affecting Safe the Plant Vital Area Shutdown NAl - Natural Phenomena Affecting Safe Shutdown HA2 - Fire or Explosion Affecting the Operability of IAl Fire or Explosion Affecting Safe Shutdown Plant Safety Systems Required to Estabhsh or Maintain Safe Shutdown HA3 Release ofToxic or Flammable Oases Within OA2 Toxic or Flammable Oases Affecting Safe a Facility Structure Which Jeopardizes Operation of Shutdown Sptems Required io Establish or Maintain Cold Shutdown HA4 Security Event in a Plant Protected Area TAI - Security Event in the Plant Protected Area HAS - Control Room Evacuation Has Been Initiated OA4 - Control Room Deing Evacuated HA6 Other Conditions Existing Which in the OAl SECJudgement Judgement of the Emergency Director Warrant Declaration of an Alert Site Emergency HSI - Security Event in Plant Vital Area TSI . Security Event in a Plant Vital Area H52. Control Room Evacuation llas Been initiated OS2 - Control Room Has Been Evacuated and and Plant Control cannot be Established Timely Plant Control Can NOT Be Established HS3 Other Conditions Existing Which in the OSI SEC Judgement Judgement of the Emergency Director Warrant Declaration of a Site <E>mergency General Emergency HO! . Secunty Event Resulting in Ims of Ability to TOl . Security Event Resulting in Less of Ability to Reach and Maintain Cold Shutdown Reach AND Maintain Cold Shutdown HO2. Other Conditions Existing Which in the 001 SEC Judgement Judgement of the Emergency Director Warrant Declaration of a General Fanergency Calvert Cliffs EAL Basis Document G:8 Rev.7

l GENERAL NOTES FOR EAL TECHNICAL 2 ASIS l.

I Table 0-3: C , a. fNUMARCOuidelmastoBO&EICs NUMARC System Muhafhactson Category i- Emergency Class Generic NUMARCIC Calvert Cliffs IC l

Unusual Event SUI less of All Otrane Power tow -nalBusses EUI 1 mas of OII-Sale Power for Greener h 15 Meuses SU2 Insinhty to Reach Required Shutdown Wilhe QU4 lasinhty to Readi Requesd MODE Wribun Teduucal "_ limits Tanh-at ".

- limits l -

SU3 Unplanned 1 Ass of All Safety Symani QU2 Unplanned Imss of Most or All Safety System Am==c==s-s for Orester Then 15 Mbules Amma= viators for OREATER 111AN 15 Minutes SU4 FuelClad P _ ' BU3 FuelClad W ^-

SUS RCSlankane BU2 RCS tmakaq, SU6 Unplanned Imas of All Onsne or Offene QU3 Unpla===d imes of All OthSne or Off-Sne ca=== unum-. Capabilities Connnumcabans %wii iias SU7 Umpl===ad imes of Required DC Power EU2 1 Ass of Vital 125 Vok DC Powc for During Cold Shuklown or Refueling Mode for OREATEklilAN 15 Maules Ornelarlhan 15 Minutes Shutdown EAL not currently addressed by QUI Unplanned imes of Any Function Needed to NUMARC Maintain Cold Shukiown Alert SAI Loss of All Offene Power and less of All EAl Stataan Blackout Wlule on Shutdown Coolmg Onsise AC Power During Cold Shutdown or QA4 Station Blackout %hile Defueled Refhelina Mode SA2 Fadure of Reactor Protechen System QAl- Failure of Automahc Renaer Tnp Instrumentation to Complete or Initiate an Automatac Reactor Scram Once a Reactor Protection System -

Setpost Has Been Exceeded and Manual Scram Was Successful SA3 Inabsiny to Maintaan Plant in CoM Shukiown QA2 Inabdrty to Manua=i Plant in Cold yhutdoI SA4 - Unplanned less of Most or All Safety System QA3 Unplanned less of Sa'ety System Annunciahon or Indicehon in Coctrol Room With Annunciators With Transient in Propees Either (1) a Signficant Transsent in Proyees or (2)

Compensatory Non-Alarnung Indicators are ,

Unavailable SAS AC Power Capabihty to Eassenaal Busses EA2 Only One AC Power Source Available to Reduce >d to a Single Poww Source for Oronter Ti an Supply 4kV Emergency Buses 15 Minutes such 1 hat Any Addrhanal Single Failure would Resuk in Station Blackout Site Emergency SSI less of All Olhite Poww and Loss d All Est Station Blackout Onsite AC Pownrto Essenhal Busses SS2 Fadure ofReactor Protechen Symarn QS1 FailureofBOTH Automatic ANDManual  ;

Instrumsemahan to Complete or Initiate an Automatic Reactor Trip '

Reestor scram Once a Reactor Protection System Seepond Has Been Exceeded and Manual Scram was

_N_O r Succesrui SS3 1 Ass of All Vaal DC Power EA3 -less of 125 Vok DC Power and Reactor Tnp ES2 IAss of All 125 Volt DC Buses Site Ernergeracy SS4 Complete 1 mas of Function Nuded to Adueve QS2 CompleteImasofFunctionNeededto Achieve or Massain Hot Shutdown ' or Maintain Hot Shutdown (Continued)

SS5 Imss of Water levellhet Has or Will Uncover QS3 less of Watw Level That Can Uncover Fuel in Fuelin tN Reactor Vessel tbs Reactor Vessel SS6 Inabiiny to Monitor a Sigsficant Transient in ES2 Loss of All 125 Volt DC Buses Prosess General Ernergency Sol ProlongedimesofAllOff-SnePowerand EOI Prolonged Stahon Bladout Prolonasd Imus of All On4ies AC Power 502 Fadure of the Reader Proteason System and QOl Failurt of BOTH Automatic AND Manual Manual Scram was NOT Sucosasful and 1here is Reader Trip -AND Extreme Challenge to the Ability t=A.*=a of an Extreme Challenge to the Ability to to Coolthe Core Cool the Core l

CalVeft Cliss EAL Basis Document G:9 Re t. 7

GENERAL NSTES FOR EAL TECHNICAL BASIS l

Table 04: Compenson of NUMARC Ouidelines to BGAE ICs NUMARC Fission Product Barrier Degradation Category Emergency Class Generic NUMARC IC Calvert Cliffs IC Unusual P.wnt FUI ANY less or ANY Potentialloss of BU1 -less OR Potential Imss of CNTMT Barrier e,  :

Alert FAI ANY loss or ANY Potentialless of EITHER DA I less OR Potential lons of EITHER Fuel Clad Fuel Clad OR RCS Barrier OR RCS Barrier Site Emergency FSI loss of BOUI Fuel Clad AND RCS BSI Less of Potential Loss of ANY Two Barriers OR Potential less of BOTH Fuel Clad AND RCS OR Potential Loss of EITHER Fuel Clad OR RCS and Imes of ANY Additional Barrier General Emergency FOI -less of ANY Two Barriers BGl Ims ofTwo Barriers AND Potentialloss of AND Third Barrier Potentialloss ofnird Barrier k

Calvert Cliffs EAL Basis Document G:10 Rev.7

{

l GENERAL NOTES FCR EAL TECHNICAL CASLS i

Table 0-5: Corn urison of NUMARC Ouidelines to BG&E EAla NUMARC F.rion Product Barrier Dearadation Categorv EALs Generic NUMARC EAL Cahert Cliffs EAL Fuel Clad Barrier Fuel Clad 1 Critical Safety Function Status FCBI . Safety Function Status 7unctional Recovery Fuel Clad 2 Pnmary Coolant Activity level FCB3 Radiation l Fuel Clad 3 Core Exit Thennoccuple Readings FCBI - Safety Function Statua,7unctional Recovery FCB2 - Temperature

( Fuel Clad 4 Reactor Vessel Water level FCB4 - Reactor Vessel Water Level Fuel Clad 5 - Contamment Radiation Motutorina FCB3 - RaAndon Fuel Clad 6 - Other (SbSpecific) Indications FCBS . SEC Judsement l Fuel Clad 7. Emersency Diredor Judaement FCBS - SEC J"d- --4 RCS Barrier RCS I - Critical Safety Function Status RCBI . Safety Function Status 7unctional Recovery RCS 2. RCS leak Rate RCB2 - Temperature RCB4. Coolant leakaae RCS 3 - SO Tube Rupture RCB2 Temperature RCB4 - Coolant leakage RCS 4. Containment Radiation Monitoring RCB3 - Radiation RCS 5 - Other (site-specific) Indications RCBI - Safety Function StatusTunctional Recovery i RCB4 - Coolant Leakase RCS 6 - Emerasney Director Judaement RCBS SECJudaement Containment Barrier Contenment i . Critical Safetv Function Status CNB1 Safety Function Status 7unctional Recovery C# " 2. N-W Pressure CNB5. Pressure C- W 3 Contamment Isolation Valve Status CNB l- Coolant leakage AfterCw 6maarIsolation Containment 4 SO Secondary Side Release With CNB4. Coolant leakage Pnmary to Secondary leakage Contamment 5 Significant Radioactive Inventory in CNB3. Radiation j Contamment  ;

I Contamment 6 - Core Exit 'Ihple Readinas CNB2. "1eiwature j Containment 7 Other(Site-Specific) Indications CNBl Safety Function Status,Tunctional Recovery CNB3 Radiation j Contamment 8 - Enwraency Director Judaement CNB6 - SEC Jud_-

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l Calvert Cliffs EAL Basis Document G:11 Rev.7

RADIOACTIVITY RELEASE I

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Calvert Cliffs EAL Basis Document Rev.7 l

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RADIOACTIVITY RELEASE Emeraency Cl-mcarian Level: UNUSUAL EVENT Applicable Operational Modes All Calvert Cliffs inisineina Condition:

RUI Unplanned Radioactive Release Exceeding 2 X Tech Spec Limits for AT LEAST 60 Minutes NUMARC Reccanition Catenorv: Abnormal Rad Levels / Radiological Effluent NUMARC Initiatina Condition:

AUl Any Unplanned Release of Gaseous or Liquid Radioactivity to the Emironment that Exceeds Two Times the Radiological Technical Specifications for 60 Minutes or Longer Barner Not Applicable NUMARC Generic Basis:

Unplanned, as used in this context, includes any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.

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

Unplanned releases in excess of two times the site technical specifications that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the Unusual Event emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes. Therefore, it is not intended that the release be averaged over 60 minutes. For example, a release of 4 times TS for 30 minutes does not exceed this initiating condition. Further, the Emergency Director should not wait until 60 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded or will likely exceed 60 minutes.

For sites that have eliminated effluent technical specifications as provided in NRC Generic Letter 89-01, the I corresponding maximum limit from the site's Offsite Dose Calculation Manual should be used as the numeric basis of the EAL.

I 10 CFR 50.72 requires a non-cmergency four hour report for release that exceeds 2 times maximum permissible concentration (MPC) in unrestricted areas averaged over a period of one hour. There is generally more than one applicable technical specification (e.g., air dose rate, organ dose rate, organ doses, release rate, etc.). Often, effluent monitor alarms are based on instantaneous release rates. Depending on the source term, other technical specifications may be more limiting. For this reason, the EALs should trigger an assessment of all applicable specifications.

l Monitor indications should be calculated on the basis of the methodology of the site Offsite Dose Calculation Manual (ODCM), or other site procedures that are used to demonstrate compliance with 10 CFR 20 and/or 10 CFR l 50 Appendix 1 requirements. Annual average meteorology should be used where allowed. <> I In < Generic > EAL 3, the 0.10 < mrem /h> value is based on a proration of two times the 500 mrem /yr basis of the 10 CFR 20 non-occupational <DAC) limits, rounded domi to 0.10 < mrem /h>. If other Site-Specific values are applicable, these should be used.

Calvert Cliffs EAL Basis Document R:1 Rev.7

RAEIOACTIVITY RELEASE Some sites may find it advantageous to address gaseous and liquid releases with separate initiating conditions and EALs.

l Plant-Snecific Information:

With the change in 10 CFR Part 20, the term MPC has been superseded by the term DAC (Derived Air i

Concentration). The new rule has also reduced the non-occupational radiation exposure from 500 mrem /yr to 100 mrenVyr. Calvert Cliffs will use the 500 mrem /yr value consistent with its Technical Specifications.

Calvert Cliss does not have either a perimeter radiation monitoring system or automated real-time dose assessment capability. Thus, the generic EALs recommended by NUMARC do not apply to the Calvert Cliffs Nuclear Power l Plant.

i The main plant vents consist of the exhaust flow from the auxiliary building ventilation systems and the condensate offgas system. Batch releases from the Waste Gas Decay Tanks, containment vents and containment purges are also directed into this stream. Per ODCM Attachment 7, the Unit I aw! Unit 2 vent flow rates are 3

assumed to be 59.4 m /sec and 47.1 m3/sec, respectively. Each plant vent is monitored by a beta sensitive plastic scintillator Wide Range Noble Gas Monitor (WRNGM l-RIC-5415 and 2-RIC-5415) which is displayed in pCi/sec and a Geiger-Muller tube Main Vent Monitor (1-RI-5415 and 2-RI 5415) which is displayed in CPM. The values used for the EALs were determined assuming annual average meteorology, RCS noble gas concentrations, and  ;

using dose conversion factors used for emergency preparedness off-site dose assessment. The total gaseous elease corresponding to 2 times Technical Specification limits is approximately 0.114 mrem in one hour, as calculated using the equation below.

2 x Technical Specification = 2 x 500 mrem / year = 1000 mrem / year Hours / year = 24 x 365 = 8760 hours0.101 days <br />2.433 hours <br />0.0145 weeks <br />0.00333 months <br /> / year (1000 mrem / year) / (8760 hours0.101 days <br />2.433 hours <br />0.0145 weeks <br />0.00333 months <br /> / year) = 0.114 mrem / hour (or 1.14E-3 mSv/ hour)

The values for the vent radiation monitor readings are based on 90% of the 2 DAC (derived air concentration) at the site boundary. This reduction will account for events that may result in releases through both unit vents. The 10% factor allowance for the other unit vent is conservative because it is two to three orders of magnitude larger than the normal releases through each vent. For the main vent monitors, which read in CPM, the Unit I flow rate is assumed because it will result in the Iowat concentration.

RIC-5415 EAL Threshold Per Reference 5, Tech Spec limit corresponds to 1.8 E+5 pCi/sec (site total) 2 x 1.8 E+5 pCi/sec = 3.6 E+5 pCi/sec Assume event in one unit, allow 10% for release from other unit RIC-5415 EAL Threshold = 0.9 x 3.6 E+5 pCi/sec

= 3.24 E+5 pCi/sec

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Read as 3.2 E+5 pCi/sec Calvert Cliffs EAL Basis Document R:2 Rev 7 l l

RADI3 ACTIVITY RELEASE l

Thus, EAL 1 is written as:

l Valid WRNGM (RIC-5415) Reading of AT LEAST 3.2 E+5 pCi/see for GREATER THAN 60 Minutes l Minimum Concentration Corresponding to RI-5415 Reading 1

Concentration = Release rate (uCi/sec) l Flow rate (cc/sec)  !

Unit i ODCM flow rates = 59.4 m 3/sec Unit 1 Concentration = 3.24 E+5 uCi/sec 59.4 m3/sec x 106 cc/m3 5.5 E-3 Ci/cc  ;

I Unit 2 ODCM flow rates = 47.1 m 3/sec Unit 1 Concentration = 3.24 E+5 uCi/sec 47.1 m3/sec x 106cc/m3 j 6.9 E-3 pCi/cc Convert Concentration to CPM for RI-5415 Reading (See Reference 5 for Isotopic Mixture) I isotope RCS  % Total Unit 1 Unit 2 Monator Urut 1 Urut 2 Ccmentration Concentration Concentration Efficiency CPM CPM (pCUcc) (pCi/cc) 4)

(CPM /10 Kr-85 0.43 9.62 5.3 E-4 6.6 E-4 35 1.9 E4 2.3 E4 )

Kr-85m O.16 3.58 2.0 E-4 2.4 E-4 55 1.1 E4 1.3 '34 l Kr-87 0.15 3.36 1.8 E-4 2.3 E-4 218 4.0 E4 5.0 E4 Kr-88 0.28 6.36 3. 4 E-4 4.3 E-4 289 9.8 E4 1.2 ES Xe-133 2.6 58.17 3.2 E-3 4.0 E-3 1.87 6.0 E3 7.5 E3 Xe-135 0.85 19.01 1.0 E-3 1.3 E-3 70 7.0 E4 9.1 E4 Totals 4.47 100.00 5.5 E-3 6.9 E-3 2.4 ES 3.0 E5 Use lower CPM value and read as 2.0 E5 CPM Thus. EAL 2 is written as:

i Valid Main Vent Monitor (RI 5415) Reading of AT LEAST 2 E+5 CPM for GREATER THAN 60 Minutes l In a similar manner to that shown for RI-5415, values were determined for the Waste Processing Monitor (1-RI-5410 and 2-RI 5410) assuming noble gas distribution for Waste Gas Decay Tank rupture, average annual meteorology, and a nominal waste processing ventilation flow of 23.4 m3 /sec (49,500 CFM). At 2 DAC at the site boundary, per Reference 5 this corresponds to a reading of 4.0 E+5 CPM.

Thus, EAL 3 is written as:

Valid Waste Processing Monitor (RI-5410) Reading of AT LEAST 4 E+5 CPM for GREATER THAN 60 Minutes In a similar manner to that shown for RI 5415, values were determined for the Fuel Handling Monitor (0-RI 5420) assuming only monitor response to noble gas released from a Fuel Handling Incident, average annual meteorology, and a nominal fuel handling area ventilation flow of 15.1 m 3/sec (32,000 CFM). At 2 DAC at the site boundary, per Reference 5 this corresponds to a reading of 3.4 E+5 CPM.

Calvert Cliffs EAL Basis Document R:3 Rev.7

MADIOACTIVITY RELEASE Thus. EAL 4 is written as:

Valid Fuel Handing Area Ventilation Exhaust Radiation Monitor (RI-5420) Reading of AT LEAST 3.4 E+5 CPM for GREATER THAN 60 Minutes Analysis was also performed for potential releases through Access Control Point and ECCS Pump Room. Per Reference 5, for each of these locations 2 DAC at the site boundary correspond to monitor readings that are greater than 1 E+6 CPM,i.e., off-scale high.

'Jhus. EAL 5 is written as:

l Valid Access Control Monitor (RI 5425) Reading Off Scale HIGH for GREATER THAN 60 Minutes l EAL 6 is written as:

l Valid ECCS PP Room Monitor (RI-5406) Reading Off-Scale HIGH for GREATER THAN 60 Minutes l Liquid effluent is monitored by the Liquid Wast: Discharge Radiation Monitor (0-R E-2201). A high radiation alarm from this monitor will result in a signal to close the Liquid Waste Discharge Valves. If these valves will not shut, the operators will stop the pump being used for the discharge and shut the Liquid Waste RMS Outlet valve.

Thus, no EAL for liquid effluent release is required. It is extremely improbable that a liquid effluent discharge for greater than 60 minutes could exist following a valid monitor alarm. It is not practical to establish an EAL based on field survey readings of 0.1 mr/hr for greater than 60 minutes. Field instruments in use for emergency response do not have a threshold of detection to meet such criteria.

Source Dc+==WReferences/C=1 & lations:

1. Technical Specifications ITS 5.5.4, Radioactive Effluents Control Program

2. Abnormal Operating Procedures

+

AOP-6B, Accidental Release of Radioactive Liquid Waste 3 System Descriptions No. IS, Radiation Monitoring System

4. Off-Site Dose Calculation Manual (ODCM) for the Baltimore Gas & Electric Company Calvert Cliffs Nuclear Power Plant

5. Radioactivity Release Emergency Action Levels, J.B. McIlvaine, JSB Associates, Inc., September 1990

6. 10 CFR Part 20, Standards for Protection Against Radiation; Final Rule,56 FR 23360. May 21,1991

7. Technical Requirements Manual e TRM 9.3.1, Instrumentation - Radiation Monitoring Instrumentation Calvert Cliffs EAL Basis Document R:4 Rev.7

1 1

I RADIOACTIVITY RELEASE Emeraency Classification Level: UNUSUAL EVENT Analic=hle Operational Modes: All Calvert Cliffs Initiatine Condition:

RU2 Unexpected Increase in Plant Radiation NUMARC Recognition Catenorv: Abnormal Rad Levels / Radiological Effluent I

NUMARC Initiatina Condition:

AU2 Unexpected Increase in Plant Radiation < >

Bamer: Not Applicable l

NUMARC Generic Basis:

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

< Events associated with this IC> 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 at two different PWRs occurring since 1984, explicit coverage of these types of events via EALs I < indication of uncontrolled water level decrease in the reactor refueling casity with all irradiated fuel assemblies remaining water covered > and 2 < indication of uncontrolled water level decrease in the spent fuel and fuel transfer canal with all irradiated fuel assembles remaining water covered > is appropriate given their potential for increased doses to plant staff. Classification as an Unusual Event is warranted as a precursor to a more serious event. < >

EAL <2 (valid Direct Area Radiation Monitor readings increase by a factor of 1000 over normal levels where Normal levels can be considered as the highest reading in the past twenty four hours excluding the current peak value)> addresses unplanned increases of 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. This <!C) escalates to an Alert per <IC RA2, Damage OR Uncovery ofIrradiated Fuel Outside the Reactor Vessel, or IC RA3, Radiation increases That Impede Safe Operation >.

Plant-SoecifieInformation:

EALs related to dry storage of spent fuel in Horizontal Storage Modules are separately addressed under RU3, Potential Degradation of Containment of Dry Stored Spent Fuel, I

Of concern in this IC are water level decreases over spent fuel that are sufficient to cause noticeable increases in measured radiation levels. Additionally, fuel handling incidents can lead to many of the same symptoms of increased plant radiation levels. Existence of a Fuel Handling Area Ventilation Exhaust Radiation Monitor alarm (RI 5420), a Spent Fuel Pool Area Radiation Monitor alarm (RI-7024), or a Containment Radiation Monitor (RI-5316A/B/C/D) reading of at least 109 mrem /h is used as the threshold for entry into this IC. One hundred mrem /h ,

corresponds to the administrative limit for a high radiation area and is significantly higher than the dose rates i expected for fuel handling.  !

l l

I Calvert Clif"s EAL Basis Document R: 5 Rev.7 l l

l

RATIOACTIVITY RELEASE Thus, EAL 1 is written as:

AOP4D Or AOP4E is Implemented AND Any of the Following:

e Valid Fuel Handling Area Ventilation Exhaust Radiation Monitor Alarm (RI 5420) e Valid Spent Fuel Pool Area Monitor Alarm (Rl-7024) e Valid Containment Radiation Monitor (RI-5316A/B/C/D) Reading of AT LEAST 100 mrem /h EAL 2 is taken directly from NUMARC. Momentary increases due to events such as resin transfers or controlled movement of radioactive sources should not result in emergency declaration. Certain radiation monitor alarms may go offscale high before reaching 1000 times normal readings.

Thus, EAL 2 is written as:

Valid Unexpected Rad Monitor Reading Offscale High OR GREATER THAN 1000 Times Normal Reading.

Valid means that the indication is from instrumentation determined to be operable in accordance with the Technical Specifications or has been verified by other independent methods such as indications displayed on the control panels, reports from plant personnel, or radiological survey results.

The Unusual Event may be terminated when the following actions occur:

(1) The source has been identified, (2) The source has been controlled or contained as appropriate, and (3) Appropriate personnel radiation practices have been implemented.

Expected increases in radiation monitor readings due to controlled evolutions (such as lifting the reactor vessel head during refueling) should not result in emergency declaration. In-plant radiation level increases that would result in emergency declaration are also unplanned, e.g., outside the limits established by an existing radioactive discharge permit.

Source Documents /Referencet' Calculations:

1. System Descriptions No.10, Spent Fuel Pool and Spent Fuel Pool Cooling And Purification Systems No.13, Refueling Equipment No.15, Radiation Monitoring System

2. Abnormal Operating Procedures AOP4D, Fuel HandlingIncident AOP4E, Loss ofRefueling PoolLnci Calvert Cliffs EAL Basis Document R:6 Rev.7

RADIOACTIVITY RELEASE Emeraency Classification Level: UNUSUAL EVENT Anoticable Onerational Modes: ALL Calvert Cliffs Initiatina Condition:

RU3 Potential Degradation of Containment of Dry Stored Spent Fuel NUMARC Pacaenitian Canaaary: Abnormal Rad Levels / Radiological Effluent NUMARC Initiatina Condition:

AU2 Unexpected Increase in Plant Radiation < >

Bamer Not Applicable NUMARC Generic Basis:

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

< Events associated with this IC) 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. o

<This IC> applies to plants with licensed dry storage of older irradiated spent fuel to address degradation of this spent fuel. One utility uses values of 2 R/hr at the face of any dry storage module or 1 R/hr one foot away from a damaged module. o Plant Snecific Information:

As a result of a meeting between BG&E Emergency Planning Staff and NRC Facilities Radiological Safety and Safeguards Branch personnel on July 16, 1992, the following EALs were developed regarding potential degradation of containment of dry stored spent fuel.

EAL 1 is written as:

l Horizontal Storage Module (HSM) Access Door Contact Dose Rate GREATER THAN 500 mrem /h j At 100 rem per Sievert, this corresponds to a dose rate of 5 (milli-Sieverts) mSv/h.

EAL 2 is written as:

l Horizontal Storage Module (HSM) Side Wall Door Contact Dose Rate GREATER THAN 100 mrem /h l This corresponds to a dose rate of 1 mSv/h.

EAL 3 is written as:

Any Unplanned Event Outside the Auxiliary Building Resulting in the Breach of a Dry Shielded Canister (DSC) Containing Spent Fuel Unplanned is used to preclude declaration of en emergency where the DSC has been intentionally opened for maintenance or repair activity in accordance with a valid radiation work permit.

EAL 4 is written as:

l Dry Shielded Canister (DSC) Transfer Cask Containing Spent Fuel Has Been Dranaad from the Trailer l

Calvert Cliffs EAL Basis Document R7 Rev.7

RADIOACTIVITY RELEASE Source D-maat</ References /Calcidations:

1

1. Letter dated September 24, 1992, L.B. Russell (BGAE) to U.S. Nuclear Regulatory Commission, re:

Emergency Action Level Resiew Meeting held on July 16,1992 4 l

2. BG E-01 121 Rev. O, An Assessment of Storage Term Radiological Exposure Rates at the Calvert Cliffs i'

NUHOMSC ISFSI, Pacific Nuclear Fuel Senices, Inc., September 1990 l

l l

l I

l i

lI l

i i

i i

I l

I Calvert Cliffs EAL Basis Document R:8 Rev.7 l

RADIOACTIVITY RELEASE Emeraency Classification Level: ALERT Annlicable Onerational Modes All Calvert Cliffs Initiating Condition:

RA1 Unplanned Radioactive Release Exceeding 200 X Tech Spec Limits for AT LEAST 15 Minutes NUMARC Recognition C='aqq: Abnormal Rad Levels / Radiological Emuent NUMARC Initiating Condition:

AAl Any Unplanned Release of Gaseous or Liquid Radioactivity to the Emironment that Exceeds 200 Times Radiological Technical Specifications for 15 Minutes or Longer Barner Not Applicable NUMARC Generic Basis:

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

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

Prorating the 500 < mrem /yr> caiterion for both time (8766 hr/yr) and the 200 multiplier, the associated site boundary dose rate would be 10 < mrem /h>. The required release duration was reduced to 15 minutes in recognition of the increased severity.

For sites that have eliminated emuent technical specifications as provided in NRC Generic Letter 89-01, the corresponding maximum limit from the site's Offsite Dose Calculation Manual, multiplied by 200, should be used as the numeric basis of this EAL.

Monitor indications should be calculated on the basis of the methodology of the site Offsite Dose Calculation Manual (ODCM), or other site procedures that are used to demonstrate compliance with 10 CFR 20 and/or 10 CFR 50 Appendix 1 requirements - adjusted upwards by a factor of 200. Annual average meteorology should be used

. where allowed. < >

i In < Generic > EAL 3, the 10 < mrem /h> value is based on a proration of 200 times the 500 mrem />T basis of the 10 CFR 20 non-occupational MPC limits, rounded down to 10 < mrem /h>. If other Site-Specific values are applicable, these should be used.

l Plant-Snecific Information:

With the change in 10 CFR Part 20, the term MPC has been superseded by the term DAC (Derived Air Concentration). The new rule has also reduced the non-occupational radiation exposure from 500 mrem />T to 100 mrem /yr. Calvert Cliffs will use the 500 mrem /yr value consistent with its Technical Specifications.

Calvert Cliffs does not have either a perimeter radiation monitoring system or automated real-time dose assessment capability. Thus, the generic EALs recommended by NUMARC do not apply to the Calvert Cliffs Nuclear Power

- Plant.

A description of the applicable monitors and the methods used to calculate EAL values is show11 in RUI, Unplanned Radioactive Release Exceeding 2 X Tech Spec Limits for GREATER THAN 60 Minutes. Values for this IC are based on the values shown in RUl multiplied by 100. (See equation below.)

Calvert Cliffs EAL Basis Document R:9 Rev.7

RADI@ ACTIVITY RELEASE RA1 Threshold for RIC-5415, RI-5415 RUI Value x 100 = RAI Value 1

For RIC-5415 3.2 E+5 pCi/second x 100 = 3.2 E+7 pCi/second For RI 5415 s

2.0 E+5 CPM x 100 = 2.0 E+7 CPM (Above top of scale)  ;

The ECCS PP Room Monitors (1/2-RI 5406) and the Access Control Monitor (0-RI 5425) are not considered here because they will be offscale high at the Unusual Event emergency classification level. At the Alert level, the  ;

readings on the main vent monitors (1/2-RI 5415), the Waste Processing Vent Monitors (1/2-RI-5410), and the  !

Fuel Handling Area Vent Monitor (0-RI-5420) correspond to readings well above the top of the range (1.0 E+6 l CPM) for these instruments. Therefore, these monitors provide no useful information for this IC and are excluded l from consideration.

Thus. EAL 1 is written as:

l Valid WRNGM (RIC-5415) Reading of AT LEAST 3.2 E+7 pCi/sec for GREATER THAN 15 Minutes l The purpose of the Main Steam Effluent Radiation Monitor System is to monitor possible noble gas releases to the atmosphere from the main steam line through the atmospheric steam dump valves, the main steam safety relief valves, and the auxiliary feedwater steam turbine exhaust. The system includes two radiation monitors (1/2-RI-5421 and 1/2-RI-5421) for each unit - one radiation monitor for each steam generator. Each radiation detector is an ion chamber filled with xenon gas with a small " keep alive" source that produces a reading on the corresponding main control board rate meter of about 10-2 R/hr.

The noble gas release rate of 3.2 E+7 pCi/second (which corresponds to a whole body dose of 10 mrem in one hour at the site boundary) may also occur through release via main steam safety valve or atmospheric dump valve. By reverse calculation using Attachment 3 of ERPIP 821 (see box below):

Calvert Cliffs EAL Basis Document R:10 Rev.7

RADIOACTIVITY RELEASE RAI Threshold for RI 5421, RI 5422 1

Release Rate = 3.2 E+7 pCi/sec (see above) i Release Coemeient (for SG Tube Rupture) = 6.1 E+2 uCi/cm3 rem /h Atmospheric Dump Valve Flow Rate = 1.4 E+6 cm 3/sec Safety Valve Flow Rate = 2.4 E+6 cm3/sec Main Steam Monitor Reading (rem /h) = Release Rate Release Cocmcient x Flow Rate j For safety valve rem /h = 3.2 E+7 6.1 E+2 x 2.4 E+6

= .022 rem /h (read as .02)(0.2 mSv/h)

For atmospheric dump valve rem /h = 3.2 E+7 6.1 E+2 x 1.4 E+6

= .038 rem /h (read as .04)(0.4 mSv/h)

The minimum reading for RI-5421/5422 is 10 mrem /h due to the " keep alive" source. Twenty mrem /h would be difficult to read accurately. The high alarm setpoint for these monitors is set at 47 mrem /h

• 5 mrem /h. Therefore, for human factors reasons, the existence of the high alarm setpoint is used as the threshold for this EAL.

Thus. EAL 2 uses the lower value and is written as:

l Valid Main Steam Effluent Monitor (RI 5421. RI 5422) High Alarm for GREATER THAN 15 Minutes l Valid means that the indication is from instrumentation determined to be operable in accordance with the Technical Specifications or has been verified by other independent methods such as indications displayed on the control panels, reports from plant personnel, or radiological survey results. Based on the March 14,1993 SG tube rupture event at Palo Verde Unit 2, the main steam effluent monitors (RI 5421 RI-5422) may read N16 immediately following SG tube rupture and prior to reactor trip. However, given the short half-life of N16, this should clear within the first minute following reactor trip.

Although Calvert Cliffs does not have a perimeter monitoring system, field monitoring could reliably detect radioactive releases. Thus EAL 3 is written as:

l Field Survey Dose Rate Readmg of 10 mrem /h or greater at Site Boundary l Source Dm='*/ References / Calculations:

1. System Descriptions

+

No.15, Radiation Monitoring System

2. Off-Site Dose Calculation Manual (ODCM) for the Baltimore Gas & Electric Company Calvert Cliffs Nuclear Power Plant

3. Radioactivity Release Emergency Action Levels, J.B. McIlvaine, JSB Associates, Inc., September 1990 Calvert Cliffs EAL Basis Document R:11 Rev.7

RADICACTIVITY RELEASE

4. Emergency Response Plan Implementation Procedures ERPIP 821, Accidental Radioactivity Release Monitoring and Sampling Methods

5. BG&E Internal Memorandum, J. R. Hill (Nuclear Plant Operations) to R. L. Wenderlich, CE Operations Subcommittee Meeting - Trip Report, April 16,1993

6. 10 CFR Part 20, Standards for Protection Against Radiation; final Rule, 56 FR 23360, May 21,1991 7, Calven Cliffs Instructions CCI 302, Calvert Cliffs Alarm Manual, Main Steam Effl Rad Monitor 2C24B Calvert Cliffs EAL Basis Document R:12 Rev.7

RAEIOACTIVITY RELEASE Emergency Classification Level: ALERT Acolicable Operational Modes: All Calvert Cliffs Initiatina_ Candition:

RA2 Damage OR Uncovery of Single Inadiated Fuel Assembly Outside the Reactor Vessel NUMARC Recognition Category: Abnormal Rad Levels / Radiological Effluent NUMARC Initiatina Caa&tian:

AA2 Major Damage to Irradiated Ft.el or Loss of Water Level that Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel Bamer Not Applicable NUMARC Generic Basis:

This IC applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage, which is discussed in <RU3, Potential Degradation of Containment of Dry Stored Spent Fuel >.

NUREG-0818 Emergency Action Levelsfor Light Water Reactors, forms the basis for these EALs. Each site should also define its EALs by the specific area where Irradiated fuel is located such as Reactor Casity, Reactor Vessel, or Spent Fuel Pool.

There is time available to take corrective actions, ar.d there ic little potn al for substantial fuel damage. In addition, NUREGICR-4982, Severe Accident in Spenn FuelPools u. Scport of Generic Safety issue 82, July 1987, indicates that even if corrective actions are not taken, no prompt fatalities ar, predicted, and that risk ofinjury is low. In addition, NRC Information Notice No. 90-08, KR-85 Hazardsfrom Decayed Fuel, presents the following in its discussion:

In the event of a serious accident involving decayed spent fuel. protective actions would be needed for personnel on site, while off-site doses (assuming an exclusion area radius of one mile from the plant site) would be well below the Emironmental Protection Agency's Protective Action Guides. Accordingly, it is important to be able to properly survey and monitor for Kr 85 in the event of an accident with decayed spent fuel.

Licensees may wish to reevaluate whether Emergency Action Levels specified in the emergency plan and procedures governing decayed fuel-handling activities appropiiately focus on concern for onsite workers Kr-85 releases in areas where decayed spent fuel accidents could occur, for example, the spent fuel p .

working floor. Furthermore, licensees may wish to determine if emergency plans and correspondmg implementing procedures address the means for limiting radiological exposures of onsite personnel who are in other areas of the plant. Among other things, moving on-site personnel away from the plume and shutting off building air intakes downwind from the source may be appropriate.

Thus, an Alert Classification for this event is appropriate. Escalation, if appropriate, would occur sia <other Radioactivity Release ICs or SEC Judgement ICs>.

Calvert Cliffs EAL Basis Document R:13 Rev.7

RADIOACTIVITY RELEASE E,hnt Snecific Information:

AOP-6E, Loss of Refueling Pool Level, provides actions to respond to a loss of Refueling Pool (RFP) inventory due  ;

to failure of the Refueling Pool Seal, Steam Generator Nozzle Dams, or the Refueling Pool Drain Line. These l actions include placing spent fuel in safe storage locations (i.e., all spent fuel will remain water covered following pool draindown to the reactor vessel flange elevation). If any spent fuel assembly can NOT be placed in an appropriate safe storage location, this corresponds to entry into this IC.

Thus, EAL 1 is written as:  !

AOP 6E, Loss of Refueling Pool Level, is Implemented AND Valid Containment Radiation Alarm (RI- ,

5316A/B/C/D)  !

EAL 2 is written as:

AOP4D, Fuel Handling Incident, is implemented And ANY of the Following:

e Valid Containment Radiation Alarm (RI-5316A/B/C/D) e Valid Fuel Handling Area Ventilation Exhaust Radiation Monitor (RI-5420) Reading of AT LEAST 2E+4 CPM e Valid Spent Fuel Service Platform Monitor (RI-7025) Reading of AT LEAST 100 mrem /h Valid means that the indication is from instmmentation determined to be operable in accordance with the i Technical Specificaiions or has been verified by other independent methods such as indications displayed on the  ;

control panels, reports from plant personnel, or radiological survey results. I The containment radiation alarm corresponds to a dose rate of 200 mrem /h.

The value for RI-5420 was determined based on a fuel handling accident damaging one fuel rod in an average (unpeaked) fuel assembly. The results of the calculation, showing RI-5420 response versus age of the assembly (time after shutdown), is shown as Figure RI. The value of 2E4 CPM corresponds to the minimum expected response and is significantly higher than the alarm setpoint of 600 CPM.

One hundred mrem /h is used for the Service Platform Monitor (RI 7025) because it corresponds to the  !

administrative limit for a high radiation area and is significt.ntly higher than the dose rates expected for fuel handling actisities.

Expected increases in monitor readings due to controlled evolutions (such as lifling the reactor vessel head during refueling) should not result in emergency declaration. Nor should momentary increases due to events such as resin transfers or controlled movement of radioactive sources result in emergency declaration. In-plant radiation level increases that would result in emergency declaration are also unplanned, e.g , outside the limits established by an existing radioactive discharge permit.

Source Domaw=Le/ References /Calenla4==:

1. System Descriptions No.15, Radiation Monitoring System

2. Abnormal Operating Procedures AOP-6D, Fuel Handling incident AOP-6E,less of Refueling Pool Le :1

3. Ogden Calculation #RA 1, 0-RI-5420 Detector Response to Fuel Handling Accident Calvert Cliffs EAL Basis Document R:14 Rev.7

RADIOACTIVITY RELEASE Emernency Cl-Mcation Level: ALERT AnD[icable Onerational Modes: All Calvert Cliffs Initiatina Condition:

RA3 Radiation Increases That Impede Safe Plant Operation NUMARC Recoanition Category: Abnormal Rad Levels / Radiological Effluent NUMARC Initiatina Condition:

AA3 -Release of Radioactive Material or Increases in Fadiation Levels Within the Facility That Impedes Operation of Systems Required to Maintain Safe Op; rations or to Establish or to Maintain Cold Shutdown Barner Not Applicable NUMARC Generic E;;;;u cv Action Levels Example Emergency Action Levels: (1 or 2)

1. Valid (site-specific) radiation monitor reading GREATER THAN 15 mR/br in areas requiring continuous occupancy to maintain plant safety functions:

(Site-specific) list

2. Valid (site-specific) radiation monitor readings GREATER THAN < site specific > values in areas requiring infrequent access to maintsin plant safety functions.

(Site-specific) list NOTE: The Emergency Director should determine the cause of the increase in radiation levels and review other ICs for applicability.

NUMARC Generic Basis:

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

This IC addresses increased radiation levels that impede necessary access to opercting stations, or other areas containin~ g 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. The cause and/or magnitude of the increase in radiation levels is not the concern of this IC. The <SEC> must consider the source or cause of the increased radiation levels and determine if any other IC may be involved. For example, a dose rate of 15 < mrem /h> in the control room may be a problem in itself. However, the increase may also indicate high dose rates in the containment due to a LOCA. In this latter case, <a> SAE or GE may be indicated by fission product barrier matrix ICs.

At multiple unit sites, the example EALs could result in declaration of an Alert at one unit due to a radioactivity increase or radiation shine resulting from a major accident at the other unit. This is appropriate if the increase impairs operations at the operating unit.

Calvert Cliffs EAL Basis Document R:15 Rev.7

_a

RADIOACTIVITY RELEASE This IC is not meant to apply to increases in containment dome radiation monitors as these events <> are addressed in the fission product barrier matrix ICs. Nor is it intended to apply to anticipated temporary increases due to planned events (e.g., in-core detector movement, radwaste container movement, depleted resin transfers, etc.)

l Emergency planners developing the (Site-Specific) lists may refer to the site's abnormal operating procedures, i emergency operating procedures, the 10 CFR 50 Appendix R analysis, and/or, the < analysis > performed in response to Section 2.1.6b of NUREG-0578, TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations, when identifying areas containing safe shutdown equipment. With regard to the NUREG-0578 analysis, do not use the dose rate postulated therein as a basis for the radiation monitor readags for this IC, as the NUREG4578 < analysis > address general emergency conditions.

Areas requiring continuous occupancy include the control room and, as appropriate to the site, any other control stations that are manned continuously, such as the radwaste control room or a central security alarm station. The value of 15 mrem /h is derived from the GDC 19 value of 5 rem in 30 days with adjustment for expected occupancy times. Although Section III.D.3 of NUREG-0737, Clarification of TM1 Action Plan Requirements, provides that i the 15 < mrem /h> value can be averaged over 30 days, the value used here is without averaging, as a 30 day duration implies an event potentially more significant than an Alert.

For areas requiring infrequent access, the (Site-Specific) value(s) should be based on radiation levels which result in exposure control measures intended to maintain doses within normal occupational exposure guidelines and limits (i.e.,10 CFR 20), and in doing so, will impede necessary access. For many areas, it may be possible to establish a single < Generic > EAL that represents a multiple of the normal radiation levels (e.g.,1000 times normal). However, areas that have normally high dose rates may require a lower multiple (e.g.,10 times normal). i NUMARC Ouestions and Answers. June 10.1993 (Abnormal Rad 14vels/ Radiological Effluent) l None l l

Plant-Soccific Information I The control room is required to be continuously occupied following design basis accidents. All Actions required to ,

achieve and maintain cold shutdown can be accomplished from the control room. Post-accident doses have been l evaluated and shown to be less than limits based on GDC 19. On a control room high radiation signal, the control room emergency ventilation system automatically switches into a recirculation mode of operation with flow through the HEPA filters and charcoal absorber banks. EAL 1 is based on the GDC 19 limit recommended by NUMARC.

In response to Generie EAL 1 Calvert Cliffs EAL 1 is written: n=. EAL ! i; de: es:

l Valid Control Room Radiation Monitor (RI-5350) Reading GREATER THAN 15 mrem /h l This corresponds to a dose rate of 0.15 mSv/h. Valid means that the indication is from instrumentation determined to be operable in accordance with the Technical Specifications or has been verified by other independent methods such as indications displayed on the control panels, reports from plant personnel, or radiological survey results.

EAL 2 addresses event sequences outside the plant design basis. Entry into any area with exposure rates of at least 10 Rem /h (100 m Sv/h) could result in an individual exceeding 10 CFR 20 limits (5 Rem REM /yr) within approximately 30 minutes.

In response to Generie EAL 2, Calvert Cliffs EAL 2 is written: E= EAL 2 i: c" :: =: -

Exposure Rate of 10 rem /h or greater in Ar:= R:pir:4 te AS=: er '. Sad: S:': Sht= an Area of Concern for Safe Shutdown Calvert Cliffs EAL Basis Document R:16 Rev.7

RADIOACTIVITY RELEASE Areas of concern for Safe Shutdown are listed below. i Areas of Concern for Safe Shutdown

. Control Room

• Electncal Penetration Rooms

. Control Room HVAC Room

• Auxiliary Feedwater Pump Room

. Cable Spreading Room + Charging Pump Rooms

• Cable Chases Diesel Generator Rooms

• Switchgear Room . Diesel Generator Building (0C/l A)

• ECCS Pump Room + Refueling Water Tank (RWT) 11(21)

. Service Water Pump Room . Condensate Storage Tank (CST) 12 Component Cooling Pump Room

• Pretreated Water Storage Tank (PWST) 11(12)G4-)

• Main Steam Penetration Room

• Fuel Oil Storage Tank (FOST) 2144

• Istake Structure This list of Safe Shutdown areas is displayed on the EAL Tables to assure that all areas related to Safe Shutdown are considered by the SEC.

Expected increases in monitor readings due to controlled evolutions (such as liAing the reactor vessel head during refueling) do not result in emergency declaration. Nor should momentary increases due to events such as resin j transfers or controlled movement of radioactive sources result in emergency declaration. In-plant radiation level increases that would result in emergency declaration are also unplanned, e.g., outside the limits established by an existing radioactive discharge permit. The containment radiation monitor readings should only apply to this IC when personnel are in containment for normal maintenance, inspection, surveillance, testing, or refueling activities.

Source Documents / References /C=1 & idions:

1. System Descriptions No.15, Radiation Monitoring System

2. Letter, G.C. Creel (BGAE) to NRC Document Control Desk dated September 1,1989, Control Room Dose

3. Letter, J. A. Tiernan (BG&E) to A.C. Thadani (NRC) dated March 5,1986, Control Room Dose

4. CCI 800, Calvert Cliffs Radiation Safety Manual I

Calvert Cliffs EAL Basis Document R:17 Rev.7 j l

l l

RADIOACTIVITY RELEASE Emernency Classification Level: SITE EMERGENCY i

Appjjcable Operational Modes: All Calvert Cliffs Initiatina Condition:

RS1 Off-Site Dose of AT LEAST 0.1 Rem (EDE + CEDE) Or 0.5 Rem CDE ThyToid l

NUMARC Raca-aitian Cata-ary: Abnormal Rad Lestis/ Radiological Effloent l l

NUMARC Initiatino Condition:

ASI Site Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactisity Exceeds 100

< mrem > Whole Body or 500 < mrem > Thyroid for the Actual or Projected Duration of the Release Barner Not Applicable NUMARC Generic Basis:

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

The 100 < mrem > integrated dose in this initiating condition is based on the proposed 10 CFR 20 annual astrage population exposure. This value also provides a desirable gradient (one order of magnitude) between the Alert, Site

<E>mergency, and General Emergency classes. It is deemed that exposures less than this limit are not consistent with the Site <E>mergency class description. The 500 < mrem > integrated < > th>Toid dose was established in consideration of the 1:5 ratio of the EPA Protective Action Guidelines for whole body and th>Toid.

I Integrated doses are generally not monitored in real-time. In establishing the emergency action levels, it is i suggested that a duration of one hour be assumed, and that the EALs be based on a site boundary dose of 100

< mrem /h> whole body or <500 mrem /b> child thyroid, whichever is more limiting (depending on source term i assumptions). If individual site analyses indicate a longer or shorter duration for the period in which the  !

substantial portion of the activity is released, these dose rates should be adjusted. j The FSAR source terms applicable to each monitored pathway should be used in conjunction with annual average meteorology in determining indications for the monitors on that pathway.

i Plant-Snecific Information 10 CFR Part 20 was revised following the development of the NUMARC methodology. Calvert Cliffs uses the new rule as its basis for determining dose. EDEis the Effective Dose Equivalent as defined in 10CFR20.1003. CEDE is the Committed Effective Dose Equivalent as defined in 10CFR20.1003. CDE is the Committed Dose Equivalent as defined in 10CFR20.1003.

Calvert Cliffs does not have either a perimeter radiation monitoring system or automated real-time dose assessment capability. Thus, the generic EALs recommended by NUMARC do not apply to the Calvert Cliffs Nuclear Power Plant.

A description of the applicable monitors and the methods used to calculate EAL values for the WRNGM is shown I

i in RUI, Unplanned Radioactive Release Exceeding 2 X Tech Spec Limits for GREATER THAN 60 Minutes.

Values for this IC are based on the values shown in RUl scaled up from 0.114 mrem in an hour (i.e., hourly rate resulting in 2 X 500 mrem in one year) to 100 mrem (EDE + CEDE) (1 mSV) in an hour. (See box below.)

l Cahert Cliffs EAL Basis Document R:18 Rev.7 I

RADIOACTIVITY RELEASE i

1 EALs 1 and 2 only apply if dose assessment capability is not available, f.e., without dose assessment. The preferred I method of declaration is via EAL3, with EALs 1 and 2 as backup ='h=Is, if required.

RSI Threshold for RIC-5415 Scale up from RUI uncorrected release rate of 3.6 E+5 pCi/sec RSI Value = 100 mrem /h x 3.6 E+5 uCi/sec 0.114 mrem /h (or .00114 mSv/h)

= 3.2 E+8 pCi/sec Read as 3 E+8 pCFsec Thus. EAL 1 is written as:

Valid WRNGM (RIC-5415) Reading of AT LEAST 3 E+8 pCi/sec for GREATER THAN 15 Minutes (Without Dose Assessment)

This value corresponds to a concentration of about 5 pCi/cc and falls well within the range of the WRNGM.

The purpose of the Main Steam Effluent Radiation Monitor System is to monitor possible noble gas releases to the atmosphere from the main steam line through the atmospheric steam dump nives, the main steam safety relief valves, and the auxiliary feedwater steam turbine exhaust. The system includes two radiation monitors (1/2-RI.

5421 and 1/2-RI 5421) for each unit - one radiation monitor for each steam generator. Each radiation detector is an ion chamber filled with xenon gas with a small ." keep alive" source that produces a reading on the corresponding main control board rate meter of about 10 2 R/hr.

The noble gas release rate of 3.2 E+8 pCi/sec (which corresponds a whole body dose of 100 mrem in one hour at i the site boundary) may also occur through release via main steam safety valve or atmospheric dump valve.

By reverse calculation using AttacTunent 3 of ERPIP 821:

1 1

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Calvert Cliffs EAL Basis Document R:19 Rev.7

RADIOACTIVITY RELEASE RSI Threshold for RI 5421. RI 5422 Release Rate = 3.2 E+8 pCi/sec (see above)

Release Coefficient (for SG Tube Rupture) = 6.1 E+2 pC1/cm3 rem /h Atmospheric Dump Valve Flow Rate = 1.4 E+6 cm3/sec Safety Valve Flow Rate = 2.4 E+6 cm3fgee Main Steam Monitor Reading (rem /h) = Release Rate Release Coefficient x Flow Rate For safety valve rem /h = 3.2 E+8 6.1 E+2 x 2.4 E+6

= 0.22 rem /h (read as 0.2)(2 mSv/h)

For atmospheric dump valve rem /h = 3.2 E+8 6.1 E+2 x 1.4 E+6

= 0.38 rem /h (read as 0.4)(4 mSv/h)

Thus, EAL 2 is written as:

Valid Main Steam Effluent Monitor (RI 5421, RI 5422) Reading of AT LEAST 0.2 rem /h for GREATER THAN 15 Minutes (Without Dose Assessment)

Valid means that the indication is from instrumentation determined to be operable in accordance with the Technical Specifications or has been verified by other independent methods such as indications displayed on the control panels, repoits from plant personnel, or radiological survey results. Based on the March 14,1993 SG tube rupture event at Palo Verde Unit 2, the main steam efiluent monitors (RI 5421, RI-5422) may read N16 immediately following SG tube rupture and prior to reactor trip. However, given the short half-life of N16, this should clear within the first minute following reactor trip.

Dose consequences can be determir>xi by use of ERPIP 822, Initial Dose Assessment Manual Calculation Methods, or by use of ERPIP 823, Dose Assessment Computer. Dose assessment will be performed in accordance with the new 10 CFR 20 scheduled to take effect January 1,1994.

Thus, EAL 3 is written as:

Dose Assessment Determines Integrated Accident Forecast Dose Off-Site is AT LEAST 0.1 rem (EDE +

CEDE) Or 0.5 rem CDE Th>Toid

. This corresponds to doses of 1 mSv (EDE+ CEDE) and 5 mSv CDE Thyroid, respectively.

Source De=at</ References /Calentmeiane:

1. System Descriptions a

Radiation Monitoring System Calvert Cliffs EAL Basis Document R:20 Rev.7

RAEIOACTIVITY RELEASE

2. Emergency Response Plan Implementation Procedures ERPIP-810, Main Steam Radic.sctivity Release Estimate a

ERPIP-821, Accidental Radioactivity Release Monitoring and Sampling Methods ERPIP-822, Initial Dose Assessment Manual Calculation Methods

+

ERPIP-823, Dose Assessment Computer

3. Radioactivity Release Emergency Action Levels, J.B. McIlvaine, JSB Associates, Inc., September 1990

4. BG&E Fuel Degradation EALs Calculation Worksheet, JSB Associates, February 18,1993

5. Radioactivity Release Emergency Action Levels, J.B. McIlvaine, JSB Associates, Inc., September 1990

6. BG&E Internal Memorandum, J. R. Hill (Nuclear Plant Operations) to R. L. Wenderlich, CE Operations Subcommittee Meeting - Trip Report, April 16,1993

7. 10 CFR 20, Standards for Protection Against Radiation; Final Rule, 56 FR 23360, May 21,1991 Calvert Cliffs EAL Basis Document R:21 Rev.7

RAECIOACTIVITY RELEASE Emeraency Classification Level: GENERAL EMERGENCY ApohcableOncrationalModes All Calvert Cliffs faitiatine Candi'iaa-RG1 Off-Site Dose of AT LEAST 1 Rem (EDE + CEDE) Or 5 Rem CDE Thyroid NUMARC R~a-nitian Catenorv: Abnormal Rad Levels / Radiological Effluent NUMARC It itiatine Condition:

AGI Site Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 1000 < mrem > Whole Body or 5000 < mrem > Child Thyroid for the Actual or Projected Duration of the Release Using Actual Meteorology Bamer Not Applicable NUMARC Generic Basis:

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

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The 1000 mrem <EDE + CEDE > and 5000 mrem <CDE> thyroid integrated doses are based on the EPA protective action guidance which indicates that public protective actions are indicated if the dose exceeds I rem

<EDE + CEDE > or 5 rem <CDE> thyroid. This is consistent with the emergency class description for a General l Emergency. This level constitutes the upper level of the desirable gradient for the Site <E>mergency. Actual I meteorology is specifically identified in the initiating condition since it gives the most accurate dose assessment.

Actual meteorology (including forecasts) should be used whenever possible. l Integrated doses are generally not monitored in real-time. In establishing the emergency action levels, it is suggested that a duration of one hour be assumed, and that the EALs be based on site boundary doses for either

<EDE + CEDE > or <CDE> thyroid, whichever is more limiting (depending on source term assumptions). If individual site analyses indicate a longer or shorter duration for the period in which the substantial portion of the activity is released, these dose rates should be adjusted.

The FSAR source terms applicable to each monitored pathway should be used in conjunction with annual average <

meteorology in determining indications for the monitors on that pathway.

Plant-Specific Information 10 CFR Part 20 was revised following the development of the NUMARC methodology. Calvert Cliffs uses the new rule as its basis for determining dose. EDE is the Effective Dose Equivalent as defined in 10CFR20.1003. CEDE is the Committed Effective Dose Equivalent as defined in 10CFR20.1003. CDEis the Committed Dose Equivalent as defined in 10CFR20.1003.

Calvert Cliffs does not have either a peruneter radiation monitoring system or automated real-time dose assessment capability. Thus, the generic EALs recommended by NUMARC do not apply to the Calvert Cliffs Nuclear Power Plant.

A description of the applicable monitors and the methods used to calcula's EAL values for the WRNGM is shown in RUI, Unplanned Radioactive Release Exceeding 2 X Tech Spec Limits for GREATER THAN 60 Minutes.

Values for this IC are based on the values shown in RUI scaled up from ti.D i mrem in an hour (i.e., hourly rate resulting in 2 X 500 mrem in one year) to 1000 (EDE + CEDE) mrem in an hour (10 mSv/h).

Calvert Cliffs EAL Basis Document R:22 Rev.7

RArlOACTIVITY RELEASE EALs 1 and 2 only apply if dose assessment capability is not available, i.e., without dose assessment. The preferred method of declaration is via EAL 3, with EALs 1 and 2 as backup methods, if required.

RG1 Threshold for RIC-5415 Scale up from RUI uncorrected release rate of 3.6 E+5 pCi/sec RG1 Value = 1000 mrem /h x 3.6 E+3 pCi/sec 0.114 mrem / hour (or .00114 mSv/h)

= 3.2 E+9 pCi/sec Read as 3 E+9 pCi/sec This value corresponds to a concentration of about 50 Ci/cc and falls within the range of the WRNGM.

Thus. EAL 1 is written as: '

Valid WRNGM (RIC-5415) Reading of AT LEAST 3E+9 pCi/sec for GREATER THAN 15 Minutes (Without Dose Assessment)

The Main Steam Effluent Radiation Monitor System is described under IC RSI, Off-Site Dose of AT LEAST 0.1  !

Rem (EDE + CEDE) OR 0.5 Rem CDE Thyroid. The appropriate EAL value for this IC was determined by scaling up the RSI reading to correspond to 1,000 mrem in one hour (10 mSv/h).

J RG1 Threshold for RI 5421, RI-5422 RG1 Value = RSI Value x 1000 mrem /h 100 mrem /h

= 0.2 rem /h x 10

= 2 rem /h (20 mSv/h) j The 2 rem /h (20 mSv/h) on 1/2 RI-5421/5422 is based on assuming a single stuck open safety valve. A value of 3 3

rem /h (30 mSv/h) corresponds to assuming a single stuck open Ltmospheric dump valve.

]

Thus, EAL 2 is written as-Valid Main Steam Effluent Monitor (RI 542), RI 5422) Reading of AT LEAST 2 rem /h for GREATER THAN 15 Minutes (Without Dose Assessment)

]

Valid means that the indication is from instrumentation determined to be operable in accordance with the i Technical Specifications or has been verified by other independent methods such as indications displayed on the I control panels, reports from plant personnel, or radiological survey results. Based on the March 14,1993 SG tube I rupture event at Palo Verde Unit 2, the main steam effluent monitors (RI-5421, RI 5422) may read N16 immeAately following SG tube rupture and prior to reactor trip. However, given the short half-life of N16, this l

should clear within the first minute following reactor trip.

Dose consequences can be determined by use of ERPIP 822, Initial Dose Assessment Manual Calculation Methods, or by use of ERPIP 823, Dose Assessment Computer. Dose assessment will be performed in accordance with the new 10 CFR 20 scheduled to take effect January 1,1994.

Calvert Cliffs EAL Basis Document R:23 Rev.7

1 l

RADIOACTIVITY RELEASE Thus, EAL 3 is written as:

Dose Assessment Determines Integrated Accident Forecast Dose Off-Site is AT LEAST 1 rem (EDE +

CEDE) Or 5 rem CDE Thyroid This corresponds to doses of 10 mSv (EDE+ CEDE) and 50 mSv CDE Th>Toid, respectively.

I Source De= ave / References /Cabd=*iane: '

l. System Descriptions No.15, Radiation Monitoring System  ;

i

2. Emergency Response Plan implementation Procedures ERPIP-810, Main Steam Radioactivity Release Estimate l

ERPIP-821. Accidental Radioactivity Releese Monitoring and Sampling Methods l ERPIP-822, Initial Dose Assessment i.ianual Calculation Methods ERPIP-823, Dose Assessment Computer

3. Radioactivity Release Emergency Action Levels, J.B. McIlvaine, JSB Associates, Inc., September 1990

4. BG&E Internal Memorandum, J. R. Hill (Nuclear Plant Operations) to R. L. Wenderlich, CE Operations Subcommittec Meeting -Trip Report, April 16,1993

5. 10 CFR 20, Standards for Pro'ection Against Radiation; Final Rule,56 FR 23360, May 21,1991 i

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Calvert Cliffs EAL Basis Document R:24 Rev.7

l FISSION PRODUCT BARRIER DEGRADATION 1

Cahert Cliffs EAL Basis Document Rev.7 )

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FISSION PRODUCT BARRIER DEGRADATION 1

Emergency Cla**inemtian I.evel: UNUSUAL EVENT Anoticable Ooerational Modes: 1, 2, 3, 4 Calvert Cliffs Initiating Conditig, '

BUI less OR Potential loss of CNTMT Barrier NUMARC Initiating Condition:

1 1

FUI ANY Loss or ANY Potential Loss of Containment l

Bamgr: Containment

{

l This JC is entered based on the Fission Barrier Reference Table EAL,s discussed below. l l

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Calvert Cliffs EAL Basis Document B:1 Rev.7

FISSION PRODUCT BARRIER DEGRADATION Emergency Claumcation Level: UNUSUAL EVENT Anolicable Operational Modes: ALL Calvert Cliffs Initiating Condition:

BJ2 RCS Ixakage NUMARC Recognition Category: System Malfunction NUMARC Initiating Condition:

SUS RCS Leakage Barner RCS NUMARC Generic Emernency Action Levels Example Emergency Action Level:

1. The following conditions exists:

a. Unidentified or pressure boundary leakage greater than 10 gym.

OR

b. Identified leakage greater than 25 gym NUMARC Generic 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 unidentified or pressure boundary leakage was selected because 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 sia Fission Product Barrier Degradation <EALs or the IC QA2, Inability to Maintain Plant in Cold Shutdown >.

Only operating epional-medes in wand hich there is fuel is in the reactor coolant sy:; tem and the system is pressurized are specified.

NUMARC Ouestions and Answers. June 30.1993 (General)

12. Questions indicated a desire to allow normal Technical Specification Action times associated with RCS leakage to identify and/or stop a leak that is above the Unusual Event threshold of SUS. For example, under NUREG 0654 guidelines, with > 10 gym leakage, we currently have the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed by tech specs to identify and reduce the leakage hg[gre the event must be classified. NUMARC guidance requires immediate classification of the event without allowing the operators time to identify and reduce the leakage.

The thresholdfor declaration has been significantly raisedfrom typically 1 gpm to 10 gpm unidenafied leakage and 10 gym to H spm idennfied leakage. A leak of such magnitude is consistent udth an Unusual Event and should be declared immediately. Geditfor the action statement time in deferring an emergency declaration should only be given naen leakage exceeds technical specification limits but has notyet exceeded the Unusual Event threshold.

Calvert Cliffs EAL Basis Document B:2 Fev.7

FISSION PRODUCT BARRIER DEGRADATION NUMARC Ouestions and Answers. June 30.1993 (System Malfunction)

2. Why is the IC of SU5 included as a system malfunction rather than a fission product barrier failure? From a human factors viewpoint, this treatment is inconsistent and could confuse the operator during classification.

Thefission product barrier reference table is intended to address actual or potentialfailures of the RCS. It does not distinguish between pressure boundary leakage and other leakage paths.

Pressure boundary leakage is distinguished in SUS by having a lower thresheid than other types ofleak Age. Any RCS leakage that meets the thresholds SUS but remains within the capability of one normally configured charging pump nill not lead to the degradarlan of the remaining)ission product barriers. This is not considered an actual or potentialfailure of the i RCS requiring the declaration ofan Alert. '

I l

3. Some plants do not have instrumentation that will directly detect leak rates of 10 or 25 gpm l specifielin SUS. How can they satisfy this EAL? l l For PWRs, various instrumentation readings may be recorded over a specsfied time (typically .

four hours) to yield a calculated leak rate. For BWRs, instantaneous leak rate detection and  !

measurement should be used if availabic.

l Plant-Snecific Information:

Improved Technical Specification Section 3.4.13 specifies allowable RCS leakage as:

l a. No Pressure Boundary Leakage

b. I GPM unidentified leakage

c. I GPM total primary-to-secondary leakage through both steam generators and 100 GPD through any one steam generator

d. 10 GPM identified leakage from the RCS l

l STP-0-27-1/2 is the daily surveillance test procedure that the operators use to measure the amount of RCS leakage.

[ The RCS GROSS leakage rate is based upon the following parameters: Tavg, RC Makeup Integrator reading, Boric l' Acid Integrator reading, Diversion integrator reading, volume control tank level, pressurizer pressure and

! pressurizer level.

If the RCS GROSS leakage rate is calculated to be GREATER THAN 11.0 GPM, AOP-2A is implemented. This

) 11 GPM threshold corresponds to the net RCS make-up from one charging pump in the normal CVCS alignment l

(44 GPM charging flow minus the total flow from reactor coolant pump seal leak-off and minimum letdown).

l If the RCS GROSS leakage rate is calculated between 1.0 GPM and 11.0 GPM, the difference between RCS l GROSS leakage rate, Reactor Coolant Drain Tank (RCDT) inleakage, safety injection tank (SIT) outicakage, Quench Tank (QT) inleakage, and the calculated SG leakage from GP434 CP-4M. L' S i" _:: b GRE ^.5R

^" !." G"', then the CRS is notified and with his approval, AOP-2A is implemented.

Calvert Cliffs Units 1 and 2 are Combustion Engineering designed reactors. These reactors use a programmed pressurizer water level that varies as a function of T "8 and load. The Chemical Volume Control System includes three fixed flow positive displacement charging pumps and a varirble letdown system. Each charging pump has a capacity of 44 GPM. The letdown system valves regulate letdown flow from 28 GPM to 128 GPM. The nominal configuration is one charging pump with ~40 GPM letdown flow. The letdown flow is varied as necessary to maintain programmed pressurizer level. Additional charging purrps are automatically started when necessary to l maintain pressurizer level.

Calven Cliffs EAL Basis Document B:3 Rev.7

i i

FISSION PRODUCT BARRIER DEGRADATION j AOP 2A, Excessive Reactor Coolant Leakage, is implemented if any entry conditions are met; this includes the results of STP-0-27-1/2, Reactor Coolant Leakage Evaluation. STP-0-27-1/2 will indicate leakage in excess of Improved Technical Specification 3.4.13 allowable limits. The purpose of AOP-2A is to provide direction and actions to be taken for loss of RCS lavestory for all operating conditions except reactor trip related events 1 and shutdown cooling. If tbc unit is on shutdown cooling, then AOP-3B, Absormal Shutdown Cooling is l implemented for loss of RCS inventory. If RCS leakage occurs while the unit is om shutdown cooling, an unusual event is declared if AOP-3B can not be esited within 15 minutes (see equipment failure, Calvert Cliffs Initiating Condition, QUI, Umplanned less of Any Function Needed to Maintain Cold Shutdown).

Control room personnel require approximately 5 to 15 minutes to implement AOP-2A if RCS leakage exceeds the capacity of one charging pump. In general, Calvert Cliffs does not distinguish between identified or unidentified i leakage when AOP-2A is implemented. Per AOP-2A, ifleakage exceeding the capacity of one charging pump (!1 GPM leakage with minimum letdown flow or greater than 39 GPM with letdown isolated) could not be isolated, then the reactor must be shutdown (tripped) and cooled down. If the leakage does not exceed the capacity of the remalaing available charging pumps, then the event terminates at unusual event under Calven Cliffs Initiating Condition BU2, RCS hakage. Should the leakage exceed available CVCS capacity the event is escalated to alen via the fission barrier degradation EAL, RCB4, Coolant hakage and its associated potential loss EAL, RCS hakage Exceeds Available CVCS Capacity.

If AOP-2A is implemented for RCS leakage exceeding the capacity of one charging pump, the procedust will require the operator to shut the reactor down and enter EOP-0, Post Trip lamediate Actions. From EOP-0, the operator can proceed to EOP-5,less of Coolant Accident; EOP-6, Steam Generator Tube Rupture; or EOP-8, Functional Recovery Procedure and the event is escalated to Alen via fission barrier degradation Calven Cliffs EAL, RCB4, Coolant Leakage, if RCS leakage is less than the capacity of one charging pump, STP-0-27-1/2 would be performed to determine the leak rate and the reactor would be maintained at power. It requires approximately 3 to 6 Luurs to perform STP 27-1/2 to determine the amount of unidentified leakage.

Calvert Cliffs EALs have been written to be consistent with procedural requirements. These Improved Technical Specification 3.4.13, RCS Operational ILeakage rates are very similar to the NUMARC generic leakage rate references. AOP-2A specifies certain flow paths that can be isolated to terminate RCS leakage. Ifisolation of the leakage path is successful (e.g., isolating a leaking pressurizer power operated relief valve), reactor operation can continue and this EAL does not apply. However, if RCS leakage could not be isolated, then under these conditions the reactor would have to be placed in cold shutdown t i; . in accordance with technical specifications. If the LCO for Improved Technical Specifications 3.4.13, RCS Operational hakage, is exceeded, the plant is placed la cold shutdown or bot standby. Since neede change is prescribed for exceeding the LCO, it is used to qualify the use of AOP-02A as a criteria for declaring U.E. The EAL language was picked to assure that: (1) leakage is greater than net RCS make-up flow threshold of 11 GPM is used as an entry criterion, and (2) reference to sSuch leakage is to that which can eeuld not be isolated in accordance with procedural requirements.

In response to the Generic EAL, Calvert Cliffs EAL is written:E=, S: C&c:M CE": E?.L k :t= :,::

AOP-2A, Excessive Reactor Coolant i enkage, is Implemented For RCS Leakage Esseedaag Within the Capacity of One Charging Pump AND a Mode Change Rosetor Sheidewe is Required NUREG_1449 raises concerns regarding events invohing leakage through RCS temporary boundaries. RCS leakage EALs apply to all operational modes at Calvert Cliffs. This will assure that leakage is appropriately addressed for cold shutdown and refueling modes and address NRC concerns about leakage through temporary RCS boundaries as they apply to EALs.

Calvert Cliffs EAL Basis Document B:4 Rev.7

i l FISSION PRODUCT BARRIER DEGRAE)ATION i

Source Documents / References /Caloitatians:

l 1. Technical Specifications

+

ITS 3.4.13. Reactor Coolant System Operational Leakage

2. Abnormal Operating Procedures AOP-2A, Excessive Reactor Coolant Leakage

3. Surveillance Test Procedure (STP) O-27-1/2, RCS Leakage Evaluation

4. NUREG 1449, Shutdowit and Low-Power Operation at Commercial Nuclear Power Plants in the United States, Draft for Comment, February 1992 f

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l l Calvert Cliffs EAL Basis Document B:5 Rev.7

FISSION PRO 2UCT CARRIER EEGRADATION Emergency Classification Level: UNUSUAL EVENT Apolicable Operational Modes: ALL Calvert Cliffs Initiating Condition:

BU3 Fuel Clad Degradation NUMARC Recognition Category: System Malfunction NUMARC Initiating Condition:

SU4 Fuel Clad Degradation Barrier: Fuel Clad NUMARC Generic Emereency Action Levels Example Emergency Action level: (1 or 2)

1. (Site-Specific) radiation monitor readings indicating fuel clad degradation greater thtn Technical Specification allowable limits.

2. (Site-Specific) coolant sample activity value indicating fuel clad degradation greater than Technical Specification allowable limits.

NUMARC Generic 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. < Generic > EAL 1 addresses (Site-Specific) radiation monitor readings such as failed fuel monitors, etc., that provide indication of fuel clad integrity.

< Generic > EAL 2 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 EALs>.

NUMARC Ouestions and Answers. June 30.1993 (Fission Product Barriers - PWR)

None NUMARC Ouestions and Answers. June 30.1993 / General)

7. If an event occurs that results in the loss of a Limiting Condition for Operation that is recovered within the Technical Specifications Action Statement period, should it be necessary to enter the Emergency Plan?

In general, no emergency declaration is necessary sf an LCO is satisfied within the time limit of the Adion Statement. If a plant is not brought to a required operating mode within that time limit, an Unusual Event should be declaredpursuant to SU2.

Calvert Cliffs EAL Basis Document B:6 Rev.7

I FISSION PRUDUCT BARRIER DEGRADATION i

Plant-Snecific Information:

A significant rise in the count rate on the Activity Monitor or valid actuation of the " RADIATION MONITOR l LEVEL HI" alarm can be due to either fuel clad failure or to crud burst. In accordance with AOP 6A, the response to high RCS activity level is to notify Plant Chemistry to perform a sample analysis to determine what radionuclides caused the radiation alarm. This means that the monitor indications are not sufficient alone to determine whether fuel clad damage has occuned at Calvert Cliffs. Thus, < Generic > EAL 1 is not appropriate for use at Calvert Cliffs.

Clad damage is determined from specific activity levels contained in reactor coolant samples. Per AOP-6A, when RCS activity is less tham Chemistry ";' " "^"iG ."'; Action Level 4- 1 valaes, the operator may return to the appropriate operating pacedure. . Per CP-204, Chemistry Action level 1 is for specific activity levels gnater than 0.5 pCi/ gram I* DEQ or greater than 50/Ebar pCi/ gram of gmse radioactivity. N E E;n 'r '*-(l* DEQ) d e '-- 6 Improved Technical Specifications Section 3.4.15 requires the .

specific activity of the reactor coolant to be withis ""2. P r ec: I

a. Mc .xx ^^- 1 Ci/ gram i DEQ.

b Nc: nx ^-- 100/Ebar pCi/ gram of gross radioactivity.

The specific activity of the reactor coolant may be as high as the limits defined by Improved Technical Specification Figure 3.4.15-1 for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The lowest limit for this figure corresponds to 60 pCi/ gram 1*

DEQ. Scaling down from the value shown for FCB3, Radiation, corresponding 1500 pCi/ gram i DEQ an RCS sample dose rate at one foot is computed as shown in tiu: equation below.

RCS Sample Reading For 60 Ci/ gram 1131 DEQ Refer to EAL FCBS , Radiation BU3 Value = 60 uCi/aram x 168 mrem /h = 6.7 mrem /h 1500 pCi/ gram Read as 6 mrem /h (.06 mSv/h)

la msponse to Generic EAL 1, Calvert Cliffs EAL 1 is written

Thr. 6 EAL ! 5:wnneeHis-l Dose Rate at One Foot from RCS Sample of AT LEAST 6 mrem /h l This corresponds to a dose rate of 0.06 mSv/h.

Improved Technical Specification 3.4.15 Reactor Coolant System - Specific Activity is addressed by EAL 2:

In msponse to Generic EAL 2, Calvert Cliffs EAL 2 is written: ThusEAL 2 i::t e Fuel Clad Degradation Indicated by RCS Sample Activity GREATER THAN Improved Tech. Spec 3.4.15 Allowable Limits AND Cooldown is mquired.

i l Calvert Cliffs EAL Basis Document B:7 Rev.7 l

t FISSION PRODUCT BARRIERIEGRADATION l Source Documents / References / Calculations:

1. Technical Specifications ITS 3.4,15, Reactor Coolant System - RCS Specific Actisity f i

2. Abnormal Operating Procedures AOP-6A, Response to High RCS Actisity

}

3. BG&E Fuel Degradation EALs Calculation Worksheet, JSB Associates, February 18,1993 i

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! Calvert Cliffs EAL Bar!3Document B:8 Rev.7 l

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FISSION PRODUCT BARRIER DEGRADATION Emeraency Classification Level: ALERT Anolicable Oncrational Modes 1,2,3,4 Calvert Cliffs laitiatina Condition:

BAl Loss Or Potential Loss of EITHER Fuel Clad Barrier OR RCS Barrier NUMARC Initiatine Condition:

FAI ANY Loss or ANY Potential Loss of EITHER Fuel Clad OR RCS Bamer FuelClad,RCS l This IC is entered based out the Fission Barrier Reference Table FALs discussed below. l Calvert Cliffs EAL Basis Document B:9 Rev.7

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FISSION PRODUCT DARRIER DEGRADATION l Emernency Classification Level: SITE F'fERGENCY Anolicable Operational Modes: 1, 2, 3, 4 i Calvert Cliffs laitiating Condition:

BS! Loss Or Potential Loss of ANY Two Barriers l NUMARC Initiatina Condidgg:

1

! FS1 Loss of BOTH Fuel Clad AND RCS OR Potential Loss of BOTH Fuel Clad AND RCS OR Potential Loss of EITHER Fuel Clad OR RCS AND Loss of ANY Additional Barrier l

l Barner Fuct Clad, RCS, Contamment l

l Calvert Cliffs logic is simplified from the generic NUMARC logic based on the following considerations:

1. Human Factors - It is easier to understand and to remember the escalation from Alert to Site Emergency to General Emergency using the simpler logic.

l 2. Coiiieid.ciisiveness - A comparison was made of the combinations of tarrier losses and potentiti loves corresponding to Site Eme.rgency between the Calvert Cliffs logie and the NUMARC logic. This comparison is shown by Tables B-1 and B 2 below. All six NUMARC barrier loss / potential loss combinations (Table B-7) are addressed in the Calvert Cliffs logic that addresses 12 combinations of barrier loss / potential loss (Table B-1).

3. hwian of SG Tube Runture Seouences - This logic change is consistent with NUMARC's intended scheme for classifying steam generator tube rupture sequences. No other sequences are significantly afected by the Fission Barrier EAL logic change. IC BU2, RCS Leakage, addresses smaller sized SG tube leakage that exceeds Tech Spec allowable but fall well within normal makeup capacity. SG tube haks in

. this category should result in declaration of an Unusual Event. Fit.sion Barrier EAL RCB4, Coolant Leakage, addresses tube breaks with leak rates that are somewhat larger than normal makeup capacity, but are readily controlled in accordance with the EOPs. SG breaks of this category result in declaration of an Alert due to potential loss of the RCS Barrier. Larger spectrum tube rupture events that can lead to SG overfill and prolonged releases off-site are addressed by Fission Barrier EAL CNB4, Coolant Leakage.

Leaks of this size result in simultaneously achieving the thresholds of RCB4 and CNB4 result in declaration of a Site Emergency due to potential loss of the RCS barrier and loss of the CTMT barrier.

Escalation to General Emergency would be based on further degradation'of the RCS barrier and the subsequent potential loss of the Fuel Clad barrier.

l This JC is entered based on the Fission Barrier Reference Table EALs discussed below. l l

l l

l

. Calvert Cliffs EAL Basis Document B:10 Rev.7

FISSION PRUDUCT EARRIER EEGRADATION Loss or Potential Lo:s of ANY Two Barricts Fuel Clad RCS Containment Potential Potential Potential Loss Loss Loss Loss Loss Lcas

1. X X

2. X X

3. X X

4. X X

5. X X

6. X X

7. X X

8. X X

o. X X

'10. X X I

11. X X

12. X X I i

f Calvert Cliffs EAL Basis Document B:11 Rev.7

FISSI"N PRODUCT CARRiiR DEGRADATION 1

Loss of BOTH Fuel Clad AND RCS OR Potential 1.oss of BOTH Fuel Clad AND RCS OR Potential Loss ofEITHER Fuel OR RCS, AND Loss of ANY Additional Barrier '

Fuel Clad RCS Containment Potential Potential Potential Loss Loss Loss Loss Loss Loss

1. X X '

2. X X 3.

4.

5. X X

6. X X

7. X X 8.

9.

10.

11. X X 12.

I l

Calvert Cliffs EAL Basis Docunient B:12 Rev.7

1 FISSION. PRODUCT BARRIER DEGRADATION Emeraency C1==emention Level: GENERAL EMERGENCY AI5dicable Operational Modes: 1, 2, 3, 4 I

, falvert Cliffs Initiatina Condition:

BG1 Loss of Two Barriers AND Potential Loss of Third Barrier NUMARC Initiating Condition:

FG1 Loss of ANY Two Bamers AND Potential Loss of Third Barrier Bamer Fuel Clad, RCS, Containment l l This IC is entered based on the Fission Barrier Reference Table EALs discussed below. l Calvert Cliffs EAL Basis Document B:13 Rey,7

FISSION PRODUCT BARRIER CEGRADATION FUEL CLAD BARRIER EALs Calvert Cliffs EAL Basis Document B:14 Rev.7

FISSION PRODUCT CARRIER DEGRADATION Emeraency Classification Level: PER FISSION BARRIER REFERENCE TABLE Apphcable Operational Modes 1,2,3,4 Calvert Cliffs Esi_a Action Level:

FCBI Safety Function Status /Furstional Recovery NUMARC Esiaa Action Level:

Fuel Clad 1 Critical Safety Function Status Loss - Core Cooling-RED l

Potential Loss - Core Cooling-ORANGE or Heat Sink-RED '

BarDgr: Fuel Clad - The Fuel Clad Barrier is the < zirconium alloy > tubes that contain the fuel pellets.

NUMARC Generic Basis:

This < Generic > EAL is for PWRs using Critical Safety Function Status Tree (CSFST) monitoring and functional recovery procedures. < >

Plant-Soccific Information:

l Calvert Cliffs does not use Critical Safety Function Status Trees. Calvert Ciiffs uses Safety Function Status Checks developed by the Combustion Engineering Owners' Group (C-E OG) which are based on logic similar to that used for CSFSTs developed for Westinghouse PWRs. However, there is no Safety Function Status Check condition that corresponds directly to Core Cooling - RED path as a loss EAL. Thus, the < Generic > loss EAL is incorporated into l FCB2. This is better addressed by core exit temperature readings as shown in FCB2, Temperature, below.

As stated above, the Potential Loss EAL should correspond to loss of subcooling conditions and the Loss EAL should correspomi to conditions indicating significant superheat. A resiew was made of the Emergency Operating Procedure basis information contained in CEN-152. Emergency Procedure Guidelines, to determine the applicable l- Calvert Cliffs symptoms corresponding to the generic conditions of interest, i.e., symptoms of inadequate core i cooling sequences leading to core heatup and significant fuel clad damage.

Satisfying the appropriate RCS and Core Heat Removal criteria assures that adequate core cooling exists.

Following a LOCA, there are two paths initially aveilable for RCS heat removal: heat transfer to the secondary side via the steam generators, and heat transfer via the fluid flowing out the break. Large break LOCAs have sufficient fluid flowing out the break to pmvide adequate heat removal. Snull break LOCAs do not have suf5cient fluid flowing out of the break to provide adequate heat removal. Therefore, under these conditions steam generator heat removal is required in addition to break flow to assure that there is adequate core heat removal. For the largest breaks, the RCS depressurizes to an equilibrium pressure with containment. In this condition, the RCS fluid is at a lower temperature than that of the steam generators.

The steam generators, therefore, act as a heat source, superheating any steam in the RCS which may be flowing through the steams generators to the break. By cooling down the steam generators, heat input to the RCS is reduced. EOP-5, Loss of Coolant Accident, does not distinguish between large and small break LOCAs, and l requires steam generator heat removal be maintained at all times during a LOCA, if at all possible. Once RCS l pressure and temperature are reduced, RCS heat removal can be provided by the Shutdown Cooling System (SDCS). Once the SDCS is placed in service, the steam generator heat sink capability is no longer necessary.

l l

l Calvert Cliffs EAL Basis Document .B:15 Rev.7

1 FISSION PRO;UCT 2ARRIER DEGRASATIUN In the event that the liquid inventory in the steam generators is not adequate to remove decay heat, a source of feedwater is unavailable, and the SDCS is not in senice, the operator will transition to EOP-8, Functional Recovery Procedure. If RCS cooling through the steam generators cannot be restored, then the operator is instructed to implement once through RCS Cooling via the (pressurizer) PORVs before depleting the remaining steam generator inventory.

The applicable ar~?a_aca criteria for Core and RCS ficat Removal are shown on the Safety Function Status Checks. They are:

Steam Generators Available for RCS Heat Removal

1. Adequate secondary side liquid inventory in at least one steam generator as indicated by level between

-170 and +30 inches, and j

2. Adequate source of feedwater available to assure continued liquid inventory available as indicated by Condensate Storage Tank level greater than 5 feet, and

3. Steam 'icnerators acting as effective heat sink as indicated by Cold Leg Temperatures (TCOLD) constant or lowering.

Primary Side Conditions for Core and RCS Heat Removal

1. Adequate core heat removal as indicated by Core Exit Thermocouple readings less than superheated, and

2. Either of the following:

+

Natural circulation established as indicated by the temperature difference between Hot Leg Temperature (THOT)and TCOLD of between 10*F and 50'F or Forced circulation effective as indicated by THOT-T COLD ess l than 10*F.

Based on the above discussion, the Potential Loss EAL is written as:

EOP-8, Functional Recovery Procedure Can NOT M-et Core and RCS Heat Removal Acceptance Criteria AND Shutdown Cooling is NOT In Senice Can NOT is used because the final safety function status is of concern, not merely the inability to meet certain intermediate status check conditions.

In service means that the SDCS is in the proper configuration for RCS heat removal (SDCS isolation valves open,

' LPSI pumps operating, etc.) and is considered " operable" ar, defined in the Calvert Cliffs Improved Technical Specifications Section 1.1.

Source Dx =- :JRii- =/Chlations

1. Emergency Operatmg Procedures

+ EOP-5, Loss of Coolant Accident EOP-8, Functional Recovery Procedure

2. CEN 152, Emergency Procedure Guidelines

• L Calvert Cliffs EAL Basis Document B:16 Rev.7

FISSION PROIUCT BARRIER DEGRADATION Calvert Cliffs Emeraency Action Lael:

1 FCB2 Temperature NUMARC Emies.cv Action Imel:

1 Fuel Clad 3 Core Exit Thermocouple Readings  !

Loss - GREATER THAN (Site Specific) 'F 1 a

Potential Loss - GREATER THAN (Site-Specific) *F NUMARC Genene Basis The Loss EAL (Site-Specific) reading should correspond to significant superheating of the coolant. This value typically corresponds to the temperature reading that indicates core cooling - RED in Fuel Clad Barrier EAL 1, usually about 1200'F.

The Potential Loss EAL (Site-Specific) reading should correspond to loss of subcooling. This value typically corresponds to the temperature reading that indicates core cooling - ORANGE in Fuel Clad Barrier EAL 1, usually about 700 to 900*F.

Plant-Soecific Information:

Calvert Cliffs uses the generic value of 1200 'F as the fuel clad " loss" indicator. This is consistent with Attachment 3 of ERPIP 802, Core Damage Assessment Using Core Exit Thermocouples. This shows that at Calvert Cliffs, clad rupture due to high temperature is not expected for core exit thermocouple teruperature readings of less than 1200*F.

Thus, the Loss EAL is written as:

l Valid Core Exit Thermocouple Readings GREATER THAN 1200'F l Valid means that the thermocouple channel (s) are considered to be operable in accordance with the Technical Specifications.

For consistency with Calvert Cliffs EOPs. the Potential Loss EAL is written as:

l Valid Core Exit Thermocouple Readings Indicate Superheat ]

Source DocumentdReferences/ Calculations

1. Emergency Response Plan implementation Procedures

a. ERPIP-802, Core Damage Assessment Using Core Exit Thermocouples

2. . Emergency Operating Procedures

+ EOP-5, Loss of Coolant Accident EOP-8, Functional Recovery Procedure Calvert Cliffs EAL Basis Document B:17 Rev.7

l FISSICN PRODUCT BARRIER DEGRADATION 1 l

)

Calvert Cliffs Emeraency Action Level:

FCB3 Radiation NUMARC Emernency Action Level:

Fuel Clad 2 Pnmary Coolant Activity Level

+

Loss - Coolant Activity GREATER THAN (Site Specific) %: 'e

+

PotentialLoss-Not Applicable Fuel Clad 5 Containment Radiation Monitoring

+

Loss - Containment Radiation Monitor Reading GREATER THAN (Site-Specific) R/Hr PotentialLoss-Not Applicable NUMARC Generic Basis:

[ Fuel Clad 2]

This (Site-Specific) value corresponds to 300 pCi/cc 1131 equivalent. Assessment by the NUMARC EAL Task l Force indicates that this amount of coolant activity is well above that expected for iodine spikes and corresponds to I about 2% to 5% fuel clad damage. This amount of clad damage indicates significant clad heating and thus the Fuel j Clad Barrieris considered lost. '

There is no equivalent Potential Loss EAL for this item.

[ Fuel Clad 5)

The (Site-Specific) reading is a value which indicates release of reactor coolant, with an elevated actisity indicative l of fuel damage, into the containment. The reading should be calculated assuming the instantaneous release and dispersal of reactor coolant noble gas and iodine inventory associated with a concentration of 300 pCi/gm dose equivalent lj33 nto i the containment atmosphere. Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within technical specifications and are ther: fore indicative of fuel damage (approximately 2 - 5% clad failure depending on core inventory and RCS volurre.) This value is higher than that specified for RCS Barrier Loss <EAL 2>. Thus, this EAL indicates a loss of bota the fuel clad banier and the RCS barrier <and would indicate at least a Site Emergency classification >.

There is no Potential Loss EAL associated with this item.

Plant-Snecific Information:

The site specific value was determined by calculating various coolant radionuclide concentrations postulated to result from 5% gap release at Calvert Cliffs. This corresponds to about 1500 pCi/cc DEQ Ig31,Under those conditions, post accident sampling using 12.5 ml pressurized bomb samples would be used. The corresponding values for a post accident sample are:

+

42 mrem /h (0.42 mSv/h) at i foot due to radio-iodines (unpressurized sample)

+

2.2 mrem /h (0.022 mSv/h) at I foot due to noble gases

+

44 mrem /h (0.44 mSv/h) at 1 foot for pressurized sample Therefore, whether the sample is pressurized or not makes little difference, as the largest contribution to the dose rat:: after I hour decay is from the radio-iodines.

Thus, Loss EAL 1 is written as:

l Dose Rate at One Foot from Post Accident Sample of AT LEAST 40 mrem /h l Calvert Cliffs EAL Basis Document B:18 Rev.7

4 FISSION PROSUCT BARRIER DEGRADATION This corresponds to a dose rate of 0.4 mSv/h. Per Reference 3, this also results in a dose rate at one foot from an unshieldedRCSsample of about 168 mrem /h. (1.7 mSv/h).

The plant-specific containment monitor radiation values were determined from ERPIP-801, assuming 5% fuel clad damage. This procedure can be used to determine the containment radiation monitor readings resulting from 5%

fuel clad failure using Attachment 2 and assuming no power correction.

The radiation monitor reading (1-RI 5317A & B,2 RI 5317 A & B) corresponding to 5% fuel clad failure at 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> aAct shutdown is about 3,500 rem /h (35 Sv/h).

Thus, Loss EAL 2 is written as:

l Valid RI-5317A/B Reading of AT LEAST 3,500 rem /h Within 2 Hours After Reactor Shutdown l' Valid means that the applicable radiation monitoring channel (s) are considered to be operable in accordance with the Technical Specifications.

The EAL uses the value of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the initiating event (assumed to closely correspond to the time of reactor shutdown) for simplicity in presentation to the Shift Supervisor acting as the Site Emergency Coordinator (SEC). f The two hour point was also picked because it allows ample time for transfer of the SEC duties to outside the ]

Control Room.

Technical support personnel can also use ERPIP-801, -802, -803, and .804 to determine core damage. Thus, Loss EAL 3 is written as:

l AT LEAST 5% Fuel Clad Damage as Determined From Core Damage Ameestment l For fuel clad loss indicated by radiochemical analysis: Calvert Cliffs reactor coolant concentrations at the NUMARC value (300 Ci/cc DEQ 1131) correspond to about 1% clad failure. This is below the NUMARC clad damage range of 2-5% and is not beyond the range of a worst case 1151 spike following a reactor trip. To ensure emergency declarations do not result from trip induced iodine spikes, the low end of the NUMARC clad damage range was selected for site specific application. As addressed presiously, calculations from various coolant radionuclide concentrations for 5% gap release correspond to about 1500 Ci/cc DEQ 1131 Ratioing this to 2%

clad loss results in reactor coolant concentrations corresponding to 600 Ci/cc DEQ 1151 Thus, Loss EAL 4 is wTitten as:

l Coolant Activity Greater Than 600 Ci/cc DEQ 1851 l Source Da-a'</ References / Cal & =*ione:

1

1. Tec'.mical Specifications

+

ITS Figure 3.4.15-1, Dose Equivalent I-131 Primary Coolant Specific Actisity Limit Versus Percent of Rated Power With the Primary Coolant Specific Actisity > 1.0 pCi/ Gram Dose Equivalent I 131

2. Emergency Response Plan Implementation Procedures

+

ERPIP-801, Core Damage Assessment Using Containment Radiation Dose Rates

+

ERPIP-802, Core Damage Assessment Using Core Exit Thermocouples

+

ERPIP-803, Core Damage Assessment Using Hydrogen ERPJ-804, Core Damage Assessment Using Radiological Analysis of Samples

3. BG&E Fuel Degradation EALs Calculation Worksheet, JSB Associates, February 18,1993 i

Calvert Cliffs EAL Basis Document B:19 Rev.7 I

FISSIDN PRO 3UCT BARRIER DEGRADATION Calvert Cliffs Eiisie.cv Action Level:

FCB4 Reactor Vessel Water Level NUMARC Emeraency Action Level:

[

Fuel Clad 4 Reactor Vessel Water Level Loss-Not Applicable Potential Loss - Level LESS THAN (Sitc-Specific) Value Bamer FuelClad NUMARC Generic J}giig:

There is no " Loss" EAL corresponding to this item because it is better covered by the other Fuel Clad Barrier

" Loss" EALs.

i The (site-specific) value for the " Potential Loss" EAL corresponds to the top of the active fuel. For sites using l

CSFSTs, the " Potential Loss" EAL is defined by the Core Cooling - ORANGE path. The (site-specific) value in i this EAL should be consistent with the CSFST value.

Plant-Soecific Information:

As part ofits Inadequate Core Cooling instrumentation, Calvert Cliffs uses a reactor vessel level monitoring system (RVLMS) that is displayed to the operators and can measure water level from the top of the fuel alignment plate to -

the top of the reactor vessel head. The bottom of this instrument's span closely corresponds to the (Site Specific) water indication of Potential Loss used by NUMARC. At the bottom of the pressurizer, the RVLMS initiates the first alarm. From AOP-3B, the transition to the EOPs is contingent upon the decrease of the pressurizer level. Per AOP-3B, Attachment 14, a 29" RVLMS indication corresponds to the bottom of the hot leg elevation and is the sixth (6th) RVLMS alarm. The threshold corresponding to the bottom of the hot leg with a trend to zero thus is chosen because it is readily recognizable by operators (i.e., consistent declaration) and indicates a severe loss of inventory.

Thus the Potential Loss EAL is written as:

l Valid RVLMS Reading at 29 Inches and Trending Toward 0 l Valid means that the appl; cable vessel level monitoring channel (s) are considered to be operable in accordance with the Technical Specifications.

Source DacumanWReferences/ Calculations:

1. Abnormal Operating Procedures

• AOP-3B Attachment 14, RCS Levels

2. Updated Final Safety Analysis Report Section 7.5.9, Inadequate Core Cooling Instrumentation l

l l

Calvert Cliffs EAL Basis Document B:20 Rev.7

FISSION PRODUCT BARRIER DEGRADATION Calvert Cliffs Emeraency Action Level:

FCBS SECJudgement NUMARC Esasecv Action 12 vel:

FuelClad6 Other(Site-Specific) Indications Fuel Clad 7 Emergency Director Judgement i

NUMARC Generic Basis j

[ Fuel Clad 6]

This EAL is to cover other (site-specific) indications that may indicate loss or potential loss of the Fuel Clad barrier, including indications from containment air monitors or any other (site-specific) instrumentation. 1

[ Fuel Clad 7]

This EAL addresses any other factors that are to be used by the <SEC> 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 <SEC) judgement that the barrier may be considered lost or potentially lost. (See IC <EGI, Prolonged Station Blackout > for additional information.)

J ant-Snecific Information Other indications were also considered and no additional reliable indications of fuel clad loss or potential loss could be determined. Thus, the generic "Other (Site-Specific) Indications" Fuel Clad EAL does not apply to the Calvert Cliffs Plant.

Per the Emergency Response Plan, the Site Emergency Coordinator (SEC) is the title for the emergency director function at Calvert Cliffs. SEC considerations for determining whether any barrier Loss or Potential Loss include imminent degradation, barrier monitoring capability, and dominant accident sequences.

Anticipated degradation of ANY Barrier within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> based on a projection of current safety system performance is considered to be imminent Barrier degradation. This must be considered by the SEC for timely declaration of a General Emergency. The term imminent refers to the inability to reach final safety acceptance before completing all l checks.

Decreased barrier monitoring ability from loss of/ lack of reliable indicators r.tust also be considered by the SEC when judging whether a Barrier may be Lost or Potentially Lost. This assessment should also include instrumentatic. operability concerns, readings from portable instrumernation, and consideration off-site monitoring results.

Dominant accident sequences will lead to degradation of all Barriers. Such sequences can lead to entry into EOP-8, Functional Recovery Procedure. The SEC should also consult Station Blackout and ATWS ICs, as appropriate, to assure timely emergency classification declaration.

Thus, the EAL is written as:

Any Condition Which in the SEC's Judgement Indicates less or Potential Loss of the Fuel Clad Barrier Based on:

Imminent Barrier Degradation Due to Safety System Performance

- Degraded Ability to Monitor Barrier Source Dws es/ References /C=1~1=%==:

1. Emergency Response Plan Calvert Cliffs EAL Basis Document B:21 Rev.7

i FISSION PRODUCT BARRIER DEGRADATION l

J

\

i l

l 4

I 4

l i

RCS BARRIER EALs 1 I

l l l

l I

I i

Q Calvert Cliffs EAL Basis Document B:22 Rev.7

FISSION PRODUCT BARRIER DEGRADATION Eiwim.cv Cla=** tion Level: PER FISSION BARRIER REFERENCE TABLE

- Anoticable Onerational Modes: 1, 2, 3, 4 Calvert Cliffs Emeraency Action Level:

RCBI Safety Function Status / Functional Recovery NUMARC Emeraency Action Level:

RCS 1 Critical Safety Function Status Loss-Not Applicable a

Potential Loss - RCS Integrity-RED OR Heat Sink-RED RCS 5 Other(Site-Specific) Indications Barner RCS - The RCS Barrier includes the RCS 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.

NUMARC Generic Bmig:

[RCSl]

This EAL is for PWRs using Critical Safety Function Status Tree (CSFST) monitoring and functional recovery procedures. < > There is no Loss EAL associated with this item.

[RCS 5]

This EAL is to cover other (site-specific) indications that may indicate loss or potential loss of the RCS barrier, including indications from containment air monitors or any other (site-specific) instrumentation.

Plant-Snecific Information:

Calvert Cliffs does not use Critical Safety Function Status Trees. Calvert Cliffs uses Safety Function Status Checks developed by the Combustion Engineering Owners' Group (C-E OG) which are based on logic similar to that used for CSFSTs developed for Westinghouse PWRs.

A review of plant design information and procedures showed that an appropriate site-specific Loss EAL could be developed based on an EOP transition. Contingency actions related to maintaining RCS Cooling, RCS Inventory, and RCS Pressure functions in accordance with EOP-6 direct the operators to EOP-8, Functional Recovery Procedure.

Thus, the Loss EAL is written as:

l EOP-8, Functional Recovery Procedure, is Implemented from EOP-6. Steam Generator Tube Rupture l The generic indications of concern for the Potential Loss EAL correspond to exceeding Pressurized Thermal Shock (PTS) cooldown limits or the determination ofloss of secondary heat sink. These are discussed below.

Among the Safety Functions to be maintained is RCS Pressure Control. The purpose of maintaining RCS Pressure Control is to maintain the .RCS inventory in a subcooled condition to prmide an adequate cooling medium for the core, and to prevent the loss of inventory out of a relief valve. Per EOP-4, the potential exists for pressurized thermal shock from an excessive cooldown rate followed by a repressurization.

Calvert Cliffs EAL Basis Document B:23 Rev.7

FISSION PRODUCT SARRIER DEGRADATION The EOPs require that the plant conditions be maintained within the limits of the RCS Pressure-Temperature Curve (which is shown as Attachment I to the EOPs). Uncontrolled RCS cooidowns which result in pressure-temperature conditions to the left of these curves (based on the combinations of Reactor Coolant Pumps in operation), which is labeled as the Non-Operating Area, is the condition which most closely corresponds to the NUMARC concern. I Thus, based on the above, Potential Loss EAL 1 is written as:

Uncontrolled RCS Cooldown AND RCS Pressure-Temperature in the Non-Operating Area (Left of the Cooldown Curve)

Uncontrolled means that the RCS cooldown was not the result of deliberate action performed in accordance with plant procedures and exceeds allowable vessel cooldown limits.

The applicable acceptance criteria for Core and RCS Heat Removal sia the Steam Generators are discussed under FCBI above. Once RCS pressure and temperature are reduced, RCS heat removal can be prosided by the Shutdown Cooling System (SDCS). Once the SDCS is placed in senice, the steam generator heat sink capability is no longer pacaesary.

On the basis of the above discussion. Potential Loss EAL 2 is written as:

EOP-8, Functional Recovery Procedure, Can NOT Meet Core and RCS Heat Removal Acceptance Criteria AND Shutdown Cooling is NOTIn Senice Can NOT is used because the final safety function status is of concern, not merely the inability to meet certain intermediate status check conditions.

In service means that the SDCS is in the proper configuration for RCS heat re.~wa.! (SDCS isolation valves open, LPSI pumps operating, etc.) and is considered " operable" as defined in the Calvert Cifs Tecimical Specifications.  :

' Source Documents / References / Calculations

1. Emergency Operating Procedures EOP-0, Post-Trip Immediate Actions EOP-1, Reactor Trip

. EOP-3, Loss of Feedwater

. EOP-4, Excess Steam Demand Event

. EOP-5, Loss of Coolant Accident EOP-6, Steam Generator Tube Rupture EOP-8, Functional Recovery Procedure

2. Emergency Operating Procedures Attachment 1

3. CEN-152, Emergency Procedure Guidelines Calvert Cliffs EAL Basis Document B:24 Rev.7

FISSION PRODUCT BARRIER DEGRADATION fstivert Cliffs Eiwisi.cv Action Level:

RCB2 Temperature NUMARC Eimie..cv Action Level:

RCS 2 RCS Leak Rate Loss - GREATER THAN Available Makeup Capacity as Indicated by a Loss of RCS Subcooling RCS 3 SG Tube Rupture

+

Loss -(Site-Specific) <lndication>

NUMARC Genenc Basis

[RCS 2]

The " Loss" EAL addresses conditions where leakage from the RCS is greater than available inventory control capacity such that a loss of subcooling has occurred. The loss of subcooling is the fundamental indication that the inventory control systems are inadequate in maintaining RCS pressure and inventory against the mass loss through the leak. <>

< " Potential Loss" EALs are addressed in IC RCB4, Coolant Leakage,>

[RCS 3)

This EAL is intended to address the full spectrum of Steam Generator (SG) tube rupture events in conjunction with

< Loss EAL CNB4 and FCB EALs>. The " Loss" EAL addresses ruptured SG(s) with an unisolable h=@y Line Break corresponding to the loss of 2 of 3 fission product barriers (RCS Barrier and Containment Barrier - this EAL will always resuh in < Loss EAL CNB4>). This allows the direct release of radioactive fission and activation products to the environment. Resultant off-site dose rates are a function of many variables. Examples include:

Coolant Activity, Actual Leak Rate, SG Carry Over, lodine Partitioning, and Meteorology. Therefore, dose assessment in accordance with IC <RGI, Off-Site Dose of AT LEAST 1 Rem (EDE + CEDE) OR 5 Rem CDE Thyroid > is required when there is indication that the fuel matrix / clad is potentially lost.

(Site-specific) indication should be consistent with the diagnostic activities of the Emergency Operating Procedures (EOPs), if availabic. This should include indication of reduction in primary coolant inventory, increased secondary radiation levels, and an uncontrolled or complete depressurization of the ruptured SG. Secondary radiation increases should be observed via radiation monitoring of Condenser Air Ejector Discharge, SG Blowdow11, Main j 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 RCS that does not involve the prolonged release of contaminated secondary coolant from the l

affected SG to the emironment. This EAL should encompass steam breaks, feed breaks, and stuck open safety or i reliefvalves.

j Plant-Specific Information  !

A review of EOP4 shows that the minimum acceptable RCS subcooling value is 25'F. Following AOP-2A procedures for Excessive RCS Ienkage Exceeds One Charging Pump in Modes 1 & 2, EOP-0, Post-Trip  !

Immediate Actions is initiated. After the completion of EOP 0, EOP4 requires that the RCS Subcooling be maintain a minimum of at least 25 'F. Failing this criterion will prompt entry into EOP-5. In addition, AOP-2A procedures for Excessive SG Tube I ankare with LTOP (i.e., plant initially in Mode 3) require that the RCS Subcooling maintain at least 25 'F. For consistency with procedural requirements, the lower value of subcooling is used for this EAL, Calvert Cliffs EAL Basis Document B:25 Rey,7

FISSION PRODUCT CARRIER DEGRADATION Thus, the Loss EAL is written as:

l RCS Subcooling Can NOT Be Maintained AT LEAST 25'F l

Source Demant</ References / Calculations:

1. Abnormal Operating Procedures AOP-2A, Excessive Reactor Coolant Leakage

2. Emergency Operating Procedures

+

EOP-0, Post-TripImmediate Actions EOP-1, Reactor Trip '

+ EOP-5, Loss of Coolant Accident EOP 6, Steam Generator Tube Rupture Calvert Cliss EAL Basis Document B:26 Rev.7

FISSICN PRODUCT 2ARRIER DEGRADATION Calvert Cliffs Emergency Action Level:

RCB3 Radiation NUMARC Emergency Action Level:

RCS 4 Containment Radiation Monitoring

+

Loss - Containment Rad Monitor Reading GREATER THAN (Site-specific) R/Hr PotentialLoss-Not Applicable NUMARC Generic Basis:

The (Site-specific) reading is a value which indicates the release of reactor coolant into the containment. The reading should be calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with normal operating concentrations (i.e., within TS) into the containment atmosphere. The reading will be less than that specified for Fuel Clad Banier <EAL 2>. Thus, this EAL would be indicative of an RCS leak only < >.

However, if the site specific physical location of the containment radiation monitor is such that radiation from a cloud of released radiation gases could not be distinguished from radiation from adjacent piping and components containing elevated reactor coolant activity, this EAL should be omitted and other site specific indications of RCS leakage substituted.

There is no Potential Loss EAL associated with this item.

Plant-Soccific Information:

Because of very high clad integrity, only small amounts of noble gases would be dissolved in the reactor coolant .

The EAL uses a value of 5 rem /h (50 mSv/h) for case of identification using RI-5317 A & B monitors. This value (5 rem /h) is in the first decade of the log scale on the monitor and is easily read.

The value 5 rem /h is based on a site-specific study that forms the basis for ERPIP 801, Core Damage Assessment Using Containment Radiation Dose Rates. The value was determined using Calvert Cliffs normal RCS actisity as the source term. Typical values of these monitors are I to 1.2 R/hr (bottom of the scale) during 100% power op1 ration. The alarm serpoint for these monitors is 6 R/hr.

TI us, the Loss EAL is written as:

l Valid FI-5317A/B Reading of AT LEAST 5 rem /h Within 2 Hours After Reactor Shutdown l By specifying the time of the reading as being after reactor shutdown, it also eliminates from consideration such factors as " shine" and N-16 effects on the detectors.

Valid means that the applicable radiation monitoring channel (s) are considered to be operable in accordance with the Technical Specifications.

The EAL uses the value of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> aper the initiating event (assumed to closely correspond to the time ofreactor shutdown)for simplicity in presentation to the Ship Supervisor acting as the Site Emergency Coordinator (SEC).

The two hour point was also picked because it allows ample timefor the transfer ofthe SEC duties to outside the ControlRoom.

Source Documents / References / Calculations:

1. Emergency Response Plan implementation Procedures ERPIP-801, Core Damage Assessment Using Containment Radiation Dose Rates Calvert Cliffs EAL Basis Document B:27 Rev.7

FISSION PRODUCT BARRIER DEGRADATION Calvert Cliffs Emergency Action Level:

RCB4 Coolant Leakage NUMARC Emergency Action Levels:

RCS 1 Critical Safety Function Status i

+

I4ss-Not Applicable Potential less - RCS Integrity - RED or Heat Sink - RED 1

RCS 2 RCS Leak Rate Loss - GREATER THAN Available Makeup Capacity as indicated by a Loss of RCS i j Subcooling.

PotentialLoss - Unisolable Leak Exceeding the Capacity of One Charging Pump in the Normal Charging Mode RCS 3 SG Tube Rupture l

+

?::::!:! Loss - (Site-Specific) Indication that a SG is Ruptured and Has a Non-Isolable Secondary Line Break OR (Site-Specific) Indication that a SG is Ruptured and a Prolonged Release of Secondary Coolant is Occurring From the Affected SG to the Emitonment

+

Potential Loss - Site Specific indication that a SG is ruptured and the primary-to-secondary leak rate exceeds the capacrty of one charging pump in the normal charging mode RCS 4 Containment Radiation Monitoring I4ss - Cortrinment Rad Monitor Reading GREATER THAN (Site Specific) R/Hr PotentialI4ss-Not Applicable RCS 5 Other (Site-Specific) Indications Loss -(Site Specific) as applicable Potential less - (Site Specific) as applicable RCS 6 Emergency DirectorJudgment Any condition in the opinion of the Emergency Director that indicates loss or potential loss of the RCS barrier.

NUMARC Generic Basis:

l"CS 2, RCS 3j L- EL':: : :" :=1: t-!C RCB2, T:=;;=:=.> o

1. Critical Safety Function Status This EAL is for PWRs using Critical Safety Function Status Tree (CSFST) monitoring and functional recovery procedures. For more information, please refer to Section 3.9 of this report

<sbown below>. RED path indicates an extreme challenge to the safety function derived from appropriate instrument readings, and these CSFs indicate a potential loss of RCS barrier.

There fs no "14ss" associated with this item.

Calvert Cliffs EAL Basis Document B:28 Rev.7

FISSION PRODUCT BARRIER SEGRADATION l

<SECTION> 3.9 EMERGENCY ACTION LEVELS l

With the emergency classes defined, the thresholds that must be met for each EAL that is to be placed under tbc emergency class can be determined. Here am two basic approaches to determining these EALs. EALs and emergency class boundaries coincide for those continuously measurable, instrumented ICs, such as radioactivity, core tensperature, coolant levels, etc. For these ICs, the EAL will be the threshold reading that most closely corresponds to the emergency class description using the best available information.

For discrete (discontinuous) events, the approach will have to be somewhat different.

Typically, in this category are internal and external hazards such as fire or earthquake.

De purpose for including hazards in EALs is to assuit that station personnel and offsite emergency response organizations am prepared to deal with consequential darange these hazards may cause. If, indeed, hazards have caused damage to safety functions or fission product berriers, this should be confirmed by symptoms or by observation of such failures.

Therefore, the Task Force believes it appropriate to enter an Alert status for events approaching or exceeding design basis limits such as Operating Basis Earthquake, design basis wind loads, fire within vital areas, etc. This would give the operating staff additional support and improved ability to determine the extent of plant damage unless damage to barriers or challenges to Critical Safety Functions (CSFs) have occurred or are identified, then the additional support can be used to escalate or terminate. The Emergency Class could be escalated or terminated based on what is then found. Of course, security events must reflut potential for increasing security threat levcis.

Plant emergency operating procedures (EOPs) are designed to maintain and/or restore a set of CSFs which are listed in the order of priority for restoration efforts during accident conditions. While the actual nomenclature of the CSFs may vary among plants, generally the PWR CSF set includes:

• Subcriticality e Core cooling e Heat sink e Pressure-temperature-stress (RCS integrity) e Containment

• RCS inventory There are diverse and sedundant plant systems to support each CSF. By monitoring the CSFs lastead of the individual system component status, the impact of multiple events is inherently addressed, e.g., the number of operable components available to maintain the function.

l The EOPs contain detailed instructions regarding tbc monitoring of these functions and provides a scheme for classifying the significance of the challenge to the functions. In providing EALs based on these schemes, the emergency classification can flow from the EOP assessment rather than being based on a separate EAL assessament. This is desirable as it reduces ambiguity and reduces the time necessary to classify the event.

Calvert Cliffs EAL Basis Document B:29 Rev.7

FISSION PRODUCT BARRIER DEGRADATION l

1 As an example, consider that the Westiagbouse Owner's Grwup (WOG) Emergency Response Guidelines (ERGS) classify challenges as YELLOW, ORANGE, and RED paths.

If tbc core exit thermocouples exceed 1200 degrees F or 700 degrees F with low reactor vessel water level, a RED path condition exists. The ERG considers a RED path as ". an extreme challenge to a plaat function necessary for the protection of the public " This is almost identical to the present NRC NUREG-0654 description of a site area emergency " .

actual or likely failures of plant functions needed for the path, a site area emergency exists.

A general emergency could be considered to exist if core cooling CSF is in a RED path and the EOP function restoration procedures have not bee successful la restoring core cooling.

2. RCS IAak Rate The " Loss" EAL addresses conditions where leakage from the RCS is greater than availab!c inventory control capacity such that a loss of subcooling bas occurred. De loss of subcooling is the i fundamental indication that ebe inventory control systems are inadequate la maintaining RCS j pressure and inventory against the volume loss through the leak.

l The Potential Loss EAL is based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control System which is considered as one centrifugal charging pump discharging to the charging header. O.!: ind:::!:n,

.pp' yin;; :: . y RCS '- '--- : f t pi- . j :: r5j '- 'y In conjunction with the SG Tube Rupture " Potential IAss" EAL this assures that any event that results in significant RCS inventory shrinkage or loss (e.g., events leading to reactor scram and ECCS actuation) will result in no lower than an " Alert" emergency classification.

3. SG Tube Rupure

]

This EAL is intended to address the full spectmm of Steam Generator (SG) tube rupture events in conjunction with Containment Barrier "IAss" EAL 4 and Fuel Clad Barrier EALs. The " Loss" 4 EAL addresses ruptured SG(s) with an unisolable Secondary Line Break corresponding to the loss of 2 of 3 fission product barriers (RCS Barrier and Containment Barrier - this EAL will always result in Containment Barrier " Loss" EAL 4). This allows the direct release of radioactive fission and activation products to the environment. Resultant offsite dose rates are a function of many variables. Examples include: Coolant Activity, Actual Leak Rate, SG Carry Over, Iodine Partiticalag, and Meteorology. Therefore, dose assessment la accordance with IC AG1, " Site Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioacti5ity that Exceeds 1000 mR Whole Body or 5000 mR Child Thyroid for the Actual or Projected Duration of the Release Using Actual Meteorology", is required when there is indication that the fuel 4 matris / clad is potentially lost.

l (Site-specific) indication should be consistent with diagnostic activities of the Emergency Cperating Procedums (EOPs), if available. This should include indication of reduction in primary coolant inventory,lacreased secondary radiation levels, and an Lucontrolled or complete depressurization of the ruptured SG. Secondary radiation increases should be observed via radiation monitoring of Condenser air Ejector Discharge, SG Blowdown, Main Steam, and/or SG Sampling System.

Iseterminatfan of the "uacontrolled" depressurization of tbc ruptured SG should be based on indication that the pressure decrease la 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 RCS coolant from tbc affected SG to the environment. This EAL should cocompass steam breaks, feed breaks, and stuck open safety or relief valves, l

Calvert Cliffs EAL Basis Document B:30 Rev.7

i l

FISSION PRODUCT 2ARRIER DEGRADATION De Potential Loss EAL is based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control System I which is considered as one centrifugal charging pump discharging to the charging header. In conjunction with the RCS leak Rate " Potential 14ss" EAL this assures that any event that results in significant RCS inventory shrinkage or loss (e.g., events leading to reactor scram and ECCS actuation) will result in no lower than an " Alert" emergency classification.

4. Containment Radiation Monitoring Tbc (site-specific) reading is a value which indicates the release of reactor coolant to the containment. He reading should be calculated assuming tbc instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with normal operating concentrations (i.e., within T/S) into the containment ainsosphere, nis reading will be less than that specified for l Fuel Clad Barrier EAL #5. Thus, this EAL would be indicative of a RCS leal: only. If the radiation monitor reading increased to that specified by Fuel Clad Barder EAL #3, fuel damage would also be i indicated. I However, if the site specific physical location of the containment radiation monitor is such that i

radiation from a cloud of released RCS gases could not be distinguished from radiation from nearby l piping and components containing elevated reactor coolant activity, this EAL should be omitted and other site specific indications of RCS leakage substituted.

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

l 5. Other (Site-Specific) Indications  !

IRGS4)

This EAL is to cover other (site-specific) indications that may indicate loss or potential loss of the RCS barrier, including indications from containment air monitors or any other (site-specific) instrumentation.

l )

6. Emergency Director Judgment

! This EAL addresses any other factors that are to used by the Emergency Director in deterwhing l whether the RCS barrier is lost or potentially lost. In addition, the inability to monitor the barrier j should also be incorporated in the EAL as a factor in emergency Director judgment that the barrier l may be considered lost or potentially lost. (See also IC SGI, " Prolonged 14ss of All Offsite Power j- and Prolonged Loss of All Onsite AC Power", for additional information.)

NUMARC Ouestion and Answers. June 30.1993 (General)

14. Can the term "unisolable" be replaced by something which is in more common usage?

l Each utility may use its onw term as long as the same meaning is expressed.

( NUMARC Ouestions and Answers. June 30.1993 (Fission Product Barriers-PWR)

1. A concern has been raised about focusing on leakage criteda based on cyrdty of one charging pump. Sites with low displacessent charging pumps (4040 gpm) will be forced to declart higher category events (Alert /SAE) when true loss of significant inventory and challenge to fuel cladding doesn't exist.

The NUREG-0634 Alert classification threshold is based on exceeding 30 gym. Wuthout a threat to thefuel and containment barrier (s) an SAE uvuld not be warranted. For those sites with single charging pump capacity below $0 gym it neuld be acceptable to use 50 gpm as a basisfor the RCS Barrier Potential Loss indicator. This information will be added to the basis statements in afuture revision.

Calvert Cliffs EAL Basis Document B:31 Rev.7 t

FISSION PRODUCT BARRIER DEGRADATION

2. Why choose the Alert leakage as that exceeding the capacity of one charging pump vs. the capacity of the available charging pumps? If more than one pump is available, why not take credit? If pump capacity is 150 gym per pump and 2 pumps are availabic with 1745 spm leak,it should be an Unusual Event. An Alert can be decland if one pump is lost.

The increase to the capacity ofa single chargingpump through the normal charging header is consistent with the amount of make-up readily available. The action of starting a second charging pungp is indscative of a substantial RCS leak and unarrants the declaration of car .

Alert. Since the leakage and make up are dynamic in nature such that both change with RCS \

pressure, it is desirable to have a definitive indication. Note that as the leak aceeds the

~

capacity of both pungps such that subcooling is lost the declaration remains an Alert until there is indication offuel or containment barrier degradation.

4. Can the mode applicability be designated in the FPB matrix when a LOCA is indicated?

This will alleviate the problems with EOP actions for other problems 1.c., blackout. ,

I It neuld be inadvisable to establish this type ofdesignation since the FPB Matrix acts to back-up other problem sources. While reactor protection-system (RPS) failure and blackout, for l

aample, are addressed separately, indications within the FPB Matrix are still available and should be used even sf a higher threshold is not met in the RPSfailure or blackout EAL.

5. There have been questions related to changing the FPB " Potential Loss" term to

" Challenged" to be more consistent with PWR EOP tenninology.

Ifthis is more consistent with the humanfactor considerationsfor a specific site then it uvuld be acceptable to do this. Caution should be exercised, houwver, as a challenge (as in Critica!

l Safety Functions usage) may be specifically defmed to the operators and that defmition may not be consistent with the intended use here.

Plant-Soecific Information:

There is no Generic Loss EAL RCS 1.

EALs responsive to Generic Potential Loss EAL RCS 1 are addressed under Calvert Cliffs EAL RCB 1, Safety Function Status / Functional Recovery.

An EAL responsive to Generic Loss EAL RCS 2 is addressed under Calved Cliffs EAL RCB 2, Temperature.

For all operating conditions, other than shutdown cooling, unisolable RCS leakage within the capacity of one charging pump is treated under fission product barrier degradation, Calvert Cliffs Initiating Condition, BU2, RCS leakage. If RCS leakage occurs while the unit is not on Mtdown cooling, AOP-2A, Excessive Reactor Coolant Leakage,is implemented and an unusual event is declared if the unit is to be placed in cold shutdown.

For a unit on shutdown cooling, unisolable leakage within the capacity of one charging pump is treated under equipment failure, Calven Cliffs Initiating Condition, QUI, Unplanned 14ss of Any Function Needed to Maintain Cold Shutdown. If RCS leakage occurs while the unit is on shutdown cooling, AOP-3B, Abnorsaal Shutdown Cooling Conditions,is implemented and an unusual event is declared if AOP-3B can not be exited within 15 minutes.

Only RCS leakage which exceeds the capacity of one charging pump is considered to be a potential loss of the RCS barrier and hence classified as Alen.

Calvert Cliffs EAL Basis Document BJ2 Rev.7

FISSION PRODUCT DARRIER DEGRADATION The Calvert Cliffs Chemical and Volume Control System (CVCS) uses three positive displacement horizontal pumps with a capacity of 44 GPM each. The pressurizer level control program regulates letdown purifice.on subsystem flow by adjusting the letdown flow control valve so that the reactor coolant pump (RCP) controlled leak-off plus the letdown flow matches the input fmm the operating charging pump. Equilibrium pressurizer level conditions may be disturbed due to RCS temperature chang:s, power changes, or RCS inventory loss due to 4

leakage. A decrease in pressurizer water level below the prop-r.md level will result in a control signal to start one or both standby charging pumps to restore water level. An increase in pressunzer water level above the programmed level will result in a control signal to increase letdown purification flow rate and initiate a backup signal to stop the two standby charging pumps.

A start signal is sent to all three charging pumps on a Safety injection Actuation Signal (SIAS), aligning the charging pumps suction to the Boric Acid Storage Tanks (BASTS) via the boric acid pumps. All three charging pumps will then inject highly concentrated boric acid into the RCS to ensure that the reactor is shutdown. Potential Loss of the RCS corresponds to conditions where the CVCS can not maintain pressurizer water level within normal limits requiring transition into the EOPs when the reactor is initially critical.

l In reponse to Generic Potential Loss EAL RCS2, Calvert Cliffs Potential 14ss EAL 1 is written: Bus; l

":^ ': ' L- EAL ! i: ; 2r:: =:

{

l RCS Leakage Exceeds Available CVCS Capacity l However, Rreview showesd that an appropriate site-specific Potential Loss EAL could be developed based on entry into EOP-5, Loss of Coolant Accident, EOP4, Steam Generator Tube Rupture or EOP-8, Functional Recovery Procedure, for an RCS leak. In events where leakage exceeds the capacity of one charging pump, Calvert Cliffs implements EOP-5, EOP4, or EOP-8.

In response to Gemede Potential Less EAL RCS 2, Calvert Cliffs Potential I4ss EAL 2 is written: Aus; PosenW r EAL 2, idt:: =:

EOP-5, Loss of Coolant' Accident, Or-E^" S,-Frt ' P=rj ."---ir; is Implemented for RCS Leakage In response to Generic Potential less EAL RCS 2, Calvert Cliffs Potential I4ss EAL 3 is written:

l EOP4, Steam Generator Tube Rupture, is Implemented for RCS Isakage l In response to Genede Potential 14ss EAL RCS 2, Calvert Cliffs Potential less EAL 4 is written:

l EOP-8, Functional Recovery Procedure,is Implemented for RCS IAakage l An EAL responsive to Generic IAss EAL RCS 3 is addressed under Calvert Cliffs EAL RCB 2, Temperature.

In response to Generic Potential Loss EAL RCS 3, Calvert Cliffs Potential less EAL 3 above also applies.

An EAL responsive to Generic I4ss EAL RCS 4 is addressed under Calvert Cliffs EAL RCB 3, Radiation.

Dere is no Generic Potential IAss EAL RCS 4.

Dere is no Calvert Cliffs EAL equivalent to Generic I4ss and Potential less EAL RCS 5.

Calvert Cliffs EAL Basis Document B:33 Rev.7

__ ~

FISSION PRODUCT BARRIER DEGRADATION Source Documents / References / Calculations:

1. Abnormal Operating Procedures

+

AOP-2A, Excessive Reactor Coolant Leakage

2. Emergency Operating Procedures )

+ EOP-5, Loss of Coolant Accident

+

EOP-6, Steam Generator Tube Rupture

+ 3 EOP-8, Functional Recovery Procedure 4

3. Surveillance Test Procedure (STP) 0-27-1/2, RCS Leakage Evaluation i 1

4. Updated Final Safety Analysis Report  !

+

Section 9.1, Chemical and Volume Control System I l

J r

I l

l 1

Calvert Cliss EAL Basis Document B:34 Rev.7

FISSION PRSIUCT BARRIER DEGRADATION Calvert Cliffs Emeraency Action imel:

RCBS S3CJudgement NUMARC Errea .cv Action Level:

RCS 6 Emergency Director Judgement NUMARC Generic Raeis:

This EAL addresses any other factors that are to be used by the <SEC) in determining whether the RCS hurier is lost or potentially lost. In addition, the inability to monitor tk barrier should also be incorporated in this T.AL as a factor in <SEC> judgement that the barrier may be cor,:Jered lost or potentially lost. (See also <.C EGI, Prolonged Station Blackout >, for additional information.)

Plant SoccificInformation Per the Emergency Response Plan, the Site Emergency Coordinator (SEC) is the title for the emergency director function at Calvert Cliffs. SEC considerations for determining whether any barrier Loss or Potential Loss include imminent degradation, barrier monitoring capability, and dominant accident sequences. This information is included on the Fission Product Barrier reference page which is to be redewed by the SEC before using the Fission Product Barrier Table.

Anticipated degradation of ANY Barrier within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> based on a projection of current safety system performance is considered to be imminent Barrier degradation. This must be considered by the SEC for timely declaration of a General Emergency. The term imminent refers to the inability to reach final safety acceptance before completing all checks.

Decreased barrier monitoring ability from loss of/ lack of reliable indicators must also be considered by the SEC when judging whether a Barrier may be last or Potentially Lost. This assessment should also include instrumentation operability concerns, readings from portable instrumentation, and consideration off-site monitoring results.

Dominant accident sequences will lead to degradation of all Barriers. The SEC should also consult Station Blackout and ATWS ICs, as appropriate, to assure timely emergency classification declaration.

Thus, the EAL is written as:

Any Concition Which in the SEC's Judgement Indicates Loss or Potential Loss of the RCS Barrier Based on:

Imminent Barrier Degradation Due to Safety System Performance

. Degraded Ability to Monitor Barrier fource D=anaate/ References /Calmia' ions:

1, Emergency Response Plan i Calvert Cliffs EAL Basis Document B:35 Rev.7

FISSION PRODUCT BARRIER DEGRADATION I

l 1

i CONTAINMENT BARRIER EALs  !

Calvert Cliffs EAL Basis Document B:36 Rev.7

FISSION PRODUCT RARRIER DEGRADATION Emernency Classification Level: PER FISSION BARRIER REFERENCE TABLE Analieble Operational Modes: 1, 2, 3, 4 Calvert Cliffs Emernency Action Level CNB1 Safety Function Status / Functional Recovery

! NUMARC Emernency Action Level:

Containment 1 Critical Safety Function Status

+

Loss-Not Applicable Potential Loss - Containment - Red l

Containment 7 Other (Site-Specific) Indications Bamer CNTMT - The CNTMT 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 blowdow11 line extensions outside the containment building up to and including the outermost secondary side isolation valve.

NUMARC Generic Basis:

[ Containment 1]

This < Generic > EAL is for PWRs using Critical Safety Function Status Tree (CSFST) monitoring and functional recovery procedures. < >Thus, this EAL is primarily a discriminator between Site <E>mergency and General Emergency representing a potential loss of the third barrier.

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

[ Containment 7]

This < Generic > EAL should cover other (site-specific) indications that may unambiguousiv indicate loss or potential loss of the containment barrier, including indications from area or ventilation monitors in containment annulus or other contiguous buildings. If site emergency operations procedures proside for venting of the containment during an emergency as a means of preventing catastrophic failure, a Loss EAL should be included for the containment barrier. This < Generic > EAL should be declared as soon as such venting is imminent.

Containment venting as part of recovery actions is classified in accordance with < Radiation Releases ICs>.

Plant Soccific Information:

Calvert Cliffs does not use Critical Safety Function Status Trees. There is no direct equivalent to the generic containment status tree " potential loss" EAL at Calvert Cliffs.

Source Documents / References /C=lMa*iana:

1. Emergency Operating Procedures EOP4, Functional Recovery Procedure t

Calvert Cliffs EAL Basis Document B:37 Rev.7 i

i

i-i I

FISSICN PRODUCT BARRIER DEGRADATION i

t Ejpernency Ch=% don Level: PER FISSION BARRIER REFERENCE TABLE

Aeolicable Operational Modes: 1,2,3,4.

l Calvert Cliffs Emernency Action Level CNB2 Temperature NUMARC Emergency Action Level:

Containment 6 Core Exit Thermocouple Readings

• Lou-Not Applicable Potential Loss - Core Exit Thermocouples in Excess of 1200'F and Restoration NOT Effective Within 15 Minutes; OR Core Exit Thermocouples in Excess of 700'F With Reactor Vessel Level Below Top of Active Fuel and Restoration Procedures NOT Effective Within 15 Minutes NUMARC Generic Basis:

In this EAL, the function restoration procedures are those emergency operating procedures that address the recovery of the core cooling critical safety functions. The procedure is considered effective if the temperature is decreasing or if the vessel water level is increasing.

The conditions in this potential loss EAL represent </mminent> melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. In conjunction with the core exit thermocouple EALs in the Fuel and RCS barrier columns, this EAL would result in the declaration of a General Emergency -

loss of two barriers and potential lo. F the third. If the function restoration procedures are ineffective, there is no

" success" path.

Severe accident analyses (e.g., NUREG-il50) 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 prmide 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 <SEC) should make the declaration as soon as it is determined that the procedures have been, or will be, ineffective. The reactor vessel level chosen should be consistent with the emergency response guide, applicable to the facility.

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

Plant-SnecificInformation:

As described in EAL FCB4, Reacter Vessel Water Level, the RVLMS measures water level to slightly above the top of the active fuel. Therefore, the generic condition of water level below the top of the active fuel and temperature greater than 700'F does not apply to Calvert Cliffs.

EOP-8, Functional Recovery Procedure, would be entered on symptoms of inadequate core cooling. This includes core exit thermocouples reading superheat. The functional recovery procedure would be entered well before 1200 F core exit temperature is achieved, which is the threshold for clad rupture due to high temperature used in EAL FCB2.

I i

l Calvert Cliffs EAL Basis Document B:38 Rev.7

FISSION PRODUCT BARRIER DEGRADATION I

The clear intent of the NUMARC methodology is to provide a higher threshold for contamment " potential loss" above that of fuel clad " loss" at 1200*F for the core damage sequences of concern. If core exit temperature continued to increase above this value, it would clearly indicate that functional recovery of RCS heat removal was i ineffective and that core conditions are continuing to degrade. Per ERPIP-802,1300*F corresponds to clad damage (

on the order of 20% In order to provide a discriminator from the FCB2 " loss" condition (1200*F), temperature of 1300*F and increasiug is used here.

Thus, the Potential Loss EAL is written as:

l Valid Core Exit Thermocouple Readings GREATER THAN 1300'F AND Incmasing l l Valid means that the thermocouple channel (s) are considered to be operable in accordance with the Technical i Specifications.

Source Documents / References /Ce!* ions:

1. Emergency Response Plsn Implementation Procedures ERPIP 802, Core Damage Asses: ment Using Core Exit Thermocouples

2. CEN 152, Emergency Procedure Guidelines

3. Emergency Operating Procedures ,

=

EOP 8, Functional Recovery Procedure

4. Abnormal Operating Procedures ,

AOP 3B, Abnormal Shutdown Cooling Conditions, Attachment 14, RCS Levels

5. Updated Final Safety Analysis Report UFSAR Section 7.5.9, Inadequate Core Cooling Instrumentation I

Calvert Cliffs EAL Basis Document B:39 Rev.7

FISSION PRODUCT 2ARRIER DEGRADATION Calvert Cliffs Emeraency Action Level:

CNB3 Radiation NUMARC Emergency Action Level:

Containment 5 Significant Radioactive Inventory in Containment

+

Zoss-Not Applicable Potential Loss - Containment Rad Monitor Reading GREATER THAN (Site-Specific) R/hr Containment 7 Other (Site Specific) Indications NUMARC Generic Basis

[ Containment 5]

The (Site-specific) reading is a value which indicates significant fuel damage well in excess of the EALs associated with <los of both Fuel Clad and RCS Barriers >. As stated in <NLMARC/NESP-007), a major release of radioactivity requiring offsite protective actions from core damage is not possible unless a major failure of fuel cladding allows radioactive material to be released from the core into the reactor coolant. Regardless of whether coctainment is challenged, this amount of activity in containment, if released, could have such severe consequences that it is prudent to treat this as a potential loss of containment, such that a General Emergency declaration is warranted. 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 than 20%.

Unless there is a (site-specific) analysis justifying a higher value, it is recommended that a radiation monitor reading correspooding to 20% fuel clut damage be specified here. <Thus, this EAL corresponds to loss of both the fuel clad and RCS barriers with Potential Loss of the Containment barrier, and would result in declaration of a General Emergency.

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

[ Containment 7]

This < Generic > EAL should cover other (site-specific) indications that may unambiguously indicate loss or potential loss of the containment barrier, including indications from area or ventilation monitors in the containment annulus or contiguous buildings..

Plant-Specific Information:

Entry into EOP-5 (Loss of Coolant Accident) or EOP-8 (Functional Recovery Procedure) would be made following a LOCA. As part of the required actions in these procedures, a check is made of radiation levels external to the contair. ment is made to assure that containment bypass has not occurred. The location of such a leak is indicated by surop alarms, room level alarms and area RMS alarms. If a significant leak bypassing contamment existed that could not be isolated, then the =.wp=e criteria for radiation levels external to containment could not be met and this would indicate a CNTMT Loss.

Thus, the less EAL is written as:

EOP-5, Loss of Coolant Accident, Or EOP-8, Functional Recovery Procedure, is Implemented AND Radiation Levels External to CNTMT Can NOT Meet Awat== Criteria Can NOT is used because the final safet) function status is of concern, not merely the inability to meet certain intermediate status check conditions.

Calvert Cliffs EAL Basis Document B:40 Rev.7.

FISSION PRODUCT BARRIER DEGRADATION Potential Loss EALs I and 2 address significant radioactive inventory in containment. The plant-specific containment radiation values were detern+.ai fram ERPIP-801, assunung 20% fuel clad damage. This procedure can be used to determine the cer* _ vadiation monitor readings resulting from 20% fuel clad failure using Attachment 2 and assumig , .,4er correction.

The radiation monitor reading (1 RI 5317A & B,2-RI 5317.A & B) corresponding to 20% fuel clad failure at 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after shutdown is about 14,000 rem /h (140 Gray /h).

Thus, Potential Loss EAL 1 is written as:

l Valid RI 5317A/B Readmg of AT LEAST 14,000 rem /h Within 2 Hours After Reactor Shutdown l l'alid means that the applicable radiation monitoring channel (s) are considered to be operable in accordance with the Technical Specifications.

The EAL uses the value of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> ayer the initia:ing event (assumed to closely correspond to the time ofreactor shutdown)for simplicity in presentation to the Ship Supervisor acting as the Site Emergency Coordinator (SEC).

The two hour point was also picked because it allows ample time for transfer of the SEC duties to wtside the ControlRoom.

Technical support personnel can also use ERPIP-801, -802, -803, and -804 to determine core damage.

Thus, Potential Loss EAL 2 is written as:

[ AT LEAST 20% Clad Damage As Determined From Core Damage Assessment l Potential Loss EAL 3 addresses conditions where leakage outside containment is detected. As part of EOP-5, Loss of Coolant Accident, the operator is instructed to review potential leak paths from the RCS to outside the Containment and isolate mch paths, if possible. Actions to be performed include verifying:

Letdown line isolation are shut

• RCS sample isolation valves are shut i

Leakage into the Component Cooling System is not occurring Existence ofleakage outside containment would indicate that the plant systems were not performing in accordance with the design basis for containment isolation. Therefore, it is appropriate to classify this condition as a Potential Loss.

Thus, Potential Loss EAL 3 is written as:

EOP-5, Loss of Coolant Accident, is Implemented AND LOCA is NOT Occurring Within the CNTMT As Indicated by Aux Building Sump Alarms or Aux Building RMS Alarms If the leakage were significant and could not be isolated, then the =~*a*=a~ criteria for radiation levels levels externs.1 to containment could not be met and the Loss condition spectfied above would exist.

Source DamaanedReferences/C=%'iane:

1. Emergency Response Plan Implementation Procedures

• ERPIP401, Core Damage Assessment Using Containment Radiation Dose Rates ERPIP402, Core Damage Assessment Using Core Exit Thermocouples ERPIP403, Core Damage Assessment Using Hydrogen ERPIP-804, Core Damage Assessment Using Radiological Analysis of Samples

2. Emergency Operating Procedures

• EOP-5, Loss of Coolant Accident

+

EOP4, Functional Recovery Procedure Calvert Cliffs EAL Basis Document B:41 Rev.7

FISSION PRODUCT BARRIER CEGRADATION Calvert Cliffs Emergency Action Level:

CNB4 Coolant Leakage NUMARC Emergency Action Level:

Containment 3 Containment Isolation Valve Status AAer Containment Isolation

+

Loss - Valve (s) NOT Closed and Downstream Pathway to the Emironment Exists PotentialLoss-Not Applicable Containment 4 SG Secondary Side Release With Primary-to ka=hry Leakage ,

Loss - Release of Secondary Side to Atmosphere with Primary to haaA=y Leakage GREATER l THANTS Allowable )

PotentialLoss-Not Applicable NUMARC Generic Basis:

[ Containment 3]

This < Generic > EAL is intended to address incomplete containment isolation that allows direct release to the emironment. It represes a loss of the containment barrier.

There is no Potential Loss EAL associated with this item.

[Contamment 4)

This < Generic > EAL addresses SG tube ruptures. Secondary side releases to atmosphere include those from the condenser air ejector, atmospheric < steam > dump valves, and main steam safety valves. For smaller breaks not exceeding 11c normal charging capacity threshold in Potential Loss <EAL RCB4, Coolant Leakage >, this EAL results in an Unusual Event < declaration under IC BU2, RCS Leakage >. For larger breaks, <EAL RCB4 Potential Loss > would result in an Alert. For < larger spectrum > SG tube ruptures < >, this < Loss > EAL would exist in conjunction with <EAL RCB4, Coolant Leakage or Loss EAL RCB2, Temperature,> and would result in a Site

<E>mergency. Escalation to General Emergency would <then> be based on " Potential Loss" of the Fuel Clad Barrier.

Plant SoecificInformation:

Loss EAL 1 addresses containment isolation valve status. It is written in language that facilitates operating staff recognition. In accordance with ITS 3.6.3, the containment purge isolation valves are not in operation for Modes 1, 2,3, & 4; they are closed. The only time the valves are in operation is Mode 5 and 6 under administrative control.

Thus, Loss EAL 1 is written as:

l Leakage Pathway Exists From inside CNTMT to Outside CNTMT l Existence of a leakage pathway may be determined by radiation monitoring, physical observation, or by control room valve indications.

Larger spectrum steam generator tube ruptures of concern for Loss EAL 2 will result in entry into EOP-6, Steam Generator Tube Rupture. EOP-6 requires that ruptured SG water level be maintained between +30 inches and -170 inches. If the water level cannot be maintained within these limits, entry into EOP-8, Functional Recovery Procedure, is then made. EOP-8 has a wider allowable acceptance band for ruptured SG water level, between +50 inches and -170 inches.

s Calvert Cliffs EAL Basis Document B:42 Rev.7

FISSION PRODUCT EARRIER DEGRADATION If the ruptured steam generator water level could not be maintained below +50 inches, this would indicate a larger spectrum steam generator tube rupture with potential to overfill the ruptured SG.

Smaller spectrum SG tube ruptures (i.e. SG tube ruptures that are isolated in accordance with AOP-2A, Excessive l Reactor Coolant Leakage) are addressed by BU2, RCS leakage. Larger wiruru SG tube ruptures (i.e. SG tube j ruptures isolated in accordance with EOP4, Steam Generator Tube Rupture) are addressed by Fission Barrier EAL RCB4, Coolant L*4= These types of tube ruptures can result in an environmental release as AOP 2A and/or EOP4 are being implemented. Releases associated with successful use of AOP-2A and/or EOP4 however, are not expected to be prolonged and are not expected to result in a significant dose to the public (i.e. the dose is not i expected to reach the Radioactivity Release level for Site Emergency). Containment barrier degradation l determination is based on whether or not the steam generator tube rupture sequence results in a prolonged and/or uncontrolled release to the environment. Prolonged and/or uncontrolled releases could result from r large

- primary-to-secondary flow that rapidly increases the ruptured SG's water level, the inability to close the ruptured SG main steam isolation valve, the ruptured SG main steam safety or atmospheric dump valves sticking open, operators not isolating the auxiliary feedwater pump turbine steam supply from the ruptured SG, or a SG repture l coincident with secondary line breaks. The timing of a prolonged release begins when actions intended to curtail the release have been completed. '

l Thus, Loss EAL 2 is written as:

Steam Generator tube rupture in progress and an une~pected/ uncontrolled release to the emironment from the affected Steam Generator for GREATER THAN 15 minutes. 4 Affected is used to indicate that the release from the steam generator with the tube rupture is the steam generator that is of concern for this EAL. Unexpected means that the release is not expected as a result of EOP4 implementation. Uncontrolled means that the given condition is not the result of planned actions. See also IC BS1, Loss or Potential Loss of ANY Two Barriers, page B:7, item 3, Escalation of SG Tube Rupture Sequences.

Source DamnantdReferences/ Calculations:

1. Technical Specifications

+

ITS 3.4.13, Reactor Coolant System Operational Leakage

• ITS 3.6.3, Containment Isolation Valves

2. Abnormal Operating Procedures

+

AOP-2A, Excessive Reactor Coolant Leakage j

3. Emergency Operating Procedures

+ EOP-0, Post-TripImmediate Action

+

EOP4, Steam Generator Tube Rupture

+

EOP-8, Functional Recmcry Procedure

4. Updated Final Safety Analysis Report

+

Chapter 6, Engineered Safety Features

+

Section 9.1, Chemical and Volume Control System

5. Letter dated September 15,1994, T. E. Forgette to Site Emergency Coordinators, et. al.

Calvert Cliffs EAL Basis Document B:43 Rev.7

FISSION PRODUCT BARRIER DEGRADATION Calvert Cliffs Emereenev Action Level:

CNB5 Pressure NUMARC E.Tassy Action Level:

Containment 2 Containment Preuure Loss - Rapid Unexplained Decrease Following Initial Increase OR Containment or Sump Level NOT Consistent with LOCA Conditions Potential Loss - (Site-specific) PSIG and Indreasing OR Explosive Mixture Exists OR Containment Pressure GREATER THeN Containment Depressurstion System Setpoint With IISS THAN One Full Train of Depressurization Equipmetn Operating Barner: Containment NUMARC Generic Basis:

Rapid unexplained loss of pressure (i.e., not attributable to containment spray or condensation effects) followin.g an initial pressure increase indicates a loss of containment integrity. Containment pressure and sump levels shco f increase as a result of the mass and energy release into containment from a LOCA. Thus, sump level or pressure not increasing indicates containment bypass (V-sequence) and a loss of containment integrity. The (site specific)

• SIG for potential loss of containment is based on the containment design pressure. Existence of an explosive j

mixture means a hydrogen and oxygen concentration of at least the lower deflagration limit cun'c exists. The indications of potential loss under this EAL corresponds to some of those leading to the RED path in EAL CNBl above and may be declared by those sites using CSFSTs. <T>his < Generic > EAL is primarily a discriminator between Site <E>mergency and General Emergency representing a potential loss of the third barrier.

) The second potential loss EAL represents a potential loss of containment in that the containment heat removal /depressurization sy, em (e.g., containment sprays, ice condenser fans, etc., but not including containment venting strategies) is either 1.st or performing in a degraded manner, as indicated by containment pressure greater than the setpoint at which the equipment was supposed to have actuated.

Plant-Snecific Informatign:

The Calven Cliffs Loss EALs correspond directly to the NUMARC EAL. Because it is difficult to determine whether pressure and sump level response is consistent with expected, snd the other Containment Loss E ALs address containment response in a way that is observable by the operations staff, the second condition specified in the generic EAL is not used at Calvert Cliffs.

Thus, Loss EAL 1 is written as:

l Rapid Unexplained CNTMT Pressure Decrease Following Initial Increase l The design pressure for the Calvert Cliffs containment is 50 psig. Proper actuation and operation of the containraent spray system when required maintains containment pressure below its design pressure following LOCA or secondary side break inside containment.

Thus. Potential loss EAL 1 is written as:

l CNTMT Pressure of AT LEAST 50 PSIG AND Increasing l The EAL uses the lower limit of flammability of hydrogen in air, f.e.,4% hydrogen concentration. However, 4%

corresponds to the explosive mixture condition specified by NUMARC.

Calvert Cliffs EAL Basis Document B:44 Rev.7

\

l FISSION PRODUCT BARRIER EEGRADATION 1 l l

Thus, Potential Loss EAL 2 is written as:

~

l CNTMT H2Concentration of AT LEAST 4.0% l Source Documents / References /Caled=4ns:

1. Technical Specifications

+

ITS 3.6, Containment Systenu

2. Emergency Operating Procedures

+

EOP-8, Functional Recovery Procedure

3. Updated Final Safety Analysis Report

+

Chapter 6, Engineered Safety Features l

Calvert Cliffs EAL Basis Document B:45 Rev.7 i

l

FISSION PRODUCT BARRIER EEGRADATION Calvert Cliffs Emernency Action Level:

CNB6 SEC Judgement NUMARC Esiis.cv Action Level:

Containment 8 Emergency Director Judgement l l

NUMARC Genenc Basis l This EAL addresses any other factors that are to be used by the <SEC> in determining 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 <SEC> judgement that the barrier may be considered lost or potentially lost. (See also <lC EGI, Prolonged Station Blackout,> for additional information.)

i Plant SnecificInformation:

Per the Emergency Response Plan, the Site Emergency Coordinator (SEC) is the title for the emergency director function at Calvert Cliffs. SEC considerations for determining whether any barrier Loss or Potential Loss include imminent degradation, barrier monitoring capability, and dominant accident sequences. This information is in:luded on the Fission Product Barrier reference page which is to be reviewed by the SEC before using the Fission Product Barrier Table.

Anticipated degradation of ANY Banier within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> based on a projection of current safety system performance is considered to be imminent Barrier degradatiaa. This must be considered by the SEC for timely declaration of a General Emergency. The term imminent refers to the inability to reach final safety acceptance before completing all checks.

Decreased barrke monitsring ability from loss of/ lack of reliable indicators must also be considered by the SEC when judging whether a Barrier may be Lost or Potentially Lost. This assessment should also include mstrumentation operability conmrns, readings from portable instru:nentation, and consideration off-site monitoring results.

Dominant accident sequences will lead to degradation of all Barriers. The SEC should also consult Station Blackout and ATWS ICs, as appropriate, to assure timely emergency classification declaration.

Thus, the EAL is written as:

Any Condition Which in the SEC's Judgement Indicates Loss or Potential Luss of the CNTMT Barrier Based on:

Imminent Barrier Degradation Due to Safety System Performance

• Degraded Ability to Monitor Barrier l

Source Dac-a'</ References / Cal & ations:

1. Emergency Response Plan Calvert Cliffs EAL Basis Document B:46 Rev.7

i EQUIPMENT FAILURE Calvert Cliffs EAL Basis Document Rev.7

EQUIPMENT FAILURE Emeraency Classification Level: UNUS'UAL EVENT Acolicable Operational Modes: 4,5,6 Cabert Cliffs Initiatina Condstson QUI Unplanned Loss of Any Function Needed to Maintain Cold Shutdown NUMARC Reconnition Catenorv: System Malfunction NUMARC Initiatina Condition:

Not Applicable Bagur Not Applicable NUMARC Generic Emereency Action 12vels None NUMARC Ouestions and Answers. June 10.1993 (System Malfunction)

None NUMARC Generic Guidanca:

None ElADI-SDecific inrormation:

Unplanned is used to preclude the declaration of an emergency where a component or system has been removed intentionally from service (e.g., for maintenance and testing).

In order to maintain the anticipatory overall philosophy of the NUMARC EAL whada!ogy and to assure that precursors to shutdown accidents are appropriately classified, Calvert CliKs las added this Initiating Condition in the Unusual Event classification. NUREG 1449 raises concerns regarding Inadvertent Criticality Events during shutdown. In its regulatory analysis of the NUMARC methodology, NRC noted that there is a likelihood that the results of ongoing risk studies relating to shutdown (e.g., NUREG-1449) may necessitate resision of both existing NRC EAL guidance and the new NUMARC guidance as well. Thus, Calvert Cliffs has added this IC that precursor events of concern are appropriately addressed and to better assure that the NUMARC-based methodology was complete before its implementation at Calvert Cliffs.

Per the Technical Specifications, the functions required to be operable during Cold Shutdown and Refueling modes and are associated with maintaining required shutdown conditions (temperature, pressure, and subcriticality) are:

Reactivity Control Systems (ITS 3.1)

RCS Loops - Mode 1 & 2 (ITS 3.4.4)

RCS Loops - Mode 3 (ITS 3.4.5)

RCS Loops - Mode 4 (ITS 3.4.6)

RCS IAops - Mode 5 (ITS 3.4.7, 3.4.8)

Shutdown Cooling and Coolant Circulation - High Water Level (ITS 3.9.4)

Shutdown Cooling and Coolant Circulation - Low Water Leel (ITS 3 9.5)

Pressurizer Safety Vahes (ITS 3.4.10)

Low Temperature Overpresr. ire Protection (LTOP) System (ITS 3.4.12)

Electrical Power Systems (ITS 3.8)

Calvert Cliffs EAL Basis Docunsent Q:1 Rev.7 l'

l .. .

EQUIPMENT FAILURE AC and DC power systems availability are separately addressed under the Loss of Power Event Category. Thus,

. these are not addressed under this initiating Condition. RCS leakage (e.g., requiring use of the Charging /HPSI Subsystems or resulting from Overpressure Protection System malfunctions) is addressed by IC BU2, RCS Leakage, and the Radioactivity Release ICs related to uncovery of irradiated fuel. Boration systems are addressed by maintaining required Shutdown Margin (SDM) as discussed below.

14ss of SDC (which is required by Technical Specifications) includes loss of shutdown cooling support functions such as Component Cooling Water that are required to remove heat from the Shutdown Cooling heat exchangers.

Under the conditions of concern, AOP-3B, Abnormal Shutdown Cooling Conditions, would be entered.

An EAL that refers to entry into AOP-3B is needed (in the equipment failure category) to respond to conditions which are precursors to shutdown accidents. An AOP-38 EAL is also needed to respond to NUMARC guidance la the fission p wduct barrier degradation category. Cahert CliNs Initiating Condition BU2, RCS leakage and Calvert CliNs Emergency Action Level, RCB4, Coolant Leakage addresses these conditions. The AOP-3B EAL described in this category, equipment failure, therefore serves to meet three diNerent but related conditions.

Calvert CliNs EAL 1 is written: E=. EAL 1 i: H"= =:

Entry into AOP-3B, Abnormal Shutdown Cooling Conditions, is Required for GREATER THAN 15 Minutes Required means that entry into the Abnormal Operating Procedure is neither optional nor merely suggested, but I rather imperative based on existing conditions.

l The Cold Shutdown and Refueling Modes are defined by specific plant conditions - reactivity condition (Ke g) and coolant temperature. Maintenance of the ability to remove core decay heat addresses the coolant temperature criteria. The EALs addressing required subcriticality conditions for operation in modes 5 and 6 are missing from the NUMARC EALs. Per Improved Technical Specification Table 1.1-1, Modes, the required SDM is Ke g less than 0.99 for Mode 5 and Keg not more than 0.95 for Mode 6. Per Technical Specification 3.9.1, the ndnimum j boron concentration required during refueling mode is at least 2300 ppm. Under the conditions of concern, AOP-  !

1 A would be entered.  :

Calvert CliNs EAL 2 is written: E=. EAL 2 i: v n =: )

l Entry into AOP 1 A. Inadvertent Boron Dilution is Required AND Shutdown Margin NOT Maintained l l

Source Documents / References / Cal& ations:

1. Technical Specifications

2. Abnormal Operating Procedures

• AOP 1 A, Inadvertent Boron Dilution

+

AOP-3B, Abnormal Shutdown Cooling Conditions ,

l

3. NUREG 1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United '

States, Draft for Comment February 1992

4. Regulatory Analysis - Revision of Regulatory Guide 1.101 to Accept the Guidance in NUMARC/NESP- j 007, Rev. 2 as an Alternative Methodology for the Development of Emergency Action Lesels i 1

Calvert Cliffs EAL Basis Document Q:/ Rev.7

EQUIPMENT FAILURE Eraiaav Classification Level: UNUSUAL EVENT Anolicable Operational Modes: 1, 2, 3, 4 Calvert Cliffs Initiatina Condition:

QU2 Unplanned Loss of Most or All Safety System Annunciators for GREATER THAN 15 Minutes NUMARC Recognition Catenory: System Malfunction NUMARC Initiatina Condition:

SU3 Unplanned Loss of All Safety System Annunciators for Greater Than 15 Minutes Bamer: Not Applicable NUMARC Generic Basis:

This IC and its associated < Generic > EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.

Recognition of the availability of computer based indication equipment is considered (SPDS, plant computer, etc.).

Unplanned loss of annunciators or indicators excludes scheduled maintenance and testing actisities.

Compensatory non-alarming indications in this context includes computer based information such as SPDS. This ,

should include all computer systems available for this use depending on specific plant design and subsequent I retrofits.

Quantification of"most" is arbitrary, however, it is estimated that if approximately 75% of the safety systems annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected.

It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgement threshold for determining the severity of the plant conditions. This judgement is supported by the specific opinion of the Shift Supervisor that additional operating personnel will be required to proside increased monitoring of system operation to safely operate the unit (s).

It is further recognized that most plant designs provide redundant safety system indication from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to the difficulty associated with the assessment of plant conditions. The loss of specific, or several, safety system indicators should remain as a ftuetion of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on <lC QU4, Inability to Reach Required MODE Within Technical Specification Limits >.

(Site-specific) annunciators or indicators for this EAL include those identitml in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.)

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

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

Calvert Oliifs EAL Basis Document Q:3 Rev.7

EQUIPMENT FAILURE l

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

Plant-Speq[ic Information:

The EAL is based on NUMARC. INPO SER 16-92 was reviewed and determined not to apply to Calvert Cliffs '

Annunciator design.

)

1 Thus, the EAL is written as:

l Unplanned Loss of 75% of Main Control Board Annunciators for GREATER THAN 15 Minutes l Source De-ate / References /Caledations:

1. Abnormal Operating Procedures

• AOP-7J, Loss of 120 Volt Vital AC or 125 Volt Vital DC Power

2. Updated Final Safety Analysis Report

3. INPO Significant Event Report (SER) 16-92, Loss of All Annunciation When Computer Lost With Annunciators l

{

j l

I l

Calvert Cliffs EAL Basis Document Q:4 Rev.7  !

i

f~

1 EQUIPMENT FAILURE Emergency Classification Level: UNUSUAL EVENT Apolicable Onerational Modes: ALL l

Calvert Cliffs Initiatina Condition:

i QU3 Unplanned loss of All On-Site or Off Site Communications Capabilities NUMARCRecognition Catenorv: System Malfunction NUMARC Initiatina Condition:

SU6 Unplanned less of All On-Site or Off Site Communications Capabilities Bamer Not Applicable NUMARC Generic Basis: I The purpose of this IC and its associated < Generic > EALs is to recognize a loss of communications capability that l cither defeats the plant operations staff ability to perform routine tasks or the ability to communicate problems with l offsite authorities. The loss of offsite communications capability is expected to be significantly more comprehensive than that addressed by 10 CFR 50.72.

l (Site-specific list) onsite communications loss must encompass the loss of all means of routine communications (i.e., phones, sound powered phone systems, page party rystem and radios /walkie talkies).

(Site-specific list) offsite communications loss must encompass the loss of all means of communications with off-site authorities. This should include the ENS, Bell Lines, FAX transmissions, and dedicated EPP phone systems.

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

Plant-Snecific Information A communication system with multiple redundancy has been provided to ensure availability and case of operation.

The communication system consists of six electronic subsystems:

• Plant Public Address e Sound powered phones for plant use e Commercial Telephone e Sound powered phones for emergency use e Microwave System e Radio telephone system Thus, EAL 1 is written as:

l Loss of ALL On Site Electronic Communications Methods l Communications with off-site authorities are provided by three electronic methods. They are:

Dedicated Off Site Agency Telephone

• CommercialTelephone a

Radio Telephone System EAL 2 is written as:

l less of ALL Telephone Communications With Government Agencies l Calvert Cliffs EAL Basis Document Q:5 Rev.7

EQUIPMENT FAILURE Source Documents / References / Calculations:

1. Emergency Response Plan

+

Chapter 5, Facilities and Equipment;Section II, Communications

2. Emergency Response Plan Implementation Procedures

+

ERPIP 508, Plant Parameters Communicator, EOF

+

ERPIP 901, Communications Equipment i

Calvert Cliffs EAL Basis Document Q:6 Rev.7

EQUIPMENT FAILURE Emeraency Classification Level: UNUSUAL EVENT Anolicable Operational Modes: 1, 2, 3, 4 Calvert Cliffs Initiating Condition:

.QU4 Inability to Reach Required MODE Within Technical Specification Limits NUMARC Ram-nitian Catemory: System Malfunction NUMARC Initiatina Condition:

SU2 Inability to Reach Required Shutdcwn Within Technical Specification Limits Barner. Not Applicable NUMARC Generic 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 CCR 50.72 (b) Non-cmergency 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 < operational > 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 < Electrical, Equipment Failure, Fission Product Barrier Degradation, and Other Hazards > ICs.

Plant-Snecific Information:

LCOs, their associated action statements, and applicable time frames for placing the unit in a shutdown mode are found in the Calvert Cliffs Improved Technical Specifications, Section 3.0.3. When an LCO is NOT met, except as .

provided in the associated action requirements, then other action requirements apply as stated in Applicability, I Section 3.0.

Thus, the EAL is written as:

l Unit Can NOT Be Brought to Required Mode Within Applicable LCO Action Statement Time Limits l l

Source D-ment </ References / Cal & a'inne:

1. - Technical Specifications ITS 3.0, Limiting Conditions for Operations (LCO) Applicability Calvert Cliffs EAL Basis Document Q;7 Rev.7

EQUIPMENT FAILURE Er.esa ;v Classification level: UNUSUAL EVENT Anolicable Operational Modes: 1,2,3,4 Calved Cliffs Initiatine Condition:

QU5 Secondary Depressurization NUMARC Recognition Catemory: Hazards and Other Conditions Affecting Plant Safety NUMARC laitiatine Condition:

HUS Other Conditions Existing Which in the Judgement of the Emergency Director Warrant Declaration of an Unusual Event.

Barrier: Not Applicable NUMARC Generic Emerrency Action Levels Example Emergency Action level:

1. Other cesditions exist which in the judgment of the Emergency Director indicate a potential degradation of the level of safety of the plant.

NUMARC Genericligi.g: i This < Generic > EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which art believed by the <SEC> to fall l unden the Unusual Event emergency class.

Five a broad perspective, one area that may warrant <SEC> judgement is related to likely or actual breakdown of site specific event mitigating actions. Examples to consider include inadequate emergency response procedures, transient response either unexpated or not understood, failure or unavailability of emergency systems during an accident in excess of tha* assumed in accident analysis, or insufficient availability of equipment and/or support personnel.

Specific examples of actual events that may require <SEC> judgement for Unusual Event declaration are listed here for consideration. However, this list is by no means all inclusive and is not intended to limit the discretion of the site to provide further examples.

• Aircraft crash on-site e Train derailment on-site e Near-site explosion which may adversely affect normal si:e actisities.

e Near-site release of toxic or flammable gas which may adversely affect normal site actisities e Uncontrolled RCS cooldown due to Secondary Depressurization e

it is also intended that the <SEC's> judgement not be limited by any list of events as defined here or as augmented by the site. This list is provided solely as examples for consideration and it is recognized that actual events may not a! ways follow a pre-conceived description.

Calvett Cliffs EAL Basis Document Q:8 Rev.7

I

~ EQUIPMENT FAILURE NUMARC Ouestions and Answers. June 10.1993 (General)

6. A majority of the EAL's list several exa.nples for each Initiating Condition. Are utilities required to address each example or select only those examples that are appropriate for the site? Ifit is the Ider,is it required to address in the basis document or NRC submittal why all the other aberu stives were not selected?

Licensees should address each example that Applies to their particular sites. WhRe not required, it is recommended that they also ea; plain uhy those exanples not selected are not i Apphcable. INsposition of all the example MLs willfacihtate the stagreview oflicensee submiatals. It should be noted that ifan ML does not qpply because ofits wording (e.g., valid reading on perimeter radmtion monitoring system greater than 10 mrMr sustainedfor 15 minutes or longer), the lilcensee is en;peded to use other men.u, if avaGable,for entry into the IC. In other nords,for the exenple given above, it may not be enough to state that this ML does not Apply because the licensee does not have a perimeter radiation monitoring system. j The intent is to use all available data to determine whether the IC should be entered.

Plant-Snecific Information:

This IC is to address uncontmiled RCS cooidown due to secondary depressurization.

An EAL 6 esponsive to the GENERIC EAL is addressed in IC OUI, SEC Judgement.

An EAL responsive to aircraft crash on-site is addressed in IC OU3, Destmetive Phenomena.

1 Calvert Cliffs Nuclear Power Plant is not in close proximity to any railroad therefore train derailment is not addressed by this scheme.

An EAL responsive to near-site explosion is addressed in IC OU3, Destmetive Phenomena.

EAL's for near-site release of toxic or flammable gas are addressed in IC OU2, Toxic or Flammable Gas.

l- Uncontrolled RCS cooldown due to secondary depressurization is given as an example uneler the NUMARC .

! Generic Basis for the initiating condition. To reduce the need for judgment in recognizing this condition, a i separate EAL is written. EOP-4 is implemented for uncontrolled RCS cooldown due to secondary depressurization at Calvert Cliffs.

In_ response to Generic EAL 1, Calvert Cliffs EAL is written: __

l EOP-4, Excess Steam Demand Event,is implemented. I l l

t Source Documents / References / Calculations:

l l 1. EOP-4, Eness Steam Demand Event i

l Calvert Clifts EAL Basis Document Q:9 Rev.7

EQUIPMENT FAILURE i

l Emeraency Classification Level: ALERT AnaliM!c Operational Modes: 1, 2

! Qdyert Cliffs laitiating Condition:

l QAl Failure of Automatic Reactor Trip NUMARC Rwaisian Catenotv: System Malfunction l

NUMARC Imtiatinn Condition:

SA2 Failure of Reactor Protection System Instrumentation to Complete or Initiate an Automatic Reactor Scram Once a Reactor Protection System Setpoint Has Been EFwded and Manual Scram Was Successful Bamer Not Applicable NUMARC Generic Basis:

This condition indicates failure of the automatic protection system to scram the reactor. This condition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient and thus the plant safety has been compromised, and design limits of the fuel may have been exceeded. An Alert is indi:ated because conditions exist that lead to potential loss of fuel clad or RCS.

Reactor protection system setpoint being exceeded (rather than limiting safety system setpoint being exceeded) is specified here because failure of the automatic protection system is the issue. A manual scram 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 bangs the reactor subcritical (e.g., reactor trip button). Failure of manual scram would escalate the event to a Site <E>mergency.

Plant-Soccific Information:

Exceeding nny of the following setpoints should result in an automatic reactor trip:

REACTOR TRIP COINCIDENCE SETPOINT High Power Level 2/4 Variable High Rate-of-Change of Power 2/4 helow 15% RTP 2.6 decade / min.

Low Reactor Coolant Flow 2/4 above 10-4% RTP Variable Low Steam Generator Pressure 2/4 670 psig Low Steam Generator Water Level 2/4 10" below top of feed ring High Pressurizer Pressure 2/4 2385 psig Thermal Margin / Low Pressure 2/4 above 10-4% RTP Variable Loss of Load 2/4 above 15% RTP N/A l High Containment Pressure 2/4 4 psig

( Axial Flux Offset 2/4 Variable i ThermalMa gin /SG Press. Diff. Hi 2/4 above 10 4% RTP 135 psid

{

) Per EOP-0, Post Trip Immediate Actions, the operator is to ensure that the reactor has tripped by depressing one set of Manual Reactor Trip buttons immediately following any symptoms of a reactor trip. These symptoms include:

l Calver. Cliffs EAL Basis Document Q:10 Rev.7 i

i EQUIPMENT FAILURE Reactor Trip alarm Control Element Assembly (CEA) Circuit Breaker (s) Trip alarms

+

Rapid Lowering in Reactor Power Protection ChannelTrip alarm Reactor Protective System (RPS) Trip Bistable Lights lit Following depression of the reactor trip buttons, the operator is to verify that reactor power is decreasing. If these responses can Igg be verified, then as part of contingency actions, the operator is instmeted to open the motor i generator (MG) set feeder breakers providing power to the Control Element Drive Mechanism (CEDM).  ;

Entry into the Alert emergency classtfcation occurs whenever it is determined by the Shsp Supervisor that a required automatic reactor trip did not occur, based on the entry conditions into EOP-0 listed above. It is \

recogmzed that EOP 0 mstructs the operator to depress the manual trip buttons, whether or not a required automatic reactor trip actually occurred. However, the failure of a redundant front-line automatic protection system function (i.e., the failure of the RPS to complete a reactor trip following receipt of a trip signal) meets the Alert classification threshold of potential substantial degradation in the level of safety of the plant. This is true whether or not fuel damage is determmed to have occurred.

Thus the EAL is written as:

Automatic Reactor Trip Signal Generated AND Manual Trip Was Required to Trip the Reactor (EOP-0, Post-Trip Immediate Actions. Reactivity Control Successful)

Source Documents / References /Ce!~Nione:

1. Technical Specifications

+

ITS 3.3.1, Reactor Protective System (RPS) Instrumentation - Operating

+

ITS 3.3.2, Reactor Protective System (RPS) Instrumentation - Shutdown

+

ITS 3.3.3, Reactor Protective System (RPS) Logic and Trip Initiation

2. Emergency Operating Procedures

+

EOP-0, Post-Trip Immediate Actions

3. Updated Final Safety Analysis Report

+

Chapter 7, Instnrentation and Control Calvert Cliffs EAL Basis Document Q:11 Rev.7

EQUIPMENT FAILURE i

Eiiwiu.cv Ch inmian Level: ALERT 1 1

ApplicableOperauonalModes 5,6 l

! Calvert Cliffs Initiatina Condition:

QA2 Inability to Maintain Plant in Cold Shutdown NUMARC Recoenition Catemory: System Malfunction NUMARC Initiatina Condition:

l l SA3 Inability to Maintain Plant in Cold Shutdown -

Barrier: Not Applicable l

I NUMARC Generic Basis:

1 This IC and its associated EAL address complete loss of functions required for core cooling during refueling and

]

cold shutdown modes. Escalation to Site <E>mergency or General Emergency would be sia <Radioactisity Release l or SEC Judgement > ICs. l For PWRs, this IC and its associated EAL are based on concerns raised by Generic Letter 88-17, Loss of Decay

Heat Removal. A number of phenomena such as pressurization, vortexing, steam generator U-tube draining, RCS l level differences when operating at a mid-loop condiuon, decay heat removal system design, and level j instrumentation problems can lead to conditions where decay heat removal is lost and core uncovery can occur.

l NRC analyses show sequences that can cause core uncovery in 15 to 20 minutes and severe core damage within an hour after decay heat removal is lost. Under these conditions, RCS integrity is lost and fuel clad integ'i? is lost or i l potentially lost, which is consistent with a Site <E>mergency. (Site-specific) indicators for these EALs are those

methods used by the plant in response to Generic Letter 8817 which include core exit temperature monitoring and l RCS water level monitoring. In addition, radiation monitor readings may also be appropriate as indicators of this condition.

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

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

Escalation to the Site <E>mergency is by <Radioactisity Release > ICs.

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

and how this may be a factor in escalating the emergency class.

Plant-SpecificInformation:

Per Calvert Cliffs Technical Specifications, the functions required to be operable daring Cold Shutdown and Refueling modes and are associated with maintaining required shutdown conditions (temperature, pressure, and subcriticality)are:

Reactivity Control Systems (ITS 3.1)

RCS Loops - Mode 1 & 2 (ITS 3.4.4)

RCS IAops - Mode 3 (ITS 3.4.5)

RCS Loops - Mode 4 (ITS 3.4.6)

RCS IAops - Mode 5 (ITS 3.4.7, 3.4.8)

Calvert Cliffs EAL Basis Document Q:12 Rev.7

I i

I~ j EQUIPMENT FAILURE Shutdown Cooling and Coolant Circulation - High Water Level (ITS 3.9.4)

Shutdown Cooling and Coolant Circulation - Low Water Level (ITS 3.9.5)

=

Pressurizer Safety Valves (ITS 3.4.10) l- Low Temperature Overpressure Protection (LTOP) System (ITS 3.4.12)

+

l Electrical Power Systems (ITS 3.8)

AC and DC power systems availability are separately addressed under the Electrical Event Category. Thus, these

! are not addressed under this Initiating Condition. RCS leakage hg., requiring use of the Charging /HPSI

! Subsystems or resulting from Overpressure Protection System malfLnctions) are addressed by IC BU2, RCS l Leakage, and the Radioactivity Release ICs related to uncovery of irradiated fuel. Boration systems are addressed l by EAL 2 discussed below.

EAL 1 is written as:

Uncontrolled RCS Temperature Increase of AT LEAST 10*F That Results in RCS Temperature GREATEI  !

l.

THAN 200*F j t '

This corresponds to the inability to maintain required temperature conditions for Cold Shutdown. The 10*F threshold was picked to assure that minor cooling interruptions occurring at the transition between Mode 4 and Mode 5 (that are already addressed by QUI) do not result in unnecessary declaration of an Alert. j i

1 Uncontrolled means that the temperature increase is not due to deliberate operator action.  :

1 Cold Shutdown and Refueling modes are defined by specific plant conditions - core reactisity condition and reactor i l coolant temperature / pressure. Maintenance of the ability to remove core decay heat addresses coolant temperature.

The reactivity condition is addressed by maintenance of required shutdown margin. At the Alert emergency classification, this corresponds to assuring that the reactor is not critical.

Thus. EAL 2 is written as: l l Inadvertent Criticality as Determined by Valid Wide Range Logarithmic Channel Indications l l

Inadvertent means accidental or unintentional, e.g., the event occurred because procedures were not strictly adhered to.

Valid means that the indication is from instrumentation determined to be operable in accordance with the

Technical Specifications or has been verified by other independent methods such as indications displayed on the j control panels, reports from plant personnel, or radiological survey results.

Source De.uusrds/ References / Calculations:

i l 1. Technical Specifications i 2. Abnormal Operating Procedures

+

l AOP-3B, Abnormal Shutdown Cooling Conditions l

3. NUREG 1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States, DraA for Comment, February 1992 Calvert Cliffs EAL Basis Document Q:13 Rev.7

1 EQUIPMENT FAILURE Emernency C1=&atian Level: ALERT Anchcable Operational Modes 1,2,3,4 Calvert Cliffs Initiatina Canditian:

QA3 Unplanned Loss of S: *y System Annunciators With Transient In Progress NUMARC Racanaisian Category: System Malfunction NUMARC f aitiania= Caadisian:

SA4 Unplanned less of Most or All Safety System Annunciation or Indication in Control Room With Either (1) a Significant Transient in Progress, or (2) Compensatory Non-Alarming Indicators are Unavailable Bamer: Not Applicable NUMARC Generic Basis:

This IC and its associated < Generic > EAL are ' intended to recognize the difficulty associated with monitoring changing plant conditions with the use of a major portion of the annunciation or indication equipment during a transient. Recognition of the availability of computer based indication equipment is considered (SPDS, plant computer, etc.).

Planned loss of annunciators or indicators includes scheduled maintenance and testing activities.

Quantification of most is arbitrary, however, it is estimated that if approximately 75% of the safety systems annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected.

It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgement threshold for determining the severity of the plant conditions. This judgement is supported by the specific opinion of the Shift Supervisor that additional operating personnel will be required to proside increased monitoring of system operation to safely operate the unit (s).

It is further recognized that most plant designs provide redundant safety system indication from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to the difficulty associated with the assessment of plant conditions. The loss of specific, or several, safety system indicators should remain as a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is *not in compliance with the Technical Specification action, the Unusual Event is based on <IC QU4, Inability to Reach Required MODE Within Technical Specification Limits >.

(Site-specific) annunciators or indicators for this < Generic > EAL must include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.)

Significant transient includes response to automatic or manually initiated functions such as scrams, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10% or greater.

Calvert Cliffs EAL Basis Document Q:14 Rev.7

EQUIPMENT FAILURE i

l Compensatory non-alarming indications in this context include computer based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits. If a major portion of the annunciation system and all computer monitoring <both> are unavailable

<such> that the additional operating personnel are required to monitor indications, the Alert is required..

i 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.

This Alert will be escalated to a Site <E>mergency if the operating crew cannot monitor the transient in progress.

Plant-Snecific Information:

Compensatory non-alarming indications include the Safety Parameter Display System (SPDS) and the plant j computer, l

Thus, the EAL is written as

Unplanned Loss of 75% of Main Control Board Annunciators for GREATER THAN 15 minutes AND EITHER of the Following:

Significant Transient in Progress

. SPDS AND Plant Computer NOT Available l

Escalation to S'te Emergency would be based on plant transient response, occurrence of other equipment malfunctions requiring operator actions outside the control room, or loss of additional monitoring instrumentation (such as ICC instrumentation) required to determine plant conditions.

Source Documents / References /Calculatiopf

1. Abnormal Operating Procedures

- AOP-71, Loss of Vital 120V AC or 125V Vital DC Power

2. Updated Final Safety Analysis Report Calvert Cliffs EAL Basis Document Q:15 Rev 7

EQUIPMENT FAILURE Emeraency C6 ification Level: ALERT Apphcable Operational Modes DEFUELED Calvert Cliffe Inisi=*ina Caa** ion:

QA4 Station Blackout While Defueled

)

NUMARC Recognition Catenary: System Malfunction NUMARC Initiatina Conditio!!:

sal less of All Off-Site Power and Loss of All On-Site AC Power to Essential Busses During Cold Shutdown Or Refueling Mode Bamer Not Applicable NUMARC Generic Basis:

Loss of all AC power compromises all plant safety systems requiring electric power int iding RHR, ECCS, Containment Heat Removal, Spent Fuel Heat Removal and the Ultimate Heat Sink. When *

• cold shutdown, refueling, or defueled mode the event can be classified as an Alert because of the significantly ..duced decay heat, lower temperature and pressure, increasing the time to restore one of the emergency busses, relative to that l specified for the Site Emergency EAL. Escalating to Site <E>mergency, if appropriate, is by < Radioactivity Release or SEC> Judgement ICs. Fifteen minutes was selected as a threshold to exclude transient or momentary I power losses.

Plant-Snecific Information:

Of concern during defueled conditions is the loss of Spent Fuel Pool cooling. If either Unit has fuel in its reactor vessel then a Site Emergency or Alert will be declared under Initiating Condition ESI and EAl respectively for loss of all off-site power and loss of all on-site AC power to essential busses This Initiating Condition (QA4) applies when both Units are defueled. When defueled, contingency plans are implemented for Spent Fuel Pool cooling malfunction regardless of the reason. Contingency plans are implemented concurrent with the problem recognition to restore power. To exclude declarations because of transients or momentary power losses, the temperature threshold of 155'F was selected. Temperature at this level (design temperature for the system) is a more appropriate indication that the loss of cooling and inability to restore it are an Alert level threat.

Thus the EAL is written as:

l Power to Spent Fuel Cooling Pumps lost AND Spent Fuel Pool temperature increases to greater than 155'F. l Source D:-:a r===/ References /C=Wa'ione:

1. Abnormal Operating Procedures AOP-3B, Abnormal Shutdown Cooling AOP 6F, Spent Fuel Pool Cooling System Malfunctions

2. UFSAR, Chapter 9.4. Spent Fuel Pool Cooling System Calvert Cliffs EAL Basis Document Q:16 Rev.7

i;

)

)

EQUIPMENT FAILURE Emgtgricy Classification Level: SITE EMERGENCY I

Anolicable Onerational Modes: 1, 2 Calvert Cliffs Initiatino Condition:

QS1 Failure of BOTH Automatic AND Manual Reactor Trip HLDWARC R=enitian Catenory: System Malfunction NLQdARC Jaitiatmg Condition SS2 Failure of Reactor Protection System Instrumentation to Complete or Initiate on Automatic Reactor Scram Once a Reactor Protection System Setpoint Has Been Exceeded and Manual Scram Was NOT Successful Bamer. Not Applicable NUMARC Generic Basis: l l

Automatic and manual scrams are not considered successful if action away from the reactor control console was l

required to scram the reactor. i Under these conditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed. A Site <E>mergency is indicated because conditions exist that lead to imminent loss or potential loss of both fuel clad and RCS. Although this IC may be viewed as redundant to the Fission Product Barrier Degradation IC, its inclusion is necessary to better assure timely recognition armi emergency response.

Escalation of this event to a General Emergency would be via Fission Product Barrier Degradation or <SEC Judgement > ICs.

Plant SnecificInformation:

EOP-0, Post Trip Immediate Actions, are described under IC QAl, Failure of Automatic Reactor Trip. As stated under QAl, entry into the Alert emergency classification occurs whenever it is determined by the Shift Supersisor that a required automatic reactor trip did not occur, based on the entry conditions into EOP-0. Entry into the Site Emergency is made consistent with EOP-0 procedural requirements and so corresponds to g91 satisfying the reactivity control criteria of EOP-0. This means that both automatic and manual ~ actions were apt effective in bringing the reactor suberitical and that entry into EOP-8, Functional Recm cry Procedure, is required.

Thus, the EAL is written as:

EOP-8, Functional Recovery Procedure, is Implemented per EOP 0, Post Trip Immediate Actions, Reactivity Control Can NOTis used because the ability to meet the final =~an== criteria is the appropriate concern, not whether intermediate a-== criteria are not being achieved at one point in time.

Source Documents / References / Calculations

1. Emergency Operating Procedures

+ EOP0, Post-TripImmediate Actions

+ EOP-8, Functional Recovery Procedure f

Calvert Cliffs EAL Basis Document Q:17 Rev.7

l EQUIPMENT FAILURE Eirse. cv Cheehtion level: SITE EMERGENCY Aonlicable Ooerational Modes 1,2,3,4 i-Calvert Cliffs Initiatina Condition:

QS2 Complete Loss of Function Needed to Achieve or Maintain Hot Shutdown l NUMARC Rect tnition Catenorv: System Malfunction I- NUMARC Initiating Condiuon:

l SS4 Complete Loss of Function Needed to Achieve or Maintain Hot Shutdown I l Bamer. Not Applicable l NUMARC Generic Basis:

This <IC and its associated Generic EAl> address complete loss of functions, including ultimate heat sink and I reactivity control, required for hot shutdown with the reactor at pre 3ure 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

<E>mergency is warranted. Escalation to General Emergency would be via <Radioacthity Release, Fission Product Barrier Degradation, or SEC Judgement > ICs.

I Multi-unit stations with shared safety functions should further consider how this IC may affect more than one unit and how this may be a factor in escalating the emergency class.

Plant SoecificInformation:

Per Calvert Cliffs Technical Specifications or TechnicalR' equirements Manual (TRM), the following functions are required to be operable during Cold Shutdown and Refueling modes and are necessary to maintain Hot Shutdown (Mode 4) conditions (temperature, pressure, and subcriticality):

• Reactivity Control Systems (ITS 3.1)

RCS Loops - Mode 1 & 2 (ITS 3.4.4)

RCS Loops - Mode 3 (ITS 3.4.5)

RCS Loops - Mode 4 (ITS 3.4.6)

RCS Loops - Mode 5 (ITS 3.4.7, 3.4.8)

Shutdown Cooling and Coolant Circulation - High Water Level (ITS 3.9.4)

Shutdown Cooling and Coolant Circulation - Low Water Level (ITS 3.9.5)

ECCS Operating and Shutdown (ITS 3.5.2,3.5.3)

Refueling Water Tank (ITS 3.5.4)

• Pressunzer Safety Valves (ITS 3.4.10)

+

Service Water System (ITS 3.7.64)

+

Low Temperature Overpressure Protection (LTOP) System (ITS 3.4.12)

Electrical Power SystemsfrS 3.8)

Instrumentation (TRM 9.3)

Reactor Coolant System Vents (TRM 9.4.6)

AC and DC power systems availability are separately addressed under the Loss of Power Event Category. Thus, these are not addressed under this initiating Condition. The Overpressure Protection System and Reactor Coolant System Vents are not directly related to core cooling and suberiticality functions. Failures of these systems functions resulting are addressed by Fission Product Barrier Degradation ICs. Loss of Monitoring Instrumentation is not directly related to maintaining suberiticality and heat removal functions, and therefore is not required to be addressed by this IC.

Calvert Cliffs EAL Basis Document Q:18 Rev 7

EQUIPMENT FAILURE Per AOP-3B, Abnormal Shutdown Cooling Conditions, auxiliary feedwater and atmospheric steam dump capability to at least oc SG is necessary to achieve Hot Shutdown conditions under natural circulation conditions.

)I Around the transition froin Mode 3 to Mode 4, the Shutdown Cooling System (SDCS) is typically used as the means to remove sensible and decay heat.

Once the SDCS is placed in service, the steam generator heat sink capability is no longer necessary. Thus, the EAL  ;

reflects that neither the steam generators nor Shutdown Cooling are fully capable of performing heat removal functions. The applicable acceptance criteria for Core and RCS Heat Removal are shown on the Safety Function  ;

Status Checks and are fully explained under the basis information for EAL FCB1, Safety Function I Status / Functional Recovery.

Per improved Technical Specification Table 1.1-1, Modes, the required SDM is eK gless than 0.99 for Mode 4 l (Hot Shutdown). 'Ihe existence of a positive startup rate that could not be climinated by operation of any reactivity control mechanism corresponds to conditions where a major function intended for the protection of the public has I failed and therefore meets the threshold for a Site Emergency classification.

Thus. EAL 1 is written as:

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

+

Reactivity Control Acceptance Criteria Can NOT Be Met

+

Shutdown Cooling is NOT in Service AND Core and RCS Heat Removal Acceptance Criteria Can NOT Be Met Can NOT is used because the ability to 7ncet the final acceptance criteria is the appropriate concern, not whether ,

intermediate acceptance criteria are not being achieved at one point in time.  !

In service means that the SDCS is in the proper configuration for RCS heat removal (SDCS isolation valves open, LPSI pumps operating, etc.) and is considered " operable" as defined in the Calvert Cliffs improved Technical Specifications Section 1.1.

In order for there to be a path for heat removal between the core and the steam generators or the shutdown cooling system, there must be enough RCS liquid inventory to maintain natural circulation. Recent information from the CE Owners Group indicates that two-phase natural circulation (reflux boiling) works very well and will maintain the RCS between 200 'F and 300 'F. This requires that the RCS water level be below the top of the hot legs. Per AOP-3B, Attachment 14,50" RVLMS Indication corresponds to the middle of the hot leg and is the 5th RVLMS alarm level. Staying above this level (and below the top of the hot legs at the 71" level) assures that, at a minimum, reflux boiling can be maintained.

Thus, EAL 2 is written as:

Zero (0) Indicated Subcooling Margin Determined Using CET Temperatures AND Valid RVLMS Level Indication of LESS THAN 50 Inches Source DeanentdReferences/Ce!44n=: -

1. Technical Specifications

2. Abnormal Operating Procedures

+

AOP-3B, Abnormal Shutdown Cooling Conditions

3. Emergency Operating Procede;res

+

EOP-8, Functional Recovery Procedure

4. Internal Memorandum, J. R. Hill to R. L. Wenderlich, CE Operations Subcommittee Meeting - Trip Report, April 16,1993

5. Technical Requirements Manual Calvert Cliffs EAL Basis Document Q:19 Rev.7

1 l

EQUIPMENT FAILURE l

Emergency Classification Level: SITE EMERGENCY

, Anoticable Operational Modes: 5, 6 l

Calvert Cliffs initiating Conditsh:

QS3 Loss of Water Level That Can Uncover Fuel in the Reactor Vessel NUMARC Initiatina Condition:

SS5 Loss of Water Level in the Reactor Vessel That Has or Will Uncover Fuel in the Reactor Vessel Bamer: Not ApplicablemEL CLAD NUMARC Generic Emernency Action Levels Example Emergency Action Level:

1. Loss of Reactor Vessel Water Level as indicated by:

a. Loss of all decay beat removal cooling as determined by (site-specific) pmcedure.

AND

b. (Site-specific) indicators that the core is or will be uncovered. I NUMARC Generic Basij:

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

Thus, declaration of a Site <E>mergency is warranted under the conditions specified by the IC. Escalation to a General Emergency is via < Radioactivity Release IC RGI, Off-Site Dose of AT LEAST 1 REM (EDE+ CEDE)

Whole Body or 5 REM (CDE) Thyroid >.

l NUMARC Ouestions and Answers. June 10.1993 (System Malfunction)

None Plant-Soccific Information Sequences that can result in uneevery of fuel in the reactor vessel being uncovered (indirectly by piolonged boiling) include leakage through SG nozzle dams, pipe breaks in the Shutdown Cooling (SDC) System or Chemical & Volume Control System (CVCS), or loss of the SDC function. These leakage sources are outside the reactor vessel and aHnest could only result in water level decreases to the bottom of the hot leg elevation. This water level decrease would cause loss of SDC due to loss of SDC suction. Loss of SDC can lead to prolonged RCS boiling. Eventually fuel in the vessel will be uncovered. In-core instrumentation (ICI) penetratians for Calvert Cliffs are through the reactor vessel head. Given this, ICI leakage can not cause reactor vessel water loss that will threaten the loss of SDC Thus, the ICI's4hese do not have to be considered for this IC.

t Calvert Cliffs EAL Basis Document Q:20 Rev.7

EQUIPMENT FAILURE A review of attachments to AOP-3B, Abnormal Shutdown Cooling Conditions, shows that depending on presious power history and assuming an initial RCS temperature of 140*F, boiling in the core can begin in as little as 7 minutes following loss of SDC during mid-loop operation. AOP-3B also shows that under these conditions, without I any operator action, the core can start to be uncovered rrerj : . i:j:: within about 80 minutes after loss of i SDC.

Methods available Avenlable-menbeds to restore RCS inventory and to remove core heat include restoring the SDCS, injecting water into the RCS from the Refueling Water Tank (RWT) using the HPSI, LPSI, CS cr charging pumps, using the steam generators as a heat sink, using the Refuelirg Pool as a heat sink, aligning a LPSI pump to take suction from the RWT, or even injecting water into the RCS using Safety Injection Tanks (SITS). 9:== *:

.._n:: :l.=::h2 :: ::::::: l ==:: y, =i & ==:_..: :l::=: == !d!:, ' :: high!y =' b!y :h:: A:: !C :- !! &

• • red-In response to Generic EAL 1, Calvert Cliffs EAL is written: S : 6 EAL i: =& =: l AOP-3B, Abnormal Shutdown Cooling Conditions, is Implemented AND ANY of the Following Conditions Exist: ,

Alternate' Methods for Restoring RCS Inventory Are NOT Effective l Valid RVLMS Reading Indicating Z L cd Water level above the core is Ten Inches or Less.

- Valid CET Reading Indicating Superheat Conditions AOP-3B is tbt Calvert Cliffs precedure used to determine tbc loss of decay beat removal cooling. The three bul!cted items are indicators that the core is or will be uncovered. With respect to the RVLMS, the last light to illuminate on the instrussent is referred to as the 10" light. When this light is lit the water level in the l vessel has descended to 10" above the top to the active core.  ;

NOT Efective means that RCS inventory is not being restored based on available operable instrumentation readings (e.g. M = CETs, RVLMS, Hot Leg Level), or from decreasing level indications from applicable suction sources such as the RWT, containment sump, or SITS.

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

Source Ds.u-crds/ References /Chh@ns:

1. Abnormal Operating Procedures

+

AOP-3B, Abnormal Shutdown Cooling Conditions l

l l,

1 Calvert Cliffs EAL Basis Document Q:21 Rev.7

l

{

EQUIPMENT FAILURE Emernency Classification Level: GENERAL EMERGENCY -

ApphcableOperauonalModes 1 Calvert Clifs Initinaian Condition: 1 Qiil Failure of BOFIE Automatic AND Manual Reactor Trip -AND-Extreme Challenge to the Ability to Cool the Core NUMARC Recoenition Catenorv: System Malfunction NUMARC Imuaung Condnuon SG2 Failure of the Reactor Protection System to Complete an Automatic Scram and Manual Scram was NOT i

Successful and There is Indication of an Extreme Challenge to the Ability to Cool the Core 1 Bamer: Not Applicable' i i

l NUMARC Generic Basis:  !

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

I Under the conditions of this IC and its associated < Generic > EAL, the eNorts to bring the reactor subcritical have I r as a result, the reactor is producing more heat than the maximum decay heat load for which been naam ul and, the safety systems were designed. Although there are capabilities away from the reactor control console, such as i emergency boration, o the continuing temperature rise indicates that these capabilities are not cNective. This situation could be a precursor for a core melt sequence.

For PWRs, the extreme challenge to the ability to cool the core is intended to mean that the core exit temperatures are at or approaching 1200 F or that the reactor vessel water level is below the top of the active fuel. o Another consideration is the inability to initially remove heat during the early stages of this sequence. For PWRs, if emergency feedwater flow is insufficient to remove the amount of heat required by design from at least one steam generator, an extreme challenge should be considered to exist. o In the event either of these challenges exist at a time that the reactor has not been brought below the power associated with the safety system design (typically 3% to 5% power), a core melt sequence exists. In this situation, core degradation can occur rapidly. For this reason, the General Emergency declaration is intended to be anticipatory of the fission product barrier matrix declaration to permit maximum orTsite intervention time. j Plant-Snecific Inforrnation:

EOP 0, Post-Trip Immediate Actions, are described under IC QAl, Failure of Automatic Reactor Trip. As stated under QS1, entry into the Site Emergency classification means that both automatic and manual reactor trip were gg effective in bringing the reactor subcritical and that functional recovery of reactivity control is required in accordance with EOP-8. Escalation to the General Fmergency is indicated whenever Reactor power is p_ql ,

decreasing following actions to bring the reactor suberitical including automatic and manual reactor trip, manually  !

inserting the control rods, tripping the CEDM motor generator sets or performing emergency boration and there l are indications ofinadequate core cooling.

l i

l Calvert CliNs EAL Basis Document Q:22 Rev.7 i

EQUIPMENT FAILURE Thus, the EAL is written as:

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

+

Reactivity Control Can NOT Meet Acceptance Criteria AND

)

l

+

Core and RCS Heat Removal Can NOT Meet Acceptance Criteria Can NOT is used because the ability to meet the final EP e criteria is the appropriate concern, not whether intermediate acceptance criteria are not being achieved at any given moment.

Source Documents / References / Calculation _s:

1

1. Emergency Operating Procedures I EOP-0, Post Trip Immediate Actions

+

EOP-8, Functional Recovery Procedure .

i i

1 l

l i

1 l

l I

l I

i l

Calvert Cliffs EAL Basis Document Q:23 Rev.7 i

ELECTRICAL Calvert Cliss EAL Basis Document Rev.7

l t

ELECTRICAL Emernency Classification Level: UNUSUAL EVENT Anoticable Operational Modes: ALL L

Calvert Cliffs Initiatina Condition:

I EU1 Loss of Off-Site Power NUMARC Recognition Categgry.; System Malfunction NUMARC Initiatina Condition:

SUI Loss of All Off Site Power to Essential Busses for Greater Than 15 Minutes l Bamer: Not Applicable l NUMARC Generic E cru cv Action levels Example Emergency Action Level:

i'

1. The following conditions exist:

a. Loss of power to (site-specific) transformers for grester than 15 minutes.

AND

b. At least (site-specific) emergency generators are supplying power to emergency busses.

NUMARC Generic Basis:

Prolonged loss of AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete Loss of AC Power (Station Blackout). Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Multi-unit stations with shared safety functions should further consider how this IC may affect more than one unit and how this may be a factor in escalating the emergency class.

NUMARC Ouestions and Answers. June 30.1993 (System Malfunction)

1. Does the EAL of SU1 apply to one unit whose essential busses can be energized from another (unaffected) unit at a multi-unit site?

SUI does apply to this situation. Pfants that have the capability to cross-tie powr from o companion unit may take creditfor the redundantpowr source in the associated EALfor this IC. Inability to efed that cross-tie within 15 minutes is groundsfor declaring the Unusual Event.

Calvert Cliffs EAL Basis Document E:1 Rev.7

4 i

ELECTRICAL Plant-Snecific Information:

" :- ' - : EO" 2, ' -- c'O" "i:: ":;;r, ; :df k 2 ;'--- ^ " - '-- S :-- f': r: c'--- . ^.OP 3F ;;'ir

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at*few-

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1

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less of all oN-site power to essential busses at Calvert Cliffs is realized when all oN-site 500kV and i

69kV/13kV SMECO power is lost to both 4kV Safety Related Buses on either Unit (applies to all operational modes). Rather than listing transformers that would be deemergized when the condition exists (as is suggested in the Generic EAL) Calvert CliNs describes the condition in the EAL. This will make the EAL l casier to use. Calvert CliNs EAL does not include a qualifying "AND" statement tl'at essergency generators are supplying power to the emergency busses. His qualifier is not needed. The loss of all oNsite power to the essential busses will be recognized without it. Being a two unit site with the ability to cross-tie power j from the other (unaNected) unit, credit is taken for the redundant power source (i.e. either Unit's 4kV Safety l Related Bus (es) may be powered from the other Unit's 500kV supply).

In addition, Calvert Cliffs Improved Technical Specifications (3.8.1) describe a third ofsite power source available from Southern Maryland Electric Cooperative (SMECO). De SMECO tic line is a 69kV/13kV onsite power source that may be connected to either 13kV bus and then to the 4kV safety related bus (es) on eitber or both units. Under certain operational conditions,13kV bus (es) may be aceiving power from SMECO or may be quickly connected to the SMECO tic line. If offsite power is restored within 15 minutes, whether from the 500kV lines or from the 69kV/13kV SMECO tie line, then the entry conditions for the EAL are not being met and the EAL does not apply.

In nsponse to Generic EAL 1, Calvert CliNs EAL is written

t.r E ^11 i: r-tr =:

EGP.414ss of All Off-site 500 kV AND 69kV/13kV SMECO Power to both 4 kV Safety Related Buses on , ' . '--- ^ ' O- Either Unit for '-- c' " d: y..cx GREATER THAN 15 minutes.

l E.^L 2 -i:  : hr :!:" d:, .c= ~.k; ECP 2 tz ::' .;;!;. .

Bus-EAL2 i:: '- - =: -

Of C" Si:: ". ;;r '= SP." ^.T"? " ^." ! 5 ' ' -

l_ ' _

l i

l Source Documents / References /Ca.1M=' ions:

1. Technical Specifications ITS 3.8.1, A.C. Sources - Operating ITS 3.8.2 A.C. Sources - Shutdown

2. " r;:rj&,r";":xfcx

"^" ' .,'. =. -f 0" ",.2 '. ".. x=

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1 a.

m_,

.A.f,in . ..1. D,1 - _ _ . .f f,,%M c.:._ M _ .. ._ MrL Ii _ : E d _ J ,__-_,,A,,C,_.f.

Calvert Cliffs EAL Basis Document E:2 Rev.7 1

I

L l

ELECTRICAL Emisncy Classification Level: UNUSUAL EVENT Anulicable Onerational Modes: All Calvert Cliffs Initiatine Condition:

EU2 Loss of Vital 125 Volt DC Power for GREATER THAN 15 Minutes NUMARC Ramanisian Catenory: System Malfunction l NUMARC Initiating Condition:

i i

SU7 Unplanned Loss of Required DC Power During Cold Ehutdown or Refueling Mode Greater Than 15 Minutes 1

[ Bamer Not Applicable NUMARC Generic Basis:

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

equipment needed to respond to the loss. l Unplanned is included in this IC and EAL to preclude the declaration of an emergency as a result of planned i maintenance activities. Routinely, plants will perform maintenance on a train related basis during shutdown l periods. It is intended that the loss of the operating (operable) train is to be considered, if this lors results in the l

inability to maintain cold shutdown, the escalation to an Alert will be per <QA2, Inability to Maintain Plant in l Cold Shutdown >. 1 (Site-specific) bus voltage should be based on the minirnum bus voltage necessary for the operation of safety related I equipment. This voltage value should incorporate a margin of at least 15 m.nutes of operation before the onset of inability to operate those loads. This voltage is usually near the minimum voltage selected when battery sizing is performed. Typically, the value for the entire battery set is approximately 105 VDC. For a 60 cru string of batteries the cell voltage <is typically > 1.75 volts / cell. For a 58 string battery set the minimum voltage is typically 1.81 volts / cell.

Plapt-Snecific Information:

The 125 volt de and 120 volt vital ac systent.s for the plant are divided into four independent and isolated channels.

Each channel consists of one battery, two battery chargers, one dc bus, multiple de unit control panels, and two inverters. Each inverter has an associated vital ac distribution panel board. Power to the de bus, de unit control panels, and inverters is supplied by the station batteries and/or the battery chargers.

Each battery charger is fully rated and can recharge a discharged battery while at the same time supplying the steady state power requirements of the s)*cm.

l A reserve 125 volt de system for the plant is completely independent and isolated from all four separation groups, yet is capable of replacing any of the 125 volt de batteries. This system consists of one battery, one battery charger, 1 and the associated DC switching equipment. Only the battery may be transferred for replacement duty.

Calvert Cliffs EAL Basis Document E:3 Rev.7

i ELECTRICAL i

The 125 volt de bus 11 provides control power for equipment associated with load group A for both units. The 125 volt de bus 21 provides control power for equipment associated with load group B for both units. The 125 volt dc buses 12 and 22 are used to supply power to the computer inverters, control room emergency lighting, and two ,

channels of the 120 volt vital ac system.

Here is one battery charger fed from Unit I and another battery charger fed from Unit 2 connected to each 125 i vc't de bus. The ac power for both battery chargers per bus is obtained from the same load group. The reserve battery is connected to its own charger when it is not connected to a safety related 125 volt de bus.

Each of the four 125 volt de power sources is equipped with the following instrumentation in the control room to enable continual operator assessment of 125 volt de power source condition:

DC bus undervoltage alarm  ;

+

Battery currentindication i

+ Charger current indication Charger malfunction alarm (including input ac undervoltage, output de undervoltage, and output de overvoltage)

+ DC bus voltageindication, and

+

DC ground indication Components affected by the loss of 125 volt de buses 11,12,21, or 22 are listed in table EU2-1. Loss of the new Diesel Generator I A 125 voit DC bus 14 does not constitute an entry condition for this EAL.

CCNPP Ouestions and Answers (Electrical)  ;

e Why does the 125 volt DC bus 14 need to be addressed in tbc basis if it has no impact on tbc EAL?

Site Emergency Coordinators askedfor documentation in the basis, that the new 125 voit DC bus 14 was consideredfor the elec#ical EAL's. AOP-7J lists the equipment that is lost ff bus 14 is lost.

In response to the Genedc EAL, Calvert Cliffs EAL is written: E= S EAL i::tx =:

AOP-7J Loss of 120 Volt Vital AC or 125 Volt Vital DC Power, is Implemented AND 125 Volt DC Power Lost for GREATER THAN 15 Minutes Source Documents / References / Calculations:

1. Abnormal Operating Procedures

• AOP-7J, Loss of 120 Volt Vital AC or 125 Volt Vital DC Power

2. Updated Final Safety Analysis Report

3. BGAE Drawing 61030-E, Single Line Diagram, Vital 120V AC & 125V DC - Emergency 250V DC

4. BG&E Drawing 61-057-E, Block Diagram - Auxiliary System Load Groups - Units 1 & 2 Calvert Cliffs EAL Basis Document E:4 Rev.7

I ELECTRICAL Table E-1: Effects ofLoSt 125 Volt DC Buses 11,21,12, and 22 loss of less of loss of lossof 11125 veh de Bus 21125 voh de Bus 12125 voh de Bus 22125 veh de Bus ChannelZD ESFAS and Charmel ZE ESFAS and AFAS Channel ZF ESFAS and AFAS Channel ZO ESFAS and AFAS AFAS Sensor Cabmets de- Sensor Cabinets d> energized Sensor Cabinets de energized Sensor Cabinets de-energized energized CNTMT Area Ratt Monitor CNTMT Area Rad Monitor out ,

CNTMT Area Rad Manitor out CNTMT Area Rad Monitor out out ofservice ofserHce ofservice ofservice Channel A RPS Cabinet de- Channel B RPS Cabinet de- Channel C RPS Cabeet de. Channel D RPS Cabinet de-energized energized energized enersped loss of 2A EDO field flash loss of 2B EDO field flash and loss of1B EDO field flash and and control power,the start control power, the start solenoids control power,the start solenoids solenoids fail shut (Unit 2 fait shut (Unit 2 only) fail shut (Unit 1 only) only) loss of breaker position loss of breaker position bdication: indication:

Normalpower supply to the Normal power supply to the 11 A/21 A and 12Ar22A 11B11B and 12BG2B RCPs RCPs 13/23 and 14/24 4 KV buses

+11/21,12/22,15/25, and 13 A/23 A,131V23B,14 A/24A, 16/26 4 KV buses and 14B24B 480 Volt Buses II A/21 A,11E21B, 12A/22A, and 12H 22B 480 Volt Buses 11 and 1213 KV buses (Unit I only)

Loss ofUnit 2 Annunciation All Unit 1 Annurwiatorlights de-energized (Status Panels remain energized)

CC CNTMT SUPPLY fails CC CNTMT RETURN fails shut shut 12 SO AFW STM SUPP & II SO AFW STM SUPP &

BYPASS valves fail shut BYPASS valves fait shut less of SRW to the Torbine loss of SRW to the Turbine Building Building IA and PA may be lost due 1A and PA may be lost due to loss to loss of SRW to the of SRW to the Turbine Buildmg Turbine Building Channel A ESFAS and Channel B ESFAS and AFAS AFAS ActuationCabinets Actuation Cabinets de-erwrgized de energized 11/21 SRW,11/2i CC, and 12/22 SRW,12/22 CC, and 11/21 ECCS Pump Room 12/22 ECCS Pump Room HX HX SW outlet valves fail SW outlet valves fail open OPen 11/21 Main Steam Effluent 12/22 Main Steam Efiluent Rad Rad Monitor out ofservice Monitor out ofservice 11 and 12 SFP Heat i1 and 12 SFP Heat Exchangers Enhangers lose coolmg flow lose cooling flow due to SRW due to SRW outlet CVs outlet CVs failing shut (Unit I failing shut (Unit 1 only) only) 11/21 MSIVloses position 12/22 MSIV leses position indication, but can still be indication, but can still be closed closed from ICO3/2CO3 from 1C03/2003 CNTMT High Range CNThrf High Range Monitor MonitorChannel Aoutof Channel B out ofservice service Cahert Cliffs EAL Basis Document E:5 Rev.7 l

ELECTRICAL

(

l

(

)

Table E-1: Effects of Lost 125 Volt DC Buses 11,21,12, and 22 j (Continued) l Loss of loss of Loss of less of d 11125 volt de Bus 21125 veh de Bus 12125 voit de Dus 22125 volt de Bus less ofopen signal to the Turbine Bypass Valves and loss ofquick open signal to the ADVs (Unit I only)

Aux Spray Valve fails shut IA downstream of the I CNTMT 1A Control Valve l is isolated ("CNTMT 1A l ISOLATED IA-2085-CV i

CIDSED* alarm does NOT l actuate)

CNTMT Gaseous Monitor out ofservice Gaseous and Liquid Waste release control valves fail shut (Unit I only) 1IB/21B and 12W22B RCPs are i untrippable frorn 1CO6/2CO6 Loss ofletdown due to 1/2-CVC-516-CV failing shut AFW Turbme Driven Train Flow Control Valves 11 SG and 12 SG fail open(Unit I only)

PORV-404 inoperable in MPT ENABLE (Unit I only)

TCBs I and 5 trip TCBs 2,6, and 9 trip TCBs 3 and 7 trip TCBs 4 and 8 trip less ofplant oscillograph (Unit I only)

Calvert Cliffs EAL Basis Document E:6 Rev.7

ELECTRICAL Eiwisecy C1===in e sion Level: ALERT ADDhcable Operational Modes 5,6 Calvert Cliffs Initiatinn Condition:

EAl Station Blackout While On Shutdown Cooling NUMARC Recoanition Catenorv: System Malfunction NUMARC Initiatian CansMeian-SAI Loss of All Off Site Power and Loss of All On-Site AC Power to Essential Busses During Cold Shutdown Or Refueling Mode Bamer Not Applicable NUMARC Generic Basis:

Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal, Spent Fuel Heat Removal and the Ultimate Heat Sink. When in cold shutdown, refueling, or defueled mode the event can be classified as an Alert because of the significantly reduced decay heat, lower temperature and pressure, increasing the time to restore one of the emergency busses, relative to that specified for the Site Emergency EAL, Escalating to Site <E>mergency, if appropriate, as by < Radioactivity Release or SEC> Judgement ICs. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Plant-Snecific Information:

AOP-3B is the procedure entered in modes 5 and 6 for a loss of shutdown cooling regardless of the initiating fault.

This procedure is implemented concurrent with problem recognition.Section IX of AOP-3B prosides the procedural steps for restoration of electrical power to the 4kV power supplies. These are the safety related buses that provide power to the pumps used for shutdown cooling. This EAL addresses Station Blackout conditions during cold shutdown or refueling. For Station Blackout while defueled, see Initiating Condition QA4, Station Blackout while defueled.

Thus, the EAL is written as:

/.OP-3B, Abnormal Shutdown Cooling, is implemented Due to Loss of 4kV Power Supplies For GREATER THAN 15 Minutes Source Dx"==m/Iteferences/C=Im1=*ione:

1. Abnormal Operating Procedures AOP-3B, Abnormal Shutdown Cooling Calvert Cliffs EAL Basis Document E:7 Rev.7  !

l ELECTRICAL Emeraency Cimincatian Level: ALERT Apolicable Operational Modes 1,2,3,4

' Calvert Cliffs initiatina Condition:

EA2 Only One AC Power Source Available to Supply 4 kV Emergency Busses

)

NUMARC Racaenitian Catenory: System Malfunction NUMARC Initiatina Condition:

SAS AC Power Capability to Essential Busses Reduced to a Single Power Source for Greater Than 15 Minutes Such That Any Additional Single Failure Would Result in Station Blackout Barrier: Not Applicable NUMARC Generic E;;;;.a ;v Action levels Example Eanergency Action levels:

1. The following conditions exist (a and b)

a. Loss of power to < site-specific > Transformers for Greater Than 15 Minutes.

AND

b. Onsite Power Capability has been Degraded to one (Train of) Emergency Bus (ses)

Powered Frora a Single Onsite Power Source due to the Loss of:

< site-specific list >

NUMARC Generic R=ia:

This IC and its associated < Generic > EAL are intended to provide an escalation from IC <EUI, Loss of Off-Site Power >. The condition indicated by this IC is the degradation of the off-site and on-site power systems such that any additional single failure would result in a station blackout. This condition could occur due to a loss of off-site power with a concurrent failure of one diesel generator to supply power to its emergency busses. Another related condition could be the loss of all off-site power and loss of on-site emergency diesels with only one train of emergency busses being backfed from the unit main generator, or the loss of on-site emergency diesels with only one train of emergency busses being backfed from off-site power. The subsequent loss of this single power source would escalate the event to a Site <E>mergency in accordance with IC <ES1, Station Blackout >.

< Generic > EAL lb should be expanded to identify the control room indications of the status of Site-specific power sources and distribution busses that, if unavailable, establish single failure vulnerability.

At multi-unit stations, the EALs should allow credit for operation ofinstalled design features, such as cross-ties or swing diesels, provided that abnormal or emergency operating procedures address their use. However, these stations must also consider the impact of this condition on other shared safety functions in developing the site specific EAL.

Calvert Cliffs EAL Basis Document E:8 Rev.'l

ELECTRICAL NUMARC Ouestions and Answers. June 30.1993 Nome l Plant Soecific Informn'ian:

- The EAL addresses conditions while operating in Modes 1, 2,3, or 4 under which only one method is available to

. supply the emergency buses and loss of that method will result in a Station Blackout. Acceptable back up power j soortes with respect to t'ais EAL include tbc non-safety related OC diesel generator and the 69kV/13kV

i. SMECO tic line. The 69kV/13kV SMECO tie line can back up both units. When one or maore of these sources are available to back up the Unit experiencing a loss of offsite power or loss of a safety related diesel generator the entry condition for the EAL is not being met and the EAL does not apply.

Is itsponse to the Generic EAL, Calvert Cliffs EAL is written: S. ::, $: EAL i: H"- =:

Only One Power Source (Off-site or Diesel) is Available to Supply Unit 1 (Unit 2) Safety Related 4 kV busses for GREATER THAN 15 Minutes AND the Unit is Not on Shutdown Cooling (this is a condition where any additional sinnie failure will result in Station Blackout).

Source Documents / References / Calculations:

1. Updated Final Safety Analysis Report

+

Section 8, Electric Power Systems

! 2. Emergency Operating Procedures

• EOP-2, Loss of Off-Site Power

3. Technical Specifications ITS 3.8.6, Battery Parameters

+

ITS 3.8.7, inverters - Operating ITS 3.8.9, Distribution Systems - Operating

+

ITS 3.8.10, Distribution Systems - Shutdown

4. Letter dated September 15,1994, T. E. Forgette to Site Emergency Coordinators, et al.

l l

t 1

Calvert Cliffs EAL Basis Document E:9 Fev. 7

ELECTRICAL Emergency Classification Level ALERT Apphcable Operational Modes 1,2 Calvert Cliffs f aiti=*ias Candi* ion:

EA3 Loss of 125 Volt DC Power AND Reactor Trip NUMARC Recognition Category. System Malfunction NUMARC Initiatina Condition:

SS3 Loss of All Vital DC Power Bamer. Not Applicable NUMARC Generic 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 < Site > Emergency would occur by <Radioactisity Release, Fission Pro.luct Barrier Degradation, Equipment Failure, or SEC Judgement ICs.> Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Multi-unit stations with shared safety functions should further consider how this IC may affect more than one unit and how this may be a factor in escalating the emergency class.

Plant onecificInformation:

The Vital (Class IE) 125 V DC power system is fully described under IC EU2, Loss of Vital 125 Volt DC Power for GREATER THAN 15 Minutes. Review of the information in Table E-1 shows that if either DC bus 11 or 21 were lost with at least one unit in operation the resulting plant response meets the threshold for an Alert at Calvert Cliffs. The EAL is written to be consistent with procedures applying to plant operation while the reactor is critical.

Thus, the EAL is written as:

l EOP-8. Functional Recovery Procedure. is Implemented on Loss of 125 Volt DC Bus l Source De-atc/ References /C#da'ioac:

1. Abnormal Operating Procedures

+ AOP-7J, Loss of 120 Volt Vital AC or 125 Volt Vital DC Power

2. Emergency Operating Procedures EOP-8, Functional Recovery Procedure

3. Updated Final Safety Analysis Report

4. BG&E Drawing 61030-E, Single Line Diagram, Vital 120V AC & 125V DC - Emergency 250V DC

5. BGAE Drawing 61-057-E, Block Diagram - Auxiliary System Load Groups - Units 1 & 2 Calvert Cliffs EAL Basis Document E:10 Rev.7

ELECTRICAL Eiisaua Classification Level: SITE EMERGENCY Anoticable Operational M~t~: 1, 2, 3, 4 Calvert Cliffs Initiatina Condition:

ESI Station Blackout NUMARC Recoenit6n Catenory: System Malfunction NUMARC Initiatine Candition:

SSI Loss of All Offsite Power and Loss of All Onsite AC Power to Essential Busses Barner: Not Applicable NUMARC Generic 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 to a General Emergency. The (Site-specific) time duration should be selected to exclude transient or momentary power losses, but should not exceed 15 minutes.

Escalation to General Emergency is via Fission Product Barrier Degradation or IC <EG1, Prolonged Station Blackout >.

Multi-unit stations with shared safety functions should further consider how this IC may affect more than one unit and how this may be a factor in escalating the emergency class.

Plant-Snecific Information:

The Calvert Cliffs EAL is based on NUMARC. Entry into EOP-7 corresponds to the NUMARC-specified conditions. Power restoration to at least one Safety Related 4 kV Bus within 15 minutes addresses the transient or momentary power loss exclusion prosision.

Thus. EAL 1 is written as:

EOP-7, Station Blackout, is implemented AND power is not restored to at least one Safety Related 4 kV Bus per Unit within 15 minutes.

Station Blackout could also be recognized while in EOP-8, Functional Recovery Procedure. I Thus EAL 2 is written:

EOP-8, Functional Recovery Procedure is implemented AND Station Blackout is indicated by ANY of the following AND power is not restored to at least one Safety Related 4 kV Bus per Unit within 15 minutes:

e' less of Control Room normal lighting on both Units e 500 kV Red Bus and Black Bus power available lights de-energized e Diesel Generators NOTloaded.

. All 4 kV Unit bus power available lights de-energized Source Documents / References / Calculations

1. Technical Specifications ITS 3.8.1, A.C. Sources - Operating; 3.8.2, A. C. Sources - Shutdown

2. Emergency Operating Procedures

- EOP-7, Station Blackout

3. Updated Final Safety Analysis Report Section 8, Electric Power Systems

4. Imer dated September 15,1994, T. E. Forgette to Site Emergency Coordinator's et al.

l Calvert Cliffs EAL Basis Document E:11 Rev.7

ELECTRICAL Eira.a Classification Level: SITE EMERGENCY i i

ApohcableOncrationalModes All l

Calvert Cliffs Initiatinn Condition ES2 Loss of All 125 Volt DC Buses NUMARC Recognition Cateaory: System Malfunction NUMARC lai'ia'ia ConditiQD:

SS3 Loss of All Vital DC Power SS6 Inability to Monitor a Significant Transient in Progress Bamer. Not Applicable l NUMARC Generic Basis:

[SS3]

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 < Radioactivity Release, Fission Product Barrier Degradation, or SEC) Judgement ICs. FiAcen minutes was selected as a threshold to exclude transient or momentary power losses.

Multi-unit stations with shared safety functions should further consider how this IC may affect more than one unit l and how this may be a factor in escalating the emergency class.

[SS6]

This IC and its associated < Generic > EAL are intended to recognize the inability of the control room staff to monitor the plant response to a transient. A Site <E>mergency is considered to exist if the control room staff cannot monitor safety functions needed for the protection of the public.

(Site-specific) annunciators for this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., rad monistors, etc.).

Compensatory non-alarming indications in this context include computer based information such as SPDS. This 4

. should include all computer systems available for this use depending on specific plant design and subsequent retrofits.

Signifcant transient includes response to automatic or manually initiated functions such as scrams, runbacks involving greater than 25% thermal power change, ECCS injections, or thermal power oscillations of 10% or l

greater.

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

i Planned actions are excluded from this EAL since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

l Calvert Cliffs EAL Basis Document E:12 Rev.7

ELECTRICAL Plant-Soccific Information:

Because of the 125 Volt DC and Annunciato4 design at Calvert Cliffs, NUMARC ICs SS3 and SS6 have been combined into one IC for Calvert Cliffs. The Vital (Class IE) 125 V DC power system is fully described under IC EU2, Loss of Vital 125 Volt DC Power for GREATER THAN 15 Minutes. Review of the information in Table E-1 j shows that if all 125 Volt DC buses were lost, the resulting plant response meets the thr:shold for a Si.e Emergency. l Thus, the EAL is written as:

~

l Loss of123 Volt DC Buses 11,12,21 And 22 l

Source Dwuiiv.iits/Refere wvC=!cd=*iam:

I

1. Abnormal Operating Procedures AOP-7J, Loss of 120 Volt Vital AC or 125 Volt Vital DC Power

2. Emergency Operating Procedures EOP-0, Post-Tripimmediate Actions

3. Updated Final Safety Analysis Report Section 8, Electric Power Systems I

1 Calvert Cliffs EAL Basis Docutaent E:13 Rev.7

ELECTRICAL Eww..cv Classification Level: GENERAL EMERGENCY Anchcable Occrational Modes 1,2,3,4 Calvert Cliffs faitiatina Condition:

EGI Prolonged Station Blackout

! NUMARC Recoenition r=. ary: System Malfunction NUMARC laiti=rian Condition:

SGI Prolonged less of All Off-Site Power and Prolonged IAss of All Onsite AC Power Bamer Not Applicable l

NUMARC Generic Basis: l l

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 lead to loss of fuel clad, RCS, and containment. The (Site-specific) hours to restore AC power can be based on a site blackout coping analysis performed in conformance with 10 CFR 50.63 and Regulatory Guide 1.155, Station Blackout, as available, with appropriate allowance for offsite emergency response. Although this IC may be siewed as redundant to the Fission Product Barrier Degradation IC, its inclusion is necessary to better assure timely recognition and emergency response.

This IC is specified to assure that in the unlikely event of a prolongei station blackout, timely recognition of the j aeriousness of the event occurs and that declaration of a General Emergency occurs as early as is appropriate, based ,

on a reasonable assessment of the event trajectory. l

\

<The likelihood of restoring at least one emergency bus should be based on a realistic appraisal of the situation '

since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions)

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 <SEC> a reasonable idea of how quickly (s)he may need to declare a General Emergency based on two major considerations:

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 IAa(INEXI7 < Refer to Fission Product Barrier Degradation EAL Table for more information>.

l

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

Thus, in lication of continu'.ag core cooling degrada* ion must be based on Fission Product Barrier monitoring with particular emphasis on <SEC> judgement as it relates to IAS#NENTless or Potential Loss of fission product barriers and degraded ability to monitor fission product barriers.

Multi-unit stations with shared safety functions should further consider how this IC may affect more than one unit and how this may be a factor in escalating the emergency class.

Calvert Cliffs EAL Basis Document E:14 Rev.7

ELECTRICAL Pjant-Snecific Information:

Under conditions where a dieselgenerator is supplying power to one Unit, it should not be considered available as apower supplyfor the other Unit.

The Erst part of this EAL corresponds to the threshold conditions for IC ES1, Station Blackout for GREATER THAN 15 Minutes. The second part of the EAL addresses the conditions that will escalate the SBO to General l Emergency. Occurrence of any one of these conditions following SBO is sufficient for escalation to General Emergency. These conditions are: (1) SBO coping capability, or (2) indications of inadegaate core cooling. Each j of these conditions is discussed below:  !

I

1. SBO Cocing Canability Calvert Cliffs falls within the four hour SBO coping category. The ability of each unit to cope j with a four hour SBO duration was based on an assessment of condensate inventory required for '

decay heat removal, Class IE battery capacity, compressed air availability or manual operation of l certaia valves, effens ofloss of ventilation, containment isolation valve operability, and reactor I coolant inventory loss. A plant-specific analysis indicates that the expected rates of reactor coolant inventory loss under SBO conditions do not result in core uncovery in a SBO of four I hours. Thereforr., makeup systems in addition to those currently available under SBO conditions  !

are not required to maintain core cooling under natural circulation (including reflux boiling).  ;

Thus, conditicns in which restoration ofACpower within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is NOT likely are included in l the &lL. l

2. Indications ofland~w* Core Coolinn Calvert Cliffs does not use Critical Safety Function Status Trees. Calvert Cliffs uses Safety Function Status Checks developed by the Combustion Engmeering Owners' Group (C-E OG) which are based on logic similar to that used for CSFSTs developed for Westinghouse PWRs.

{

The applicable acceptance criteria for Core and RCS Heat Removal are shown on the Safety '

Function Status Checks. They are:

i Steam Generators Available for RCS Heat Removal I

1. Adequate secondary side liquid inventory in at least one steam generator as indicated by level  !

between -170 and +30 inches, and l

2. Adequate source of feedwater available to assure continued liquid inventory available as indicated by Condensau Storage Tank level greater than 5 feet, and

3. Steam Generators acting as effective heat sink as indicated by Cold Leg Temperatures (TCOLD) constant or lowering.

Primary Side Conditions for Core and RCS Heat Removal

1. Adequate core heat removal as indicatw by Core Exit Thermocouple readings less than superheated, and

2. Either of the following:

Natural circulation established as indicated by the temperature difference between Hot Leg Temperature (THOT)and TCOLD of between 10 *F and 50 *F, or i Forced circulation effective as indicated by THOT-TCOLD ess l than 10 *F.

Calvert Cliffs EAL Basis Document E:15 Rev.7

ELECTRICAL Per CEN-152, superheated conditions indicate core uncovery and inadequate core cooling.

Thus, the EAL is written as:

EOP-7, Station Blackout,is Implemented AND ANY of the FoCowing:

e Restoration of Power to ANY Vital 4kV Bus Is NOT Likely Within 4 Hours e Valid CET Readings Indicate Superheat Temperatures e Core and RCS Heat Removal Using Steam Generators Can NOT Meet Awaam Criteria Valid means that the indication is from instrumentation determined to be operable in accordance with the Technical Specifications or has been verified by other indications displayed on the control panels.

Can NOT is used because the ability to meet the final Waam criteria is the appropriate concern, not whether intermediate Waa~ criteria are not being achieved at any given moment.

Source Dc-:+a-# References /Calculadene:

1. Emergency Operating Procedures

. EOP 7, Station Blackout EOP-8, Functional Recovery Procedure

2. CEN-152, Emergency Procedure Guidelines

3. Letter, Daniel G. MacDonald (US Nuclear Regulatory Conunission) to G.C. Creel (BG&E), Response to Station Blackout Rule - Calvert Cliffs Nuclear Power Plant, Units 1 and 2, TAC Numbers 68525 (Unit 1) and 68256 (Unit 2), October 10,1990 Calvert Cliffs EAL Basis Document E:16 Rev.7

I l

i SECURITY l l

1 l

1 Calvert Cliffs EAL Basis Document Rev.7

~

SECURITY Emeraency Classification Level: UNUSUAL EVENT Anolicable Onerational Madac: ALL Calvert Cliffs Initiatino Condifian:

TU1 Confirmed Security Event With Potential Degradation in the Level of Safety of the Plant NUMARC Recognition Catenorv: Hazards and Other Conditions Affecting Plant Safety NUMARC Initiatino Canditian:

HU4 Confirmed Security Event Which Indicate: a Foiential Degradation in the Level of Safety of the Plant Barrier: Not Applicable NUMARC Generic Emermency Actiou Levels Example Emergency Action levels: (1 or 2)

1. Bomb device discovered withis plant Protected Area and outside the plaat Vital Area.

2. Other security events as defensised fmm (site-specific) Safeguards Contingency Plan.

NUMARC Generic Basis:

This EAL is based on (Site-specific) Site Security Plan. Security events which do not represent at least a potential degradation in the level of safety of the plant are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72. The plant Protected Area Boundary is typically that part within the security isolation zone and is dermed in the (Site-specific) security plan. Bomb devices discovered within the plant Vital Area would result in <> escalation

<to a higher emergency classification level via other Security Event Ics>.

NUMARC Ouestions and Answers. June 30.1993 (Hazards and Other CrrfP'::: Aff&tian Plant Safety) 9.

HU4/EAL 1 refers to a bomb device discovered within the Pmtected Area and outside the Vital Area. No EAL or IC specifically addresses a bomb discovend within the Vital Area.

A cessmwA es; plosive device within a Vital Ares is a direct threat to vital equipment designed to protect the public. The event therefore exceeds HSi, " Security Event in a Plant Vital Area." A Site Area Emergency is therefore uwerented. The basis ofHU4 does state that bomb devicesfoundin the Mtal Area wouldresult in EAL escalation.

Plant-Snecific Infor==tian:

The Calvert Cliffs EALs " .__ d:;:-i - ; C ~- ; --f include the ISFSI. A_empted intrusion means that intruders are not successful in getting past the innermost fence of the double fence that surrounds the plant Pyrotected Aarea. Sabotage within the ISFSI includes discovery of a bomb device. Intruders are armed or unarmed personnel that are attempting to or have gained unauthorized access in-e 9": r.= . Nuclear Security will determine whether or act latrusion or sabotage exists la accordance with the Safeguards Contingency Plan.

Calvert Cliffs EAL Basis Docurnent T:1 Rev.7 l

SECURITY Sabotage (including discovery of a bomb device)inside the Plant Protected Area warrants escalation to an Alert level emergency. A Site Emergency is warranted if sabotage occurs in an Aarea of Ceoncern for Ssafe Sshutdown for of either Unit remeter Calvert Cliffs Safeguards Contingency Plan defines all security events including discovery of a bomb device.

For Calvert Cliffs, Generic EAL 1 is included in the guidance of Generic EAL 2. Hence one site specific EAL addresses both of the Generic EALs.

In response to Generic EAL 1 and 2. Calvert Cliffs EAL 1 is wdtten: E=. E.^.L ! i: :"r:: =:

l " Security Emergency" or " Security Alert" Declared for attempted intrusion into the Plant Protected Area l To address the ISFSI, Calvert Cliffs EAL 2 is written: E.^.L 2 i: ;" :: =:

" Security Event" Declared for:

. Sabotage Within or to ISFSI Protected Area e Intrusion Into ISFSI Protected Area Source Documents / References / Calculations:

None i

l l

Calvert Cliffs EAL Basis Document T:2 Rev.7 i

SECURITY '

Emeraency Cla h'ian Lael: ALERT Anoticable Operational Modes: ALL Calvert Cliffs !aitia'ia= Condition:

TAI Security Event in the Plant Protected Area NUMARC Recoanition Catenorv: Hazards and Other Conditions Affecting Plant Safety NUMARC Initiatia= Cnadisian:

HA4 Security Event in a Plant Protected Area Barrier: Not Applicable NUMARC Generic Emeroency Action Levels Example Emergency Action levels: (1 or 2)

1. Istasion into plant Pmtected Area by a hostile forte.

2. Other security events as detennised fmm (site-specific) Safeguards Contingency Plan.

NUMARC Generic Basis:

This class of security events represents an escalated threat to plant safety above that contained in the Unusual Event. For the purposes of this IC, 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

< Emergency >.

Multi-unit stations with shared safety functions should further consider how this IC may affect more than one unh and how this may be a factor la escalating the emergency class.

NUMARC Ouestions and Answers. June 30.1993 Glazards and Other Cee9tions Affectina Plant Safety)

None Plant SoecificInformation:

3: C:!=r. C"" E?.L: '"u $: ;--i a c' ::-- -- Sabotage includes discovery of a bomb device.

Intruders are armed or unarmed personnel that have gained unauthorized access in : ':Mk --- a Nuclear Security will determine whether or not lastrusion or sabotage exists la accordance with the Safeguards Contingency Plan.

j In msponse to Generic EAL 1 and 2 Calvert Cliffs EAL is written: S r,E?.L1b: t = =:

" Security Emergency" or " Security Alert" Declared For: I e Intrusion into the Plant Protected Area e Sabotage inside the Plant Protected Area l

Source D==*ata/ References / Cal & a'ione:

None Calvert Cliffs EAL Basis Document T:3 Rev.7  !

l i

l

SECURITY l Emergency Classification Level: SITE EMERGENCY Acolicable Operational Modes: ALL Calvert Cliffs Initiatina Condition:

TS1 Security Event in a Plant Vital Area NUMARC Recognition Category: Hazards and Other Conditions Affecting Plant Safety NUMARC Initiating Condition:

HS1 Security Event in Plant Vital Area i

Barner Not Applicable I NUMARC Generic Emereency Action Ixvels Example Emergency Action I4vels: (1 or 2)

1. Intrusion into plant Vital Area by a hostile force.

2. Other security events as determined from (site-specific) Safeguards Contingency Plan.

NUMARC Generic 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.

Multi-unit stations with shared safety functions should further consider how this IC may affect more than one unit and how this may be a factor in escalating the emergency class.

NUMARC Ouestions and Answers. June 30.1993 (Hazards and Other C::'Maas Affectine Plant Safetv)

9. HU4/EAL 1 refers to a bomb device discovered within the Protected Area and outride the Vital Area. No EAL or IC specifically addresses a bomb discovestd within the Vital Area.

A confirmed explosive device uuhin a Vital Area is a dired threat to vital equipment designed to protect the public. The event therefore exceeds HSI, " Security Event in a Plant Ystal Area." A Site Area Emergency is therefore warranted. The basis ofHU4 does state that bomb devicesfoundin the Vital Area uvuld result in EAL escalation.

Plant-Soccific Information:

":: T;;n C'i": E?.L: " 5 ;----!: n of =:= Sabotage includes discovery of a bomb device.

Intruders are armed or unarmed personnel that have gained unauthorized access in : '-M': ----- Nuclear Security will determine whether or not intrusion or sabotage exists in accordance with the Safeguards Contingency Plan.

Calvert Cliffs EAL Basis Document T:4 Rev.7

SECURITY In response to Generic EAL 1 and 2 Calvert Cliffs EAL is written: S. :. EAL ! !: v"t= =:

" Security Emergency" or " Security Alert" Declared for:

• Intrusion into a Vital Area or an Aarea of $ ;!=: in i: : == ::: for =S d d: m Of enher4 easter-Concern for Safe Shutdown.

• Sabotage within a Vital Area or an Aarea of $ ;'r: in: i: : r --- fe: ='; d: f::: Of edher4 easter-Concers for Safe Shutdown The list of Aareas of Ceoncern for Safe Shutdown are shown below .d  : p::rl =:!y f ;':y:d := i: EAL Table.

Areas of Concern for Safe Shutdown

• Control Room Electrical Penetration Rooms

• Control Room HVAC Room + Auxiliary Feedwater Pump Room

• Cable Spreading Room + Charging Pump Rooms

• Cable Chases

• Diesel Generator Rooms

• Switchgear Room + Diesel Generator Building (OC/l A)

• ECCS Pump Room Refueling Water Tank (RWT) 11(21)

• Service Water Pump Room Condensate Storage Tank (CST) 12

+ Component Cooling Pump Room Pretreated Water Storage Tank (PWST) 11(12)(21)

+ Main Steam Penetration Room + Fuel Oil Storage Tank (FOST) 21 +2

+ Intake Structure This list of Safe Shutdown areas is displayed on the EAL Tables to assure that all areas related to Safe Shutdown are considered by the SEC.

EAL 2 i::"t= =:

l c k::;;;;"th : c:: Of :::: f::":k Ebid: -

l Source Documents / References / Calculations:

1. NRC Information Notice No. 96-71: Licensee Response to Indications of Tampering, Vandalism, or Malicious Mischief.

Calvert Cliffs EAL Basis Document T:5 Rev.7

1 SECURITY

)

Emergency Cl=***ation Level: GENERAL EMERGENCY Anolicable Onerational Modes: ALL Calvert Cliffs initiatinn Condition:

TG1 Security Event Resulting in Loss of Ability to Reach AND Maintain Cold Shutdown NUMARC Recognition Catsggry: Hazards and Other Conditions Affecting Plant Safety NUMARC Initiatina Condition:

HG1 Security Event Resulting in Loss of Ability to Reach and Maintain Cold Shutdown Bam_gt: Not Applicable NUMARC Generic Basis:

This IC encompasses conditions under which a hostile force has taken physical control of sital area required to reach and maintain safe shutdown. < >

Plant-Soccific Information:

l The Calvert Cliffs EALs address the generic areas of concern. Thus, the EAL is written as:

{

l Security Threat Resulting in Loss of Ability to Achieve and Maintain Safe Shutdown of Either Reactor l l This would include areas where any switches that transfer control of safe shutdown equipment to outside the control room are located.

The list of areas of concern for Safe Shutdown are shown below and are prominently displayed on the EAL Table. J Areas of Concern for Safe Shutdown

• Control Room + Electrical Penetration Rooms

• Control Room HVAC Room a Auxiliary Feedwater Pump Room

+ Cable Spreading Room

• Charging Pump Rooms a Cable Chases

• Diesel Generator Rooms

• Switchgear Room . Diesel Generator Building (OC/l A)

• ECCS Pump Room a Refueling Water Tank (RWT) 11(21)

+ Senice Water Pump Room . Condensate Storage Tank (CST) 12

• Component Cooling Pum, Room + Pretreated Water Storage Tank (PWST) 11(12)(M)

• Main Steam Penetration Room + Fuel Oil Storage Tank (FOST) 21 M

+ Istake Structure This list of Safe Shutdown areas is displayed on the EAL Tables to assure that all areas related to Safe Shutdown are considered by the SEC.

Source De-atMiences/Calml=' ions:

1. BG&E Internal Memorandum, Tom Forgette (Enuergency Planning Unit) to POSRC, July 29,1986 Calvert Cliffs EAL Basis Document T:6 Rev.7

FIRE l

i I

l FIRE Calvert Cliffs EAL Basis Document Rev.7

FIRE Emergency Classification Level: UNUSUAL EVENT Apolicable Operational Modes: ALL Calvert Cliffs Initiating Condition:

IUl Fire Within Protected Area Boundary Not Extinguished Within 15 Minutes of Detection NUMARC Recognition Category: Hazards and Other Conditions Affecting Plant Safety NUMARC Initiating Condition:

HU2 Fire Within Protected Area Boundary Not Extinguished Within 15 Minutes of Detection Barrier: Not Applicable NUMARC Generic Emergency Action 1.4vels Example Emergency Action I.4 vel:

1. Fire in buildings or areas contiguous to any of the following (site-specific) areas not extinguished within 15 minutes of control room notification or verification of a control room alarm:

e (Site-Specific) list l

NUMARC Generic Basis: 1 The purpose of this IC is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. This excludes such ite.ms as fires within administration buildings, waste-basket fires, and other small fires of no safety consequence. This IC applies to buildings and areas contiguous to plant sital l areas or other significant buildings or areas. The intent of this IC is not to include buildings (l.c., warehouses) or areas that are not contiguous or immediately adjacent to plant vital areas. Verification of the alarm in this context means those actions taken in the control room to determine that the control room alarm is not spurious.

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

l Multi-unit stations with shared safety functions should further consider how this IC may affect more than one unit and how this may be a factor in escalating the emergency class.

NUMARC Ouestions and Answers. June 10.1993 (Hazards and Other Conditions Affection Plant Safety)

7. When does the 15 minute time period of HU2 begin with regard to a fire within the protected area? Receipt of a fire alarm, reports from the scene, or arrival of the fire brigade are possible initiators of the 15 minute clock.

The 15 minute time period of HU2 begins with a credible notifscation that afire is occurring, or versfication of afire detection system alarm. Versfication of afire detection system alarm includes any actions that can be taken within the controlroom or other plant-specsjic location to ensure that the alarm is not spurious but does not include dsspatch ofpersonnel to the scene to confirm that afire exists.

I l

I Calvert Cliffs EAL Basis Document I:1 Rev.7

FIRE Plant-Snecific Information:

Cd= C'i": E^.L i:' " '.i.rJy =MA4ARG-Visible smoke is sufficient to conclude that a fire exists. Flames do not have to exist. Odor by itself does not constitute a fire.

A fire is extinguished when the Fire Brigade Leader determines that active combustion has ceased and there is no immediate danger of the fire spreading.

In response to the Generie EAL, Calvert Cliffs EAL is written: "= $: EAL i: dx .::

Fire in/ involving any of the below listed areas, that is not extinguished within 15 minutes of Control Room notification or receipt of a IC24B, Fire System Control Panel, alarm for fire detection and fire suppression system actuation.

• Auxiliary Building e Hydrogen Storage Tanks e Containment e Intake Structure e Containment Butler Building

• ISFSI Protected Area e Containment Emergency Air Lock e Main Station & Senice Station Vestibule Transformers e Diesel Generator Rooms e North Senice Bldg.12 Foot Elevation e Diesel Generator Buildings (OC/l A) e RWT Rooms

. . Fire Pump House e Turbine Building e Fuel Oil Storage Tanks e 13KV Switchgear Houses e 13KV Voltage Regulators CCNPP Ouestions and Answers fFire) e Aren't the areas listed above for this EAL (IU1) laeluded in the Areas of Concern for Safe Shutdown? If they are, what is the difference between this Unusual Event and Alert, IAl 1, and IAl-2?

Most of the areas listed in skis EAL (1U1) are included in the Areas of Concern for Safe Shutdoun. ' The diferences between Unusual Event,1U1 and Alert IA11 and IAl-2 are time and the application of an extinguishing agent. For example: afare in the Diesel Generator Room that is not extinguished within 15 minutes of Control Room notification is an Unusual Event. Thisfare willescalate to an Alert ifit either: a. is not extinguished within 30 minures of notification. or b. is not extinguished within 15 minutes of the first extinguishing asent beine ecolied

. The NUMARC answer to question number 7 does not appear to match uith Calvert CIWs dispatch ofa Fire and Safety Technician or Plant Operator to investigate the alarm.

Calvert Clifs has changed its policy to start the 15 minute time period when an alarm is received on 1C24B and does not wait untilpersonnel are despatched to confsrm that a fare suists,Just as described in the guidance.

Source Daen=nt</ References /Calcuhtianc:

1. Issue Report IRO-012603, Fire in Room 511...,10-23 92

2. April 28,1995 letter, T. E. Forgette to Emergency Planning Unit file 9.5, re: April 14,1995 fire in Unit 2 Auxiliary Building, five foot elevation, fan room.

3. Issue Report IR0-004-422 (AIT IR199502146), failure to declare Alert in exercise for fire / explosion.

4. EPU file 4.14, EALs; June 30,1993 letter: " Methodology for Development of Emergency Action Levels",

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

Calvert Cliffs EAL Basis Document 1:2 Rev.7

FIRE Emergency Classification Level: ALERT Acolicable Ooerational Modes: ALL Calvert Cliffs Initiating Condition:

IAI Fire or Explosion Affecting Safe Shutdown j

NUMARC Recoenition Category: Hazards and Other Conditions Affecting Plant Safety NUMARC (nitiating Condition:

HA2 Fire or Explosion Affecting the Operability of Plant Safety Systems Required to Establish or Maintain Safe Shutdown Barner Not Applicable l NUMARC Generic Emerrency Action levels Example Emergency Action level:

1. Tbc following conditions exist:

a. Fire or explosion in any of the following (site-specific) areas:

e (Site-Specific) list AND

b. Affected system parameter indications show degraded performance or plant personnel report visible damage to permanent stmetures or equipment within the specified area.

NUMARC Generic Basis:

(Site-specific) Areas containing functions and systems required for the safe shutdown of the plant should be specified. (Site-Specific) Safe Shutdown Analysis should be consulted for equipment and plant areas required for the applicable mode. This will make it easier to determine if the fire or explosion is potentially affecting one or more trains of safety systems. Escalation to a higher emergency class, if appropriate, will be based on < Equipment Failure, Electrical, Fission Product Barrier Degradation, Radioactivity Release, or SEC Judgement ICs>. <>

Multi-unit stations with slaared safety functions should further consider how this IC may affect more than one unit and how tble may be a factor la escalating the emergency class.

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 enerSy to near-by structures and materials. The inclusion of a " report of sisible damage" should not be interpreted as mandating a lengthy damage assessment before classification. No attempt is made in this < Generic >

EAL to assess the actual magnitude of the damage. The occurrence of the explosion with reports of evidence of damage (e.g., deformation, scorching) is sufficient for the declaration. The declaration of an Alert and the activation of the TSC will provide the <SEC) with the resources needed to perform these damage assessments. The

<SEC) also needs to consider any security aspects of the explosions, if applicable.

Calvert Cliffs EAL Basis Document I:3 Rev.7

FIRE NUMARC Ouestions and Answers. June 30.1993 (Hazards and Other Conditiae A#ectina Plant Safety)

None Plant SnecificInformeion:

liaoh Calvert CliNs unit uses the Abnormal Operating Procedures (AOP) 9A through 9S to address fires within the plant protected and vital areas that are of particular concern because they contain equipment required for safe shutdown. Implementation of any AOP-9 series procedure will satisfy this initiating condition.

In response to the Generic EAL, Calvert CliNs EAL 1 is written:

l AOP-9 series pmcedure Impleascated for fire. l For the purpose of EAL classification the eNect that a fire will have om equipment operability is determined only by the annoust of time that the fire exists.

There are two i='-71+nt clocks for determining the magnitude of a fire based on time. One clock starts when a fire is detected. For practical purposes a fire is detected when the report of the fire is received in the Control Room. Report of a fire may be by Control Room fire alarm or by voice message. A fire alarm refers to IC24B, Fire System Control Panel, for fire detection and fire suppression system actuation. Fire pump running and trouble alarms by themselves do not constitute a report of a fire. This clock includes: the time it takes to confirm or verify the fire report, plus the response team assembly time, plus the time it takes the responders to establish a fire fighting strategy, plus the time it takes to actually extinguish the fire.

la response to the Generic EAL, Calvert Cliffs EAL 2 is written: n= EAL ! h M=: =:

l Fire in an Area of Concern for Safe Shutdown that is not extinguished within 30 minutes ofits detection. l Visible smoke is sufficient to conclude that a fire exists. Flames do not have to exist. Odor by itself does not constitute a fire.

A fire is extinguished when the Fire Brigade Leader determines that active combustion has ceased and there is no immediate danger of the fire spreading.

The other clock for determining the magnitude of a fire is the time it takes to extinguish the fire. This clock begins when the first extinguishing agent is applied to the fire.

In response to the Generic EAL, Calvert Cliffs EAL 3 is written: E= EAL 2 b d:: =

Fire in an Area of Concern for Safe Shutdown that is not extinguished within 15 minutes of the first extmguishing agent being applied.

This EAL accounts for situations where the time to validate and respond to the fire is short.

CCNFP Ouestions and Answers (Fire) e Why is there a 15 minutes time allowance for fires in Areas of Concern for Safe Shutdown (EAL 3) but act for AOP-9 series implemented fires (EAL 1)?

For EAL 1, AOP-9 series, implementation is suficient to satisfy the NUMARC generic guidance (".. . , afecting the operability ofplant safety sydems"). For other than AOP-9 area jires, time ofburn is used to determine the efect that thejire will have on plant sydems.

Calvert Cliffs EAL Basis Document I:4 Rev.7 I

FIRE l

l In etsponse to the explosion portion of the Generic EAL, Calvert Cliffs EAL 4 is written: E.^.L ? i: 9:::: I

-av Explosion in any of the below listed areas:

e any area listed la AOP-9 series procedures e any an Area of Concern for Safe Shutdown.

An explosion is a rapid, violent, unconfined combustion, a catastrophic failure of pressurized equipment, or a l violent electric arc, of sufficient force to potentially damage ec sipment, structures or components.

Fire and/or explosion in the Control Room HVAC R;an may lead to evacuation of the Control Room and implementation of Altessate Shutdown P sceducts p c. M ;!:e 1: S tr-" " ^' 7 7 '- Thus, the -

Control Room HVAC Room (Room 512) has been added to the areas of concern for safe shutdown. The list of areas of concern for Safe Shutdown are shown below: - ' ::: p. _ '-- ^'y 't' yd := 6 E.^.L T ":

Areas of Concern for Safe Shutdown

• Control Room . Electrical Penetration Rooms e Control Room HVAC Room . Auxiliary Feedwater Pump Room

. Cable Spreading Room . Charging Pump Rooms e Cable Chases e Diesel Generator Rooms e Switchgear Room . Diesel Generator Buildings (OC/l A) e ECCS Pump Room e Refueling Water Tank (RWT) 11(21) e Service Water Pump Room o Condensate Storage Tank (CST) 12 e Component Cooling Pump Room . Pretreated Water Storage Tank (PWST) 11(12)6M) e Main Steam Penetration Room

• Fuel Oil Storage Tank (FOST) 12 M e Intake Structure This list of Safe Shutdown areas is displayed on the EAL Tables to assure that all areas related to Safe Shutdown are considered by the SEC.

The significance of these EALs is not that safety systems have been degraded What is significant is that a fire of ,

such magnitude that it can not be extinguished in the times specified exists in an area of concern for safe - l shutdown. Likewise, an explosion is significant because it occurred in an area of concern for safe shutdown, not because it degraded safety systems.

Source Documents / References /Calculatiom:

1. Abnormal Operating Procedures AOP-9A through 9S, Alternate Safe Shutdown / Control Room Evacuation procedure series

2. Issue Report IRO-012603, Fire in Room 512...,10-23 92

3. April 28,1995 letter, T. E. Forgette to Emergency Planning Unit file 9.5, re: April 14,1995 fire in Unit 2 Auxiliary Building, five foot elevation, fan room.

4. Issue Report IR0 004-422 (AIT IR199502146), failure to declare Alert in exercise for fire / explosion.

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

NUMARC/NESP 007, Revision 2, Questions and Answers, June 1993; Hazards and Other Conditions Affecting Plant Safety, question 13, page 24.

Calvert Cliffs EAL Basis Document I:5 Rev.7

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NATURAL PHENOMENA l

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Calvert Cliffs EAL Basis Document Rev.7

NATURAL HAEARDS PHENOMENA i Emeraency Classification 1xvel: UNUSUAL EVENT Anolicable Operational Modes: ALL Calvert Cliffs Initiating Condition:

NUI Natural Phenomena NUMARC Recognition Category Hazards and Other Conditions Affecting Plant Safety NUMARC Initiating Conditio11:

HUI Natural and "a utve Phenomena Affecting the Protected Area Barner Not App . "

NUMARC Generic Emernency Action Levels Example Emergency Action 14 vel (1 or 2 or 3 or 4 or 5 or 6 or 7):

1. (Site-Specific) method indicates felt canhquake.

2. Report by plant personnel of tornado striking within protected area boundary.

3. Assessment by the control room that an event has occurred.

4. Vehicle crash into plant structuns or systems within protected ama boundary.

5. Report by plant personnel of an unanticipated explosion within protected area boundary resulting in visible damage to permanent structure or equipment.

6. Repon of turbine failure resulting in casing penetration or damage to turbine or generator seals.

7.. (Site-Specific) Occurrences.

NUMARC Generic Basis:

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

< Generic > EAL 1 should be developed on Site-Specific basis. 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 vibratory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated. For most plants with seismic tnstrumentation, the seismic switches are set at an acceleration of about 0.0lg.

< Generic > EAL 2 is based on the assumption that a tornado striking (touching down) within the protected boundary may have potentially damaged plant structures containing functions or systems required for safe shutdown of the plant. If such damage is confirmed visually or by other in-plant indications, the event may be escalated to Alert.

f Calvert Cliffs EAL Basis Document N:1 Rev.7

NATUf AL HAZARDS PHENOMENA

< Generic > EAL 3 allows for the control room to determine that an event has occurred and take appropriate action based on personal assessment as opposed to verification (i.e., an earthquake is felt but does not register on any plant-specific instrumentation, etc.)

C:=:;-:: EW ', 3, =d S : : 7":=:2 =h:!C OU3, D=:=::w: ."h:==:=.

EAL 4 is intended to address such items as plane or helicopter crash, or on some sites, train crash, or barge crash that may potentially damage plant structures containing functions and systems required for safe shutdown of the plant. If the crash is confirmed to affect a plant vital area, the event may be escalated to Alert.

For IIAL 5 only those esg' sons of sufficient force to damage permanent 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 structures 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 distctor also needs to consider any security aspects of the explosion,if applicable.

EAL 6 is intended to address main turbine rotating component failurts of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Of najor concern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the pn :.; environs. Actual fires and flammable gas build up are appropriately classified via HU2 and HU3. 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 missiles generated by the failure or by the radiological releases for a BWR, or in conjunction with a steam generator tube rupture, for a PWR. These latter events would be classified by the radiological ICs or Fission Product Barrier ICs.

< Generic > EAL 7 covers other (Site-Specific) phenomena such as hurricane, flood, or seiche. These EALs can also be precursors of more serious events. In particular, sites subject to severe weather (as defined in NUMARC station blackout initiatives) should include an EAL based on activation of the severe weather mitigation procedures (e.g., precautionary shutdons, diesel testing. staff call-outs, etc.) < >

Multi-unit stations with shared safety functions should further consider how this IC may affect more than one unit and how this may be a factor in escalating the emergency class.

NUMARC Ouestions and Answers. June 30.1993 (Hazards & Other Conditions Affectine Plant Safety)

1. If generator seal damage is observed after the generator has been purged for disassembly, should an Unusual Event be declared?

For the exanple given, an Unusual Event should not be declared. The generator seal damage is prima facie evidence that hydrogen gas escapedinto the turbine area. In this example, however, there us no report of a leak, no detection of the hydrogen, and no explosion orfire in efed, the amount ofgas that leaked did not afect normal operation of theplant.

4. Does HU1/EAL3 - control room assessment of an event - apply only to EALs 1 and 2 or to all of the EALs.

EAL 3 ofHU1 pplies A to all example EAls ofHU1.

Calvert Cliffs EAL Easis Document N:2 Rev.7

NATURAL HAZARDS PHENOMENA

5. What is the latent of HU1/EAL 37 This EAL appears to be covered by HUS.

As stated in the basis, EAL 3 of HU1 allows control room personnel to make the determination (nithout waitingfor verification) that a natural or destructive phenomenon has occurred that untrants the declaration of an Unusual Event. HUS applies to any situation not ewlicitiv addressed in the l EALs that, in theJukment ofthe Emergency Director, merits an emergency declaration.

6. Can a " vehicle crash" as used in HU1/EAL 4 be caused by an automobile, truck, or forklift? The basis seems to limit such crashes to alstraft, trains, or barges.

The scope ofthe term " vehicle"should not be limited to aircrap, trains, or barges. Automctiles, tucks, andfork!sps are also vehicles nithin the context ofthis EAL. The key is whether or not the vehicle can potentially cause significant damage to plant structures.

Plant-Soccific Information:

Calvert Cliffs EALs r: 5 r-i f ::dy := "U" ^"C rd include the Independent Spent Fuel Storage Installation (ISFSI). l EAL 1 addresses seismic activity. This EAL is based on the acceleration level which causes actuation of the seismic monitor and is verified to be the result of an carthquake, or tbc presence of a " felt carthquake" as described in the NUMARC generic basis above. On 1: Erb ef pp!k:bk ;!=: p rdre, E.^.L ! k =":= =>

In response to Generic EAL 1 and 3, Calvert Cliffs EAL 1 is written:

l Earthquake Detected By Seismic Instrumentation per 01-46 Or Based on Shift Supenisor Judgement l l

In responw to Generic EAL 2. Calvert Cliffs EAL 2 is written as:

Nr!:r S::ndy R:pe.1 ef a Tornado Striking Switchyard, Plant Protected Area Or Within the ISFSI l Protected Area l

EALs responsive to Generic EAL 4,5 and 6 are addressed is IC OU3, Destivctive Phenonema.

In response to Generic EAL 7, Calvert Cliffs EALs 3,4, and S are: 9 Per UFSAR Section 2.8.3.4, the design basis hurricane (used for tidal surge estimates) has a maximum wind speed of 124.7 MPH and a forward speed of 23 MPH. EAL 3 uses 75 MPH to be anticipatory of the design basis wind speed.

Bus: EAL 3 is written as:

l l Sustained Wind Speed GREATER THAN 75 MPH (34 meters /second) for AT LEAST 15 Minutes l The duration of 15 minutes is selected to indicate sustained winds and to preclude wind gusts. An increase in sustained speed aoove 90 mph (40 meters /second) is cause for escalation to an Alert. Wind speeds are also prosided here in meters /second for dose assessment input. The conversion equation is as follows:

l 75 miles / hour x 5280 feet / mile x (I hour /3600 seconds) x 1 meter /3.2808 feet) = 34 meters /second l Per UFSAR Section 2.8.3.6, the still water level used for Intake Stmeture analysis is 17.6 feet MSL. The top of the Traveling Screen cover housing is about 18 feet MSL. EAL 4 is anticipatory of the design water level.

Rus: EAL 4 is written as:

l Bay Water Level at or above bottom of traveling screen cover housing.

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Calvert Cliffs EAL Basis Document N:3 Rev.7

NATURAL HAEARDS PHENOMENA i l

Per UFSAR Section 2.8.3.7, the predicted extreme low tide is -3.6 feet MSL and normal operation can continue with the bay l level as low as -4.0 feet MSL.

h EAL 5 is written w l Bay Water Level is AT lEAST 3.6 Feet Below Mean Sea Level l Surveillance Test Procedures provide a way to determine Bay level.

Source Dacuman'</Referaar**>C2Ic'ila'ianc:

1. Updated Final Safety Analysis Report

2. Operating Instruction (OI) 46, Seismic Measurement Equipment

3. BGAE Drawing 60-220-E (M-31), Equipment Location Senice Building, Water Treatment Area & Intake Structure Section "] J"

4. BG&E Drawing 83 278-E, Plan Auxiliary Building Restricted Access Area El. (-)8'-0", (-)l0'-0" And (-)l5'-0"

5. BG&E Internal Memorandum, J.E. Thorp to R.E. Denton, Emergency Action Level Review Criteria, June 1,1990

6. Letter, G.C. Creel (BGAE) to U.S. Nuclear Regulatory Commission Document Control Desk, Emergency Action Level Revision, September 24,1992

7. ERPIP 3.0, Rev.17, revised bay water level reference points to reflect plant construction changes.

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Calvert Cliffs EAL Basis Document N;4 Rev.7

NATURAL HAZARDS PHENOMENA FJneraency Classification Level: ALERT l

l Anolicable Operational Modes: ALL Calvert Cliffs Initiating Condition:

NAl Natural Phenomena Affecting Safe Shutdown l

NUMARC Recognition Category: Hazards and Other Conditions Affecting Plant Safety NUMARC Initiating Condition:

HAl Natural and Destructive Phenomena Affecting the Plant Vital Area Bamer: Not Applicable NUMARC Generic Emereency Action Levels Example Emergency Action Levels: (1 or 2 or 3 or 4 or 5 or 6 or 7)

1. (Site-Specific) method indicates Seismic Event greater than Operating Basis Earthquake (OBE).

2. Tornado or high winds stri!'ing plant vital areas: Tornado or high winds greater than (site-specific) mph strike within protected area boundary.

3. Report of any visible stewetural damage on any of the following plant structures:

. Reactor Building

• Intake Building e Ultimate Heat Sink e Refueling Water Storage Tank e Diesci Generator Building

• Turbine Building

• Condensate Storage Tank e Control Room

. Other (Site-Specific) Structures

4. (Site-Specific) indications in the control room.

5. Vehicle crash affecting plant sital areas.

6. Turbine failure generated taissiles result in any visible structural damage to or penetration of any of the following plant areas (site-specific) list.

7. (Site-Specific) occurrences.

NUMARC Generic Basis:

< Generic > EAL 1 should be based m (site-specific) FSAR design basis. Seismic events of this magnitude can cause damage to safety functions.

< Generic EAL 2 & should be based on (site-specific) FSAR design basis. Wind loads of this magnitude can cause damage to safety functions.

Calvert Cliffs EAL Basis Document N:5 Rev.7

NATURAL HAEARDS PHENOMENA

< Generic EAL 3 3> should spectfy (site-specific) structures containing systems and functions required for safe shutdown of the plant.

< Generic > EAL 4 should specify the types of instimmentation or indications including judgment which are to be used to assess occurrence.

< Generic > EAL 5 is intended to address such items as plant or helicopter crash, or on some site, train crash, or barge crash into a plant vital area.

C:..:::: 54L- n 3, =! S : : ::=1 =d:: !C CA!, D=:n::::= Ph==.== Ap::::; S:l: 22:!=-

< Generic > EAL 7 covers other (Site-Specific) phenomena such as flood.

Each of thesc < generic > EALs is intended to address events that may have resulted in a plant vital area being subjected to forces beyoix! design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial " report" should not be interpreted as mandating a lengthy damage assessment before classification. No attempt is made in <these Generic > EAL to assess the actual magnitude of the damage. Escalation to a higher emergency class, if appropriate, will be based on <Equipinent Failure, Electrical, Fission Product Barrier Degradation, Radioactisity Release, or SEC) Judgment ICs.

Multi-unit stations with shared safety functions should further consider how this IC may afect more than one unit and how this may be a factor in escalating the emergency class.

NUMARC Ouestions and Answers. June 30.1993 Glazards and Other Cc:Bions Affectine Plant Safety)

11. EAL 2 of HA1 is based upon the FSAR desiep basis windspeed. Meteorological instrumentation is used to determine if this windspeed is reached. In the case of a hurricane, conditions may disable this instrumentation well before the design basis speed is reached. Denied windspeed information, the operators would have no way of knowing if the design basis value is being approached.

Similarly, a tornado could impact a plant site and sever be recorded on the meteorological lastrumentation because of the storm's localized winds. Because of these limitations, EAL 2 should not be based on a wind velocity value. For a hurricane, the EAL should instead be a hurricane warning for a storm with winds in excess of the design basis limit. Since tornado winds cannot be directly measured, entry into <an EAL> should be based on the severity of damage that occurs.

The meteorological towr should not be usedfor assessment of hurricane and tornado winds for emergency classification purposes. Afeteorologicaltowers typically are designedfor sustained winds of 1N aqph. Instrumentation is calibrated to IN mph and may survive to 125 nqph. Hurricane wind speed data usedfor emergency classification purposes should be the estimated sustained winds provided by the National Weather Service or hurricane warning indication. For tornadoes or other high uind conditions, damage exceeding HAIE4L 3 uvuld be prima facie evidence of uinds exceeding design basis.

12. EAL 2 of HA1 is met only when winds exceed FSAR design basis. What if the Vital Area is "affected" at winds less than the design basis?

If Vital Areas are afeded (damaged) by winds less than the design basis nind, then HAIM4L 3 uvuld

^995 0 Plant Soecificinformation:

Calvert Cliffs EALs = Mf i ="y = " MARC d include the Independent Spent Fuel Storage Installation (ISFSI),

as appropriate.

Calvert Cliffs EAL Basis Document N:6 Rev.7

NATURAL HAEARDS PHENOMENA la response to Generic EA L 1, Calvert CliNs EAL 1 is written: E ^1 ! i: ;f:= =:

l Seismic Event Causing Ground Acceleration GREATER THAN 0.08g Horizontal Or 0.053g Vertical l This EAL addresses the Operating Basis Earthquake (OBE) as described in UFSAR Section 2.6.5.2.

Verification of damage can be by physical observation, or by indications of degraded equipment performance in the Control Room or at local control stations.

In response to Geocric EAL 2, Calvert CliNs EAL 2 4 uses a sustained wind speed of 90 MPH to address high winds striking the Plant Vital Area = r - M h h"21^"C. Although tThis speed is below the FSAR design basis it was chosen to assure that the wind speed is within the design capability of the meteorological tower.

The duration of 15 minutes is selected to indicate sustained winds and to preclude wind gusts. Wind speeds are also provided here in meters /second for dose assessment input. The conversion equation is as follows:

l 90 miles / hour x 5280 feet / mile x (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> /3600 seconds) x 1 meter /3.2808 feet) = 40 meters /second l In response to Generic EAL 2, Calvert CliNs EAL 2 is written: E=. E *13 i: =i = =:

l Sustained Wind Speed GREATER THAN 90 MPH (40 meters /second) for AT LEAST 15 Minutes l In response to Generic EAL 3, Calven CliNs EAL 3 and 4 are are written: E ^12 i;;"t= =: l EAL3 I V:d ' Pgn ic C=" : ".== 0' Vid': P-- ;- :: ". -f: c'M "#;-- ' Observable damage to eeulpment located inside as Area of Concern for Safe Shutdown.

The Refueling Water Tanks (RWT) and Pretreated Water Storage Tanks (PWST) do not contain equipment therefore EAL 4 is written:

l Damage to RWT 11(21) or PWST 11(12) that in the SEC's judgement is significant. l The latent of EAL 3 and 4 is to address stewctural damage to buildings that contain safety systems, the RWT, and PWST. A declaration must be made without doing a lengthy damage assessment of the building or tank to determine whether or not it has been subjected to forces beyond design basis. The EAL wording addresses this need. The  !

slightest damage to equipment located inside an Area of Concern for Safe Shutdown is suNicient to put tbc structural  ;

lategrity of the building itself in question. When assessing the significance of damage done to the RWT or PWST the '

SEC should consider structural damage rather than cosmetic.

Generic EAL 4 is addressed by IC OA1, SEC Judgment.

Generic EAL 5 is addressed by OA3, Destructive Phenomena ANecting Safe Shutdown.

Generic EAL 6 is addressed by OA3, Destructive Phenomena ANecting Safe Shutdown.

Per UFSAR Section 2.8.3.6, the still water level used for intake Structure analysis is 17.6 feet MSL. This is above the top of the range of the Tide Level Recorder (0-LR-5195). The top of the Traveling Screen caer housings is about 18 feet MSL.

Calvert CliNs EAL 4 indicates achieving the design water level.

In response to Generic EAL 7, Calvert CliNs EAL 5 and 6 are written: E= E ^1 ' i: :" x =:

l Bay Water Level At Or Above the Top of the Traveling Screen Cover Housing l Calvert CliNs EAL Basis Document N:7 Rev.7

NATURAL HAEARDS PHENOMENA l Per UFSAR Section 2.8.3.7, the predicted extreme low tide is -3.6 feet MSL and the plant is designed to safely operate at an extreme low water level of 4.0 feet MSL. EAL 5 is based on the lower elevation.

In response to Generic EAL 7. Calvert Cliffs EAL 6 is written: S.=. EAL 5 E "=: =-

l Bay Water Level Is AT LEAST 6 Feet Below Mean Sea Level l Surveillance Test Procedures provide a way to determine Bay level.

Source Documents / References / Calculations:

1. Updated Final Safety Analysis Repon

2. Operating Instrusion (OI) 46, Seismic Measurement Equipment

3. BG&E Drawing 60-220-E (M-31), Equipment Location Service Building, Water Treatment Area & Intake Structure Section "M"

4. BG&E Internal Memorandum, J.E. Thorp to R.E. Denton, Emergency Action Level Review Criteria, June 1,1990 Calven Cliffs EAL Basis Document N:8 Rev.7

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Calvert Clins EAL Basis Docuanent Rev.7

' THER HAZARDS Emeraency Classification Level: UNUSUAL EVENT Anolicable Operational Modes: ALL Calvert Cliffs Initiatinn Condition:

0U1 SEC Judgement i

NUMARC R-nhian Catenory: Hazards and Other Conditions Affecting Plant Safety }

l NUMARC Initiatina Condition:

i HUS Other Conditions Existing Which in the Judgement of the Emergency Director Warrant Declaration of an Unusual Event Barner Not Applicable NUMARC Generic Emernency Action Imels Example Emergency Action I.4 vel:

1. Other conditions exist which in the judgment of the Emergency Director indicate a potential degradation of the level of safety of the plant.

l NUMARC Generic Basis: 1 This < Generic > 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 <SEC> to fall under the Unusual Event emergency class.

From a broad perspective, one area that may warrant <SEC) judgement is related to likely or actual breakdown of  !

site specific event mitigating actions. Examples to consider include inadequate emergency response procedures, transient response either unexpected or not understoed, failure or unavailability of emergency systems during an accident in excess of that assumed in accident analysis, or insufficient availability of equipment and/or support personnel.

Specific examples of actual events that may require <SEC> judgement for Unusual Event declaration are listed here for consideration. However, this list is by no means all inclusive and is not intended to limit the discretion of the site to provide further examples.

• Aircraft crash on-site e . Train derailment on-site

• Near-site explosion which may adversely affect normal site activities.

• Near-site release of toxic or flammable gas which may adversely affect normal site activities e Uncontrolled RCS cooldown due to Madary Depressunzation It is also intended that the <SEC's> judgement not be limited by any list of events as defined here or as augmented by the site. This list is provided solely as examples for consideration and it is recognized that actual events raay not always follow a pre-conceived description.

Calvert Cliffs EAL Basis Document 0:1 Rev.7

OTHER HAZARDS NUMARC C="'-- and Answers. June 30.1993 (Hazards and Other Oxf%== Affectine Plant Safety)

5. What is the latent of HU1/EAL37 This EAL appears to be covered by HU5.

As stated in the basis, EAL 3 ofHUI allone control roompersonnel to make the ddermination (udthout moitingfor versfscation) that a natural or destrudive phenomenon has occurred that marrants the declarnak n of an Unusual Event. HUS applies to any situation not explicitly addressed in the EALs that, in theJufpnent of the Emergency Diredor, merits an emergency declaration.

10. Missile impacts maa rescitant damage should be included for consideratien in HUS.

3 Missile impads and resultant damagefall nithin exangpie EALs 3 and 5 of HU1. The basis could be anpanded to include missde ingpeds pecificallyfor HU1/EAL 5. Missile impads frone ofsite events should be included in HUNEAL 7. Licensees may choose to adopt a site-gecific EAL to addreu aussile ingpads.

Plant-Snecific Information:

Site Emergency Coordinator (SEC) is the title for the emergency director function at Cwvert Cliffs. n=, $: E.^.L te-wnteer In response to the Generic EAL, Calven Cliffs EAL is written:

Any Condition Which in the SEC's Judgment Indicates Potentia! Degrritation in the Level of Safety of the Plant The SEC is not limited as to the esents that may be considered when judging the impact on plant safety.

I- $!: ---- :, 9 E^.L "- - r:f tr d:: f:!! '-- 1: M:'.i"=dx cf U :r ' E==: :-- :;nrj

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.An EAL responsive to aircraft crash on-site is addressed in IC OU3, Destructive Phenomena.

Calven Cliffs Nuclear Power Plant is not le close proximity to any railroad therefore train derailment is not addressed by this scheme.

An EAL for near-site explosion is addsessed in IC OU3, Destructive Phenomena.

EAL's for stu-site release of toxic or flammable gas are addressed in IC OU2, Toxic or Flammable Gas.

An EAL !or uncontrolled RCS cooldown is addressed in IC OUS, Secondary Depressurization.

Source Documents /Rifwe,ces/Calenh' ions:

1. Emergency Response Plan

2. :PJ"IC "'5 0.""4 ^. "I" 1, Cd;_. . f : P- ;:- Mr ud Ed:fS c' P-f:':gr! " - ;;.rj

"^ : ::n "'- - ' P- ;:: '- - i.- E;;:1 ef "c!z P::=

P'--" "addx 1, ^=d:: 19*0,

. -;;:: f: 1 Calvert Cliffs EAL Basis Document O;2 Rev.7

OTHER HAZARDS l l

Ewin..cv Cia inentian level: UNUSUAL EVENT Apohcable Operational Modes ALL Calvert Cliffs laisiasino Condition:

CU2 Toxic or Flammable Gases NUMARC Raca-aitiaa Casa ary: Hazards and Other Conditions Affecting Plant Safety NUMARC Initiatine Caadisian:

' HU3 Release of Toxic or Flammable Gases Deemed Detrimental to Safe Operation of the Plant l

Bamer Not Applicable NUMARC Genenc Basis This IC is based on releases in concentrations within the site boundary that will affect the health of plant personnel or affecting the safe operation of the plant with the plant being within the evacuation area of an offsite event (i.e.,

tanker truck accident releasing toxic gases, etc.) The evacuation area is as determined from the DOT Evacuation Tables for Selected Hazardous Materials, in the DOT Emergency Response Guide for Hazardous Materials. < > j Plar.t-Snecific Information:

For the purposes of this IC, Halon (such as is discharged by the fire suppression system) is not toxic. Fire i suppressant discharge can be lethal ifit reduces oxygen to low concentrations that are immediately dangerous to life and health (IDLH). Fire suppressant discharge into an area is not basisfor emergency classification under this JC unless: (1) Access to the afected area is required, and (2) Fire suppressant concentration results in conditions that make the area inaccessible (i.e., ID121).

EAL 1 is written as:

On Site Toxic or Flammable Gas Release Which in the Shift Supervisor's Judgement Could Potentially Degrade the Level of Safety of the Plant EAL 2 is written as:

l Notification of a Near-Site Release That May Require Evacuation of Plant Personnel l This EAL addresses releases that could originate from the Cove Point Liquid Natural Gas Plant.

Source Dac=*a'dReferences/Calcul.glips

1. Abnormal Operating Procedures

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AOP-11, Control Room Evacuation and Safe Shutdown Non-Fire Conditions

2. Updated Final Safety Analysis Report Calvert Cliffs EAL Bas:s Document 0:3 Rev.7

OTHER HAZARDS Emeraency Classification Level: UNUSUAL EVENT Anoticable Operational Modes: ALL Calvert Cliffs Initiatina Condition:

OU3 Destructive Phenomena NUMARC Recognition Catenory: Hazards and Other Conditions Affecting Plant Safety NUMARC Initiatina Condition:

HUI Natural and Destructive Phenomena Affecting the Plant Protected Area Bamer Not Applicable NUMARC Generic E;.c.ui. V Action Levels:

Exampic Emergency Action Levels: (1 or 2 or 3 or 4 or 5 or 6 or 7)

1. (Site-Specific) method indicates felt earthquake.

2. Report by plant personnel of tornado striking within protected area boundary.

3. Assessment by the contml mom that an event has occurred.

4. Vehicle crash into plant struct: ires or systems within protected area boundary.

5. Report by plant personnel of an unanticipated explosion within protected area boundary resulting in visible damage to permanent structure or equipment.

6. Report of turbine failure resulting in casinapenetration or damage to turbine or generator seals.

7. (Site-Specific) Occurrences.

NUMARC Generic Basis:

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

C:=:.-:: 2!.: 1, 2, =! .' : : ^ " :.=1 by !C ."!, .' ::2. : .*:z:=:::.

< Generic > EAL 1 should be developed on 2: gific basis. Damage may be caused to some ponions of the site, but should not affect ability of safety functions to operate. Method of detection can be based on instmmentation, validated by a reliable source, or operator anaaament. 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 vibratory gmund anotion is felt at the nuclear plant site and recogn zed as an earthquake based on a consensus of contml 8

room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated. For most plants with seismic instrumentation, the seismic switches are set at an acceleration of about 0.01g.

Calven Cliffs EAL Basis Document 0:4 Rev.7

OTHER HAZARDS

< Generic > EAL 2 is based on the assumption that a tornado striking (touching down) within the protected boundary may have potentially damaged plant structures containing functions or systems required for safe shutdown of the plant. If such damage it confirmed visually or by other in-plant indications, the event may be escalated to Alert.

i

< Generic > EAL 3 allows for the control room to determine that an event has occurred and take appropriate action based on personal assessment as opposed to verification (i.e., an earthquake is felt but does not register on any plant-specific lastrumentation, etc.) ,

< Generic > EAL 4 is intended to address such items as plane or helicopter crash, or on some sites, train crash, or barge crash that may potentially damage plant structures containing functions and systems required for safe '

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

For < generic > EAL 5, only those explosions of sufficient force to damage permanent structures or equipment within the protected area should be considered. As used here, an explosion is a rapid, siolent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to near-by structures 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 the declaration. The <SEC> also needs to consider any security aspects of the explosion, if applicable.

< Generic > EAL 6 is intended to address main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the generator. Of major concern is the potential for leakage of combustible fuels (lubricating oils) and gases (hydrogen cooling) to the plant emirons. Actual fires and flammable gas buildup are appropriately classified via <lCs IU1 and OU2>. This < generic > EAL is consistent with the definition of an Unusual Event while maintaining the anticipatory nature desired and recognmng the risk to non-safety related equipment. Escalation of the emergency classification is based on potential damage done by missiles generated by the failure <> or in conjunction with a steam generator tube rupture, for a PWR. These latter events would be classified by the < Radioactivity Release, Equipment Failure, or Fisdon Product Barrier Degradation > ICs.

< Generic > EAL 7 covers other (Site-Specific) phenomena such as hurricane, flood, or seiche. These EALs can also be precursors of more serious events. In particular, sites subject to severe weather as defined in NUMARC station blackout initiatives, should include an EAL based on activation of the severe weather mitigation procedures (e.g.,

precautionary shutdowns, diesel testing, staff call-outs. etc.)

Multi-unit stations with shared safety functions should further consider how this IC may affect more than one unit and how this may be a factor in escalating the emergency class.

NUMARC Ouestions and Answers. June 30.1993 (Hmrds and Other Conditions Affectine Plant Safety)

1. If generator seal damage is observed after the generator has been purged for disassembly, should an Unusual Event be declared?

For the example given, an Unusual Event should not be declared. The generator seal damage is primafacie evidence that hydrogen gas escaped into the turbine area. In this example, howver, there was no report ofa leak, no detedion ofthe hydrogen, and no e.tplosion or) ire.

In ejfed, the amount ofgas that leaked did not affed normal operation oftheplant.

3. An explosion of an acetylene bottle adjacent to a temporary construction trailer within the protected area does not seem to fall within boundaries of any EAL for HUI. Is this correct?

Yes. The explosion did not involve apermanentplant strudure.

Calvert Cliffs EAL Basis Document 0:5 Rev.7

I OTHER HAZARDS

4. Does HU1/EAL 3 - control room assessment of an event - apply only to EALs 1 and 2 or to all of the EALs.

EAL 3 HUI applies to all example EALs ofHU1.

5. What is the latest of HU1/EAL3 7 This EAL appears to be covered by HU5.

As stated in the basis, EAL 3 of HU1 allows control room personnel to make the determination (without waitingfor verification) that a natural or destrudive phenomenon has occurred that warrants the declaration of an Unusual Event. HUS applies to any situation not ewlicitiv addressed in the EALs that, in theJu4gment of the Emergency Director, merits an emergency declaration. n

6. Can a " vehicle crash" as used in HU1/EAL 4 be caused by an automobile, truck, or forklift?

Tbc basis seems to limit such crasbes to aircraft, trales, or barges.

The scope of the term " vehicle" should not be limited to aircrap, trains, or barges.  !

Automobiles, trucks, andforkhfts are also vehicles nithin the sentext of this EAL The key is whether or not the vehicle can potentially cause signylcant damage toplant structures.

10. Missile impacts and resultant damage should be included for consideration in HU5.

Missile impacts and resultant damagefall nithin example EALs 3 and 5 of HUL The basis could be expanded to include missile impads specifically for HU1/EALS. Missile impads from ofsite events should be included in HU1/EAL7. Licensees may chose to adopt a site-specific EAL to address missile impacts.

Plant-Soccific Informatiog These EALs are 5 M f: :'!y = "UT "C =d include the Independent Spent Fuel Storage Installation (ISFSI).

{

l EAL's responsive to GENERIC EAL's 1,2 and 3 are addressed la IC NUI, Natural Phenomena. j In response to GENERIC EAL 4, Calved Cliffs EAL 1,2, and 3 are written: j t

EAL1 l Vessel crash into the Istake Stmeture Baffle Wall that in the SEC's judgment causes significant damage to I the wall.

Site Emergency Coordinator (SEC) is tbc title for tbc emergency director function at Calvert Cliffs. The ,

Shift Supervisor is most likely to be the SEC for events classified at the Unusual Event level and may be I relieved by others designated for the position.  !

A vessel is any water craft of sufficient size that it could ccuse significant damage to the Intake Stmeture Baffle Wall Even though the Baffle Wall is not within the Protected Area boundary it is being used for this EAL because it is more practical to use it than the Istake Stmeture. Using the Intake Structure would eliminate declarations for crasbes causing severe and eyes catastrophic damage to the wall unless sosmething i serious happens to the Intake Structure. Significant/ severe /catastmpbic damage to the Baffle Wall would be distracting to normal plant operation. Furthermore, an event of this nature by itself is unusual and warrants an emergency declaration. j i

Consideratio.as for EAL 1 are similar to the aircraft ciash into the Owner Contmlied Area.

Calven Cliffs EAL Basis Document O:6 Rev.7

OTHER HAZARDS EAL2 Vehicle crash into any of the below listed structures that in the SEC's judgment causes significant damage to the stmeture:

e 45 foot Switchgear Room '

• Diesel Generator rooms

. Diesel Generator Building (OC/1A) e Vehicles carrying dry stored spent fuel A vehicle is anything of sufficient size that it could cause significant damage to any of the listed structures (e.x. tack, car, forklift, crane, trailer, etc.).

l 1

1 Dis list is derived from the list of Areas of Concern for Safe Shutdown and addresses dry stored spent fuel.

These structures contain functions and systems required for safe shutdown or dry stored spent fuel and are susceptible to vehicle crashes. The list is intended to preclude declarations for crashes that do not involve stmetures containing functions and systems required for safe shutdown. Containments, Condensate Storage Tank 12, Fuel Oil Storage Tank 21 and the ISFSI are not included because land vehicles are not of sufficient size to cause significant damage to these structures given the area of travel Significant damage to these simctures would occur only as a result of an aircraft crash and hence ait covered by the aircraft crash EAL.

De Refueling Water Tanks (RWTs) and Pretreated Water Tanks (PWST) air not included. A vehicle crash into these tanks resulting in significant damage to the tank will b: . ease for e Alert declaration under, IC OA3, Destructive Phenomena Affecting Safe Shutdown. It isn't practical to divinguish between Unusual Event and Alert level damage to these tanks. Doing so would challenge the objective Of being able to make a declaration without doing a lengthy damage assessment.

EAL3 Aircraft crash into any of the below listed areas: I e Plant Protected Area e Owner Controlled Area

]

• ISFSIProtected Area Thia EAL considers the unusual nature of the event as much as the potential for impacting plant safety.

Hence the EAL does not have a qualifier for damage. The Owner Controlled Area is included in part because of NUMARC Generic IC HU5, (SEC Judgment), and because a crash in this area would be distracting to normal plant operation.

In response to Generic EAL 5, Calvert Cliffs EAL 4 is written:

Explosion within any of the below listed areas:

• Plant Protected Area e ISFSIProtected Area An explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment.

The occurrence of the explosion with reports of evidence of damage (deformation, scorching) is sufficient for a declaration.

In response to Generic EAL 6, Calvert Cliffs EAL 5 is written:

l Turbine failure causing observable casing damage. l Turbine failures that cause seal damage without casing damage are addressed by IC OU2, Toxic or Flamnable Gases, laternal casing dsmage discovered subsequent to turbine disassembly after a turbine failure Joes not warrant an emergency declaration.

Calvert Cliffs EAL Basis Document O.7 Rev.7

OTHER HAZARDS In response to Generic EAL 7, Calved Cliffs EAL 6 is written:

l Flooding la as Ana of Concera for Safe Shutdown that la the SEC's judgment is significant. l ;

Mooder lodicates that the act water flow lato the moas nsults la elevated water levels, may be most thaa i available drain capacity, and if coatissed, can prevent operation of equipment la the room. Thus, minor l water level lacetases that may result la wet floors and de act pose a challenge to equipment operation are not included la this EAL. Areas of Concera for Safe Shutdown are listed below. Rooms located below MSL include the ECCS Pump Roomas and the Charging Pump Rooms. Ilie Shutdows Cooling Heat Exchangers are also located la the ECCS Pump Roomas. Such flooding can result la a potential degradation la the inel of

]

safety of the Calved Cliffs plant and is therefore included in this EAL. l l

IC 001, SEC Judgecat is also responsive to GENERIC EAL 7.

Areas of Concer1s for Safe Shutdown e Control Room . Electrical Penetration Rooms e Contiel Rooni HVAC Room e Auxiliary Feedwater Pump Room o Cable Spitading Room o Charging Pump Rooms e Cable Chases e Diesel Generator Rooms

. Switchgear Room . Diesel Generator Building (OC/1A) e ECCS Pump Room e Refueling Water Tank (RWT) 11(21) e Service Water Pump Room e Condensate Storage Tank (CST) 12 e Component Cooling Pump Room . Pretreated Water Storage Tank (PWST) 11(12) e Main Steam Penetration Room . Fuel Oil Storage Tank (FOST) 21 e Istake Structure This list of Safe Shutdown areas is displayed on the EAL Tables to assure that all areas atlated to .

Safe Shutdown are considered by the SEC. l 1

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OTHER HAZARDS

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Source Documents / References / Calculations:

1. Updated Final Safety Analysis Report

2. BG&E Drawing 60-220-E (M-31), Equipment Location Service Building, Water Treatment Area &

Intake Structure Section "J4"

3. BG&E Drawing 83 278-E, Plan Auxiliary Building Restricted Access Area El. (-)8'-0", (-)l0'-0" And (-

)l5'-0"

4. Letter, G.C. Creel (BG&E) to U.S. Nuclear Regulatory Commission Document Control Desk, Emergency Action level Revision, September 24,1992 Calvert Cliffs EAL Basis Document O:9 Rev.7

f

]

I OTHER HAZARDS Emeraency C6=%tian Level: ALERT Anoticable Operational Modes: ALL Calvert Cliffs initiatina Condition:

OAl SEC Judgement NUMARC Pm-nitian Catenory: Hazards and 6ther Conditions Affecting Plant Safety

@ MARC Initiatine Condition:

HA6 Other Conditions Exist Which in the Judgement of the Emergency Director Warrant Declaration of an Alert Bamer. Not Applicable NUMARC GenericBasig:

This < Generic > 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 <SEC) to fall under the Alert Emergency Class.

Plant-Soccific Information: l Site Emergency Coordinator (SEC) is the title for the emergency director function at Calvert Cliffs.

1 Thus. EAL 1 is written as:

Any Condition Which in the SEC's Judgement Indicates That Safety Systems May Be Degraded AND Which Requires Emergency Response Organization Staffing In this manner, the EAL addresses conditions that fall under the Alert emergency classification description contained in NUREG-0654, Appendix 1 that is retained under the NUMARC methodology.

At Calvert Cliffs, the emergency response organization would be activated on entry into EOP-8; thus, it is included here as an EAL.

Thus. EAL 2 is written as:

l EOP-8. Functional Recovery Procedure, is Implemented l Source Dx"=== References /Calculatip_ng:

1. Emergency Response Plan

2. NUREG-0654/ FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Resision 1, October 1980, Appendix 1

3. Emergency Operating Procedures EOP-8, Functional Recm cry Procedure Calvert Cliffs EAL Basis Document O:10 Rev.7

GTHER HA71.RDS Emeraency Classification Level: ALERT ApplicableOperationalModes ALL Calvert ' . ffs Initiatina Condition:

OA2 Toxic or Flammable Gases Affecting Safe Shutdown NUMARC R==nitian Catenorv: Hazards and Other Conditions Affecting Plant Safety NUMARC Initianian Condition:

HA3 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 Barner: Not Applicable NUMARC Genenc Basis This IC is based on gases that have entered a plant structure affecting the safe operation of the plant. This IC

. applies to buildings and areas contiguous to plant Vital Areas or other significant buildings or areas (i.e., Senice Water Pumphouse). The intent of this IC is not to include buildings (i.e., warehouses) or other areas that are not I coatiguous or immediately adjacent to plant Vital Areas. It is appropriate that increased monitoring be done to ascertain whether consequential damage has occurred. Escalation to a higher emergency class, if appropriate, will be based on < Electrical, Equipment Failure, Radioactivity Release, Fission Product Barrier Degradation, or SEC Judgement ICs.> <>

Plant SnecificInformation:

For the purposes of this IC, Halon (such as is discharged by the fire suppression system) is not toxic. Fire suppressant discharge can be lethal if it reduces oxygen to low concentrations that are immediately dangerous to life and health (IDLH). Fire suppressant discharge into an area is not basisfor emergency classification under this 1C unless: (1) Access to the afected area is required, and (2) Fire suppressant concentration results in conditions that make the area inaccessible (i.e.,1 Dill).

Thus, the EAL is written as:

l Toxic or Flammable Gas Making Safe Shutdown Areas inaccessible. l This EAL also addresses releases that could originate from the Cove Point Liquid Natural Gas Plant.

The areas of concern for safe shutdown are identified below.

Areas of Concern for Safe Shutdown e ControlRoom o Electrical Penetration Rooms e ControlRoom HVAC Room e Auxiliary Feedwater Pump Room e Cable Spreading Room o Charging Pump Rooms e Cable Chases e Diesel Generator Rooms e Switchgear Room . Diesel Generator Building (OC/l A) e ECCS Pump Room e Refueling Water Tank (RWT) 11(21) e Service Water Pump Room o CoMensate Storage Tank (CST) 12 e Component Cooling Pump Room e Pretreated Water Storage Tank (PWST) 11(12)(44) o *

• Main Steam Penetration Room Fuel Oil Storage Tank (FOST) 21 +2

• Istake Structure This list of Safe Shutdown areas is displayed on the EAL Tables to assure that all areas related to Safe Shutdown are considered by the SEC.

Calvert Cliffs EAL Basis Document O:11 Rev.7

OTHER HAZARDS Source Dociunents/ References / Calculations:

1. Updated Final Safety Analysis Report Calvert Cliffs EAL Basis Document 0:12 Rev. 7

OTHER HAZARDS Emergency Classification Level: ALERT Anolicable Operational Modes: ALL Calvert Cliffs Initiatina Condition:

OA3 Destructive Phenomena Affecting Safe Shutdown NUMARC Recognition Category: Hazards and Other Conditions Affecting Plant Safety NUMARC Initiatina Condition-1 HA1 Natural and Destructive Phenomena Affecting the Plant Vital Area l

Barner: Not Applicable NUMARC Generic E.T.c.a cv Action levels Example Emergency Action Levels: (1 or 2 or 3 or 4 or 5 or 6 or 7)

1. (Site-Specific) method indicates Seismic Event greater than Operating Basis Earthquake (OBE).

2. Tornado or high winds striking plant vital areas: Tornado or high winds girater than (site-specific) mph strike within protected area boundary. l

3. Report of any visible structural damage on any of the following plant stmetures:

• Reactor Building e Intake Building e Ultimate Heat Sink e Refueling Water Storage Tank e Diesel Generator Building

. Turbine Building

• Condensate Storage Tank e Control Room

. Other (Site-Specific) Stevetures

4. (Site-Specific) indications in the control room.

5. Vehicle crash affecting plant vital areas.

6. Turbire failure generated missiles result in any visible structural damage to or penetration of any of the following plant areas (site-specific) list.

7. (Site-Specific) occurrences.

NUMARC Generic Basis:

C:=:::: Eib !, 2, =d ? :. : " ::::d ==d:-IC ?"!, N:: ::!Ph:===^:== .4f::: =g &l: FF=:d:--

< Generic > EAL 1 should be based on (site-specific) FSAR design basis. Seismic events of this magnitude can cause damage to safety functions.

Calvert Cliffs EAL Basis Document 0:13 Rev.7

OTHER HAZARDS

< Generic > EAL 2 should be based on (site-specific) FSAR design basis. Wind loads of this magnitude can cause damage to safety functions.

< Generic > EAL 3 should specify (site-specific) structures containing systems and functions required for safe shutdown of the plant.

< Generic > EAL 4 should specify the types of instrumentation or indications including judgment which are to be used to assess occurrence.  ;

i

< Generic > EAL 5 is intended to address such items as plane or helicopter crash, or on some sites, train crash, or l barge crash into a plant vital area.

< Generic > EAL 6 is intended to address the threat to safety related equipment imposed by missiles generated by i main turbine rotating component failures. This (site-specific) list of areas should include all safety related equipment, their controls, and their power supplies. This EAL is, therefore, consistent with the definition of an ALERT in that if missiles have damaged or penetrated areas containing safety-related equipment the potential exists for substantial degradation of the level of safety of the plant.

< Generic > EAL 7 covers other (Site-Specific) phenomena such as flood.

Each of these < generic > EALs is intended to address events that may have resulted in a plant sital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial " report" should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in <these> EAL to assess the actual magnitude o'the damage. Escalation to l

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

NUMARC Ouestions and Answers. June 30.1993 (Hazards and Other Conditions Affectine Plant Safety)

None Plant-Soecific Information:

The Calvert Cliffs EALs are based on a report to the control room of damage affecting equipment located in Areas of Concern for Safe Shutdown. =S d $ .t2=.

EALs responsive to Generic EAL's 1 and 2 are addressed in IC NA1, Natural Phenomena.

EALs responsive to Generic EAL 3 are addressed in:

. EAL for IC NA1, Natural Phenomena Affecting Safe Shutdown

. EAL for IC OA1, SEC Judgment e ne below listed EAL for this IC (OA3, Destructive Phenomena Affecting Safe Shutdown).

An EAL responsive to Generic SAL 4 is addressed in IC OA1, SEC Judgment.

Calvert Cliffs EAL Basis Document 0:14 Rev.7

OTHER HAZARDS In response to Generic EAL 3,5,6 and 7, Calvert Cliffs EALI an 2 are wrtten:

EAL1 Observable damage to equipment located inside an Area of Concern for Safe Shutdown caused by any of the followleg:

e VehicleNessel/ Airplane crash e Turbine failust generated missile e Severe weather generated missile e Explosion generated missile e Flooding EAL2 Damage caused by any of the following to RWT 11(21) or PWST 11(12) that la the SEC's judgement is significant.

e Vehicle / Vessel / Airplane crash e Turbine failure generated missile e Severe westber generated missile e Explosion generated missile

. Flooding These EALs address aircraft, cars, trucks, forklifts, trailers, missiles generated fewei turbine failure, severe weather and explosions, and flooding.

A separate EAL is written for the RWT/PWST because these tanks do not contain equipment.

The latent of these EALs is to address structural damage to buildings that contain safety systems, the RWT, and PWST. A declaration must be made without doing a lengthy damage assessment of the building or tank to determine whether or not it has been subjected to forces beyond design basis. 'Ibe EAL wording addresses this aced. The slightest damage to equipment within an Anta of Concern for Safe Shutdown is sufficient to put the structural integrity of the building itself in question. It provides a distinct threshold above Unusual Event, Other Hazards. When assessing the significance of damage done to the RWT or PWST the SEC should consider structural damage ratber than cosmetic.

Calvert Cliffs is not located in close proximity to any railroad therefore train derailments are not included.

Missiles generated froan explosions is la addition to that addressed la NUMARC genede basis, la the case of floodia2, observable damage includes evidence / indication / observation that equipment was/is submerged.

The SEC must exertisc judgment for partial submergence. For exampic a submerged motor pedestal may not damage the motor.

E?.L ! "- . .i.7 - ' r;"::, t e., i: ., " '1, :: , 0- ._i - "' ':1. S.!: E?.L i:: ::: inii ; '

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Calvert Cliffs EAL Basis Document 0:15 Rev.7 l

OTHER HAZARDS E.^13 i::":::: =:

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The list of areas of concern for Safe Shutdown are shown below and=: px- '-- y i ;!:yd := th E ^.L Td!;. i Areas of Concern for Safe Shutdown e Control Room o Electrical Penetration Rooms e Control Room HVAC Room e Auxiliary Feedwater Pump Room

. Cable Spreading Room e Charging Pump Rooms e Cable Chases e Diesel Generator Rooms 1

• Switchgear Room o Diesel Generator Building (OC/l A) i e ECCS Pump Room e Refueling Water Tank (RWT) 11(21) l e Senice Water Pump Room e Condensate Storage Tank (CST) 12 e Component Cooling Pump Room e Pretreated Water Storage Tank (PWST) 11(12)(34) e Main Steam Penetration Room o Fuel Oil Storage Tank (FOST) 2143

. Intake Stmeture  !

This list of Safe Shutdown areas is displayed on the EAL Tables to assure that all areas related to Safe Shutdown are considered by the SEC. -

I Source Documents / References / Calculation 3: 1

1. Updated Final Safety Analysis Report Calvert Cliffs EAL Basis Document O:16 Rev.7

@THER HAZARDS l

Emeraency Classification Level: ALERT Analicah!c Onerational Modes: ALL Calvert Cliffs Initiatino Condition:

OA4 Control Room Being Evacuated l- NUMARC Recognition Catenorv: Hazards and Otirr Conditions Affecting Plant Safety l NUMARC Ini'infine Condition:

HA5 Control Room Evacuation Has Been Initiated i

Barner, Not Applicable j NUMARC Generic Basis:

With the control room evacuated, additional support, monitoring and direction through the Technical Support l Center and/or other Emergency Operations Center is necessary. Inability to establish plant control from outside the control room will escalate this event to a Site < Emergency >,

Plant-Snecific Information:

l This EAL addresses events requiring evacuation of the Control Room such as fire or toxic gas release that make  !

i the Control Room uninhabitable and transferring of control to local stations outside the control room. AOP-9A l l

(fire conditions) and AOP-11 (non-fire conditions) control actions for Control Room evacuation and re-establish l control of the plant.

l

\

l

! Thus, the EAL is written as:

l Control Room Evacuation Initiated per AOP-9A or AOP-11 l Source Documents / References / Calculations:

1. Abnormal Operating Procedures AOP-9A, Control Room Evacuation and Safe Shutdown Due to a Severe Control Room Fire

- AOP-11, Control Room Evacuation and Safe Shutdown Non-Fire Conditions

• Calvert Cliffs EAL Basis Document 0:17 Rev.7

OTHER HAZARDS Emergency Classification Level SITE EMERGENCY l

Anolicable Operational Modes: ALL Calvert Cliffs initiating Condition:

OSI SEC Judgement NUMARC Recoenition Category: Hazards and Other Conditions Affecting Plant Safety NUMARC Initiating Condition:

HS3 Other Conditions Existing Which in the Judgement of the Emergency Director Warrant Declaration of Site

<E>mergency Barner Not Applicable NUMARC Generic Basis:

This < Generic > 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 <SEC) to fall under the emergency class description for Site < Emergency >.

Plant-Soccific Information:

Site Emergency Coordinator (SEC) is the title for the emergency director function at Calvert Cliffs.

Thus, the EAL is written as:

Any Condition Which in the SEC's Judgement Indicates Loss or Potential Loss of Two Fission Product Barriers In this manner, the EAL addresses conditions that fall under the Site Emergency classification and is consistent with the Fission Product Barrier Degradation EAL Table.

Loss means that a severe challenge to a tission product barrier (Fuel Clad, RCS, or CNTMT) exists such that the barrier is considered incapable of performing its safety function.

Potentialloss means that a challenge to a fission product barrier (Fuel Clad, RCS, or CNTMT) exists such that the barrier is considered degraded in its ability to perform its safety furetion.

Source Documents / References / Calculations:

1. Emergency Response Plan

2. NUREG-0654/ FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, October 1980, Appendix 1 Calvert Cliffs EAL Basis Document 0:18 Rev.7

l OTHER HAZARDS Emernency Classification Level: SITE EMERGENCY Aindicable Onerational Modes: ALL Calvert Cliffs Initiating Condition:  :

i OS2 Control Room Has Been Evacuated AND Timely Plant Control Can NOT Be Established NUMARC Reconnition Catenorv: Hazards and Other Conditions Affecting Plant Safety NUMARC Initiatina Condition:

HS2 Control Room Evacuatica Has Been initiated And Plant Control Can Not Be Established Bamer Not Applicable NUMARC Generic Bas,ig:

Expeditious transfer of safety systems has not occurred but fission product barrier damage may not yet be indicated.

(Site-Specific) time for transfer based on analysis or awaments as to how quickly control must be reestablished without core uncovering and/or core damage. This time should not exceed 15 minutes. In cold shutdown and refueling modes, operator concern is directed toward maintaining core cooling such as is discussed in Generic Letter 8817, " Loss of Decay Heat Removal", in power operation, hot standby, and hot shutdown modes, operator concern is primarily directed toward maintaining critical safety fimetions and thereby assuring fission product barrier integrity. Escalation of this event, if appropriate, would be by < Fission Product Barrier Degradation, Radioactivity Release, or SEC) Judgement ICs. <>

Plant Soccific Information:

This EAL addresses events requiring evacuation of the Control Room such as fire or toxic gas release that make the Control Room unhabitable and transferring of control to local stations outside the control room. AOP-9A (fire conditions) and AOP-11 (non-fire conditions) control actions for Control Room evacuation and re establish control of the plant.

An analysis was performed of how quickly control must be re-established at Calvert Cliffs without core uncovery or damage to develop an appropriate site-specific EAL. A RETRAN simulation shows that the steam generators go dry at about 47 minutes for the AOP-9 (station fire) scenario. RCS pressure reaches the lowest pressurizer safety i valve setpoint soon thereafter. Restoring feedwater within 45 minutes assures that R.CS pressure remains below the safety valve setpoint thus avoiding inventory loss. The maximum time allowable to restore RCS inventory for Appendix R (station fire) scenarios is 90 minutes. Site Emergency declaration at 30 minutes and 60 minutes for inability to restore feedwater and RCS make-up respectively thus constitutes a consenative action for emergency <

response.

l i

This EAL is established based on previous analyses and actual procedure walk throughs. Licensee Event Report l (LER) 50-371/89-009, Rev. 2 was provided to the NRC on July 7,1989 to document the analysis performed to i demonstrate the ability to safely shutdown Unit 1 in accordance with AOP-9.

l Three NRC inspections documented in inspection Report 50-317/90-05,90-13 & 90-34 and 50 318/90-05, 90-13 j

& 90-34 reviewed the issue and concluded that BG&E's actions to develop and implement Alternative Safe l Shutdown Procedure were adequate. One specific issue reviewed by the NRC was the procedure technical basis i document. Additionally, the NRC observed portions of our procedure validation process. This included a )

walkdown of Abnormal Operating Procedure 9A, " Control Room Evacuation and Safe Shutdows Due to a Severe j Control Room Fire."

Calvert Cliffs EAL Basis Document O:19 Rev.7 i

i OTHER HAZARDS Thus, the EAL is written as:

l l Control Room Evacuation Initiated AND Either of the Following: l l

• Inability to Establish Auxiliary Feedwater to AT LEAST One Steam Generator Within 30 t

Minutes e Inability to Establish Reactor Coolant Make-up (Charging Pump Flow) Within 60 Minutes Source Documents / References /C=Imlatiojng:

1. Abnormal Operating Procedures AOP-9A, Control Room Evacuation and Safe Shutdown Due to a Severe Control Room Fire a AOP-11, Control Room Evacuation and Safe Shutdown Non-Fire Conditions

2. Letter, L.B. Russell (BG&E) to James H. Joyner (U.S. Nuclear Regulatory Commission Region 1),

Emergency Action Level Review Meeting, June 6,1991 1

l i

l t

i

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J i

1 I

Calvert Cliffs EAL Basis Document 0:20 Rev.7 1

i

@THER HAZARDS Emeraency Classification Level: GENERAL EMERGENCY Aanticable Ooerational Modes: ALL Calvert Cliffs f aitiatine Condition:

I OG1 SEC Judgement 1

NUMARC R-nitian Catenory: Hazards and Other Conditions Affecting Plant Safety i NUMARC Initiatine Condition:

HG2 Other Conditions Existing Which in the Judgement of the Emergency Director Warrant Declaration of General Emergency Bamer Not Applicable NUMARC Generic Basis:

This < Generic > 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 <SEC> to fall under the General Emergency class. <>

Plant SoccificInformation: i l

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

Any Condition Which in the SEC's Judgement Indicates Potential for Radiological Releases Requiring Off-Site Protective Actions  !

In this manner, the EAL addresses conditions that fall under the General Emergency classification description contained in NUREG-0654, Appendix 1.

Source Documents / References /Calentatione:

1. Emergency Response Plan

2. NUREG-0654/ FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, October 1980, Appendix 1 I

h Calvert Cliffs EAL Basis Document O:21 Rev.7