ML20236W650

Emergency Action Level Basis Document

ML20236W650
Person / Time
Site:	Crystal River
Issue date:	07/31/1998
From:	FLORIDA POWER CORP.
To:
Shared Package
ML20236W649	List: 3F0798-20, Forwards Crystal River Unit 3 Emergency Action Level Basis Document, Rept Applied Methodology That Is Consistent W/ NUMARC/NESP-007,Rev 2.Commitments Made by Util,Encl ML20236W650
References
NUDOCS 9808060125
Download: ML20236W650 (70)

Text

FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 ATTACHMENT B CRYSTAL RIVER UNIT 3 EMERGENCY ACTION LEVEL BASIS DOCUMENT l 1

JULY 1998

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[88" 28an*8?jjp j l

EMERGENCY ACTION LEVEL BASIS DOCUMENT I TABLE OF CONTENTS l

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I ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ....................................... 3 l Gaseous Effluents Liquid Effluents Radiation Levels l Fuel Pool Water Level increase l

NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT ..................... ................ 14

Earthquake Flood d

Hurricane Tornado Aircraft / Vehicle Crash Toxic or Flammable Gas l Explosions or Pressurized Equipment Failure Fire Control Room Evacuation Security Event l Internal Flooding i Emergency Coordinator Judgment l S YSTEM M A LF U NCTI ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 Loss of Communication Failure of Reactor Protection Improved Technical Specification l Loss of Indications i Fuel Clad Degradation ,

Turbine Failure RCS Leakage l Loss of Function (Hot Shutdown)

Inadvertent Criticality LOS S O F POW E R . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 5 Loss of AC Power Loss of DC Power FISSION PRODUCT B ARRIER M ATRIX BASIS ..... ... ...... . . ... . ... ... . . .. . . . . . . .. . . . . . . ... . . .. .. . 61 l D E FI N ITI O N S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

_____m_________________________._ _____ _ _ _ _ . _ _ . _ . _ . _ . _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _

l Emergency Action Level Basis Document ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUElVF l Gaseous Ef11uents

< MODES: ALL l

Classincation: l Unusual Event l

Initiatine Condition: i An UNPLANNED release of gaseous radioactivity to the environment that exceeds 2 times the tODCM noble gases instantaneous release limit for 60 minutes or longer I

Emernency Action Level:

(1 or 2)

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

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

The Unusual Event threshold value listed on the Release Permits represents 2 times the ODCM limit. Releases in excess of 2 times the ODCM limits continuing for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose is not the primary concern here; it is the degradation in plant control implied by the fact the release was not isolated within 60 minutes. Therefore, it is not intended for the release to be averaged over 60 minutes. For example, a release of 4 times the ODCM for 30 minutes does not exceed this initiating condition. Further, the Emergency Coordinator should not wait until 60 minutes elapses, but declare the event as soon as it is determined the release duration will likely exceed 60 minutes.

This is identified by an increasing trend in monitor readings. This does not include spikes or other erroneous  ;

instrument readouts.

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

Reference:

AUI t

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Emergency Action Level Basis Document ABNORRAL RAD LEVELS / RADIOLOGICAL EFFLUENT Gaseous Emuents MODES: ALL fjaff ficatiorn i Alert Initiating Condition:

.An UNPLANNED release of gaseous radioactivity to the environment that exceeds 200 times the ODCM noble gases instantaneous release limit for 15 minutes or longer Emergency Action Level:

(1 or 2)

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

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

The Alert threshold value listed on the Release Permits represents 200 times the ODCM limit. Unplanned releases in j excess of 200 times the ODCM limits continuing for 15 minutes or longer represent an uncontrolled situation and  ;

hence, a potential substantial degradation in the level of safety. The primary concern for the time factor here is the loss of control of radioactive material allowing the release to continue. The Emergency Coordinator should not wait until 15 minutes elapses, but declare the event as soon as it is determined the release duration will likely exceed 15 minutes.

CR-3 Matrix Reference Number: 1.2 NEl 97-03

Reference:

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

Site Area Emergency Initiatine Condition:

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

(1 or 2 or 3) l

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

Stability Class Mid-Rance Monitor Readine (mR/hr) l A, B, or C 80 D or E 20 i F or G 5 J M

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

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3. Environmental Survey Team results indicate > 100 mR/hr closed window reading at the SITE BOUNDARY for more than one hour l l

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

The 100 mR integrated dose in this initiating condition is based on the 10 CFR 20 annual average population exposure.

It is deemed exposures less than this are not consistent with the Site Area Emergency class description. These values are 10% of the EPA 400 Protective Action Guidelines.

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

. whichever is more limiting.

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

The Dose Assessment Team provides projected dose.

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

Reference:

ASI 5

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

( Gaseous Eftluents l MODES: ALL Classification:

General Emergency l Initiatine Condition:

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

(1 or 2 or 3)

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

Stability Class Mid-Rance Monitor Readine (mR/hr)

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

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

3. Environmental Survey Team field survey results indicate > 1000 mR/hr closed window reading at the SITE BOUNDARY for more than one hour Basis:

To achieve the dose for this initiating condition, core damage with a failure of all the fission product barriers is necessary.

A RM-Al or RM-A2 mid-range monitor reading exceeding the values on the above Table would result in a Site Boundary Dose of > 1000 mR TEDE using conservative meteorology (1 m/see windspeed, G Stability class, no precipitation as outlined on the attached Table).

The 1000 mR TEDE and the 5000 mR Thyroid CDE are based on the EPA protective action guidance which indicates that public protective actions are indicated if the dose exceeds 1000 mrem TEDE or 5000 mrem Thyroid CDE. This is consistent with the emergency class description for a General Emergency. Actual meteorology (including forecasts)

should be used whenever possible.

Classification for items 2 & 3 above result from emergency response team input. For example, the Environmental I

. Survey Team provides actual dose rates which are used to determine dose for the projected duration of the release.

The Dose Assessment Team provides projected dose.

CR-3 Matrix Reference Number: 1.4

- NEI 97-03

Reference:

AGI 6

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

Unusual Event Initiatine Condition:

i An UNPLANNED release of liquid radioactivity to the environment exceeding 2 times the ODCM instantaneous release limit for 60 minutes or longer Emerrency Action Level:

A VALID reading on RM-L2, RM-L7, or sample analysis confirms the release exceeds 2 times the ODCM release limit for 60 minutes or longer Basis:

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

An evaluation is necessary to compare monitor setpoint against the EAL limit.

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

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

Reference:

AUI l

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

Alert initiatine Condition:

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

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

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

CR 3 Matrix Reference Number: 1.6 NEl 97-03

Reference:

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

l Radiation Levels l 110 DES: ALL Classification:

Unusual Event Initiatine Condition:

An unexpected increase in radiation ler:Is within the plant ,

Emereenev Action Level:

- One or more VALID Area Radiation Monitor readings unexpectedly exceeds the values listed below for 15 minutes or longer RM-G3 = 400 mR/hr RM-G4 = 600 mR/hr RM-G9 = 100 mR/hr RM-G10 = 800 mR/hr RM-G17 = 800 mR/hr Basis:

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

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

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

l Monitor Locations; RM-G3 (primary sample room)

RM-G4 (Auxiliary Building entrance corridor)

RM-G9 (Intermediate Building outside RB personnel airk)ck)

RM-GIO (Makeup pump area)

RM-G17 (inside RB at personnel hatch)

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

Reference:

AU2 l

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

Alert jnitiatine Condition:

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

(1 or 2)

1. VALID radiation reading greater than 15 mr/hr for 15 minutes or longer in the Control Room (RM-GI) or the Central Alarm Station (CAS) f DE

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

RM-G3 = 2,000 mR/hr RM-G4 = 3,000 mR/hr RM-G9 = 500 mR/hr RM-G10 = 4,000 mR/hr RM-G17 = 4,000 mR/hr R81151 This addres3es increased radiation levels impeding necessary access to operating stations, or other areas containing equipment operated manually, in order to maintain safe operation or perform a safe shutdown. The specific area radiation monitors were chosen as they represent access corridors to the plant. It is this impaired ability to operate the plant that results in the actual or potential substantial degradation of the level of safety of the plant. The cause and/or magnitude of the increase in radiation levels is not a concern of this initiating condition. The Emergency Coordinator must consider the source or cause of the increased radiation levels and determine if any other Initiating Condition is involved. For example, a dose rate of 15 mR/hr in the control room may be a problem in itself. However, the j increase may also be indicative of high dose rates in the coritainment due to a LOCA. In this latter case, a Site Area l Emergency or General Emergency may be indicated by the Fission Product Barrier Matrix Initiating Conditions. l 1

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- The values listed above represent approximately 5000 times normal monitor readings based on nominal historical data of the monitors during normal plant operation. Portable surveys may be substituted for in plant radiation monitors.

l l . Monitor Locations-

!. RM-G3 (primary sample room)

RM-G4 ( Auxiliary Building entrance corridor)

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

RM-GIO (Makeup pump area)

RM-G17 (inside RB at personnel hatch)

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

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Emergency Action Level Basis Document Radiation Levels (Cont'd)

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

CAS dose rates are determined by portable monitors.

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

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

Reference:

AA3 1

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

Unusual Event Initiatine Condition:

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

(I and 2)

1. (a or b)

a. Uncontrolled level decrease resulting in indications of-2.5 feet in spent fuel pool O.1

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

2. Fuel remains covered with water Basis:

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

i CR-3 Matrix Reference Number: 1.9 NEl 97-03

Reference:

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Emergency Action Level Basis Document }

- ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT Fuel Pool / Water Level Decrease MODEt . ~ALL 1

Classification: l' Alcrt Initiating Condition:

Major damage to irradiated fuel nt loss of water level has or will uncover irradiated fuel outside the reactor vessel Emernency Action Level:

(1 or 2)

1. (a and b)

a. Plant personnel report damage of irradiated fuel BED

b. VALID increasing trend as indicated on RM-G15 or RM-Gl6 or area surveys OR

2. Plant personnel report water level drop has nt will exceed makeup capacity such that irradiated fuel will be uncovered Basis:

There is time available to take corrective actions, and there is little potential for substantial fuel damage. Thus, an l Alert classification for this event is appropriate. Escalation, if appropriate, would occur via Abnormal Rad Levels or {

Emergency Coordinator judgment. j CR-3 Matrix Reference Number: 1.10 NEI 97-03

Reference:

AA2 l

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Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Earthquake f

MODES: ALL Classification:

Unusual Event Initiatine Condition:

Earthquake detected by seismic instrumentation.

Emergency Action Level:

(1 and 2)

1. Ground motion sensed by plant personnel AND

2. Confirmed earthquake causing Annunciator C-3-14 " Seismic System Trouble' alarm Basin Damage may be caused to some portions of the site, but should not affect ability of safe shutdown equipment te opcrate. Method of detection is based on instrumentation, validated by a reliable source, or operator assessment. As defined in the EPRI-sponsored, " Guidelines for Nuclear Plant Response to an Earthquake," dated October 1989, a

" felt earthquake" is:

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

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

Reference:

1101

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Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT l

1 Earthquake i MODES: ALL Classification:

Alert Earthquake detected by seismic instrumentation (1 and 2)

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

2. (a or b)

a. Analysis cor: firms the earthquake at >0.05g OR

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

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

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

This EAL is intended to address an earthquake resulting in a plant vital area being subjected to forces beyond design limi's, and thus damage is assumed to have occurred to plant safe shutdown equipment. The initial report is not interpreted as mandating a lengthy damage assessment before classification and no attempt is made to assess the actual magnitude of the damage.

Additional information on the earthquake (confirmation and magnitude) can be obtained from the U. S. Geological Survey - Golden, Colorado at (303) 273-8500.

If the ability to achieve and maintain safe shutdown exists, item 2b of the EAL is Det met.

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

Reference:

IIAI

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

Unusual Event jnitiatine Condition:

Flood being experienced or projected Emereenev Action Level:

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

This EAL covers flooding due to natural phenomena. This EAL can be a precursor of more serious events. In panicular, since CR-3 may be subject to severe weather as defined in the NUMARC station blackout initiatives, this includes action based on activation of the severe weather mitigation procedures for flooding (e.g., precautionary shutdowns, diesel testing, staff call-outs, etc.).

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

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

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

increase.

CR-3 Matrix Reference Number: 2.3 NEl 97-03

Reference:

11U1 l

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Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT i

Flood MODES: ALL Classification:

Alert Initiatine Conditiont i Flood being experienced or projected Emereency Action Level:

(1 and 2)

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

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

This EAL covers flooding due to natural phenomena. 1 This E.AL is intended to address flooding that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report is not interpreted as mandating a lengthy damage assessment prior to classification and no attempt is made to assess the actual magnitude of the damage.

If the ability to achieve and maintain safe shutdown exists, item 2 of the EAL is Det met.

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

Reference:

IIAl i

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

Unusual Event Initiatine Condition:

llurricane Warning Emereeney Action Level:

The plant is within a Hurricane Warning area Basis:

This EAL can be a precursor of more serious events. In particular, since CR-3 may be subject to severe weather as defined in the NUM ARC station blackout initiatives.

This should include a notification from the National llurricane Center via the State Warning Point over ESATCOM.

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

Reference:

11U1 f

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Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Tcrnado I

MODES: ALL '

Classification:

Unusual Event i

Initiating Condition:

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Tornado within the Protected Area Emernency Action Level:

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

This EAL is based on the assumption a tornado strikes (touches down) within the protected area boundary and may have potentially of 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.

Waterspouts remaining intact after coming onshore / land are classified as tornadoes.

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

Reference:

11U1 a

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! Emergency Action Level Basis Document l

NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT i

l Tcrnado or High Winds MODES: ALL l

! Classification:

Alert Initiatine Condition:

Tornado m High Winds or windborne object (s) strik., structures and results in significant visible damage l

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Emernency Action Level:

(1 and 2)

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

. Auxiliary Building

. BWST

= Control Complex

• EFT-2 Building

• Diesel Generator Building

• Intermediate Building

• Reactor Building AND

2. (a or b)

a. Confirmed report of significant visible damage to buildings listed above OE

b. Indications show degradeo SAFE SHUTDOWN EQUIPMENT performance due to Tornado or high winds BR1bi This EAL addresses events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report is not interpreted as mandating a lengthy damage assessment before classification and no attempt is made to assess the actual magnitude of the damage.

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

Waterspouts remaining intact after coming onshore / land are classified as tornadoes.

If the ability to achieve and maintain safe shutdown exists, item 2b of the EAL is nel met.

l I CR-3 Matrix Reference Number: 2.7 j NEI 97-03

Reference:

IIAl l

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

Classification:

Unusual Event l

Initiatine Condition:

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

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

• Auxiliary Building

• BWST

• Control Complex

• EFT-2 Building

• Diesel Generator Building

• Intermediate Building

• Reactor Building Basis:

This EAL is intended to address such items as a plane, helicopter or vehicle crash, potentially damaging plant

structures containing functions and systems required for safe shutdown of the plant. Automobiles, trucks, and forklifts

l. are vehicles within the context of this EAL. The intent is to address any vehicle that can cause significant damage to plant structures.

l CR-3 Matrix Reference Number: 2.8 NEl 97-03

Reference:

11U1 i

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l Emergency Action Level Basis Document t

! NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Aircrft/ Vehicle Crash MODES: ALL

! Classification:

Alert I initiatine Condition:

Aircraft nt Vehicle strikes vital structures and results in significant visible damage Emernency Action Level:

(1 and 2)

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

• Auxiliary Building.

• BWST,

• Control Complex,

• EFT-2 Building,

• Diesel Generator Building,

• Intermediate Building, '

• Reactor Building AND

2. Indications show degraded SAFE SHUTDOWN EQUIP INT performance due to Aircraft nt Vehicle Crash Hiisist This EAL is intended to address such items as a plane or helicopter or vehicle crash damaging plant structures containing functions and systems required for safe shutdown of the plant. Automobiles, trucks, and forklifts are also vehicles within the context of this EAL. Significant damage refers to structural damage that is beyond cosmetic damage.

. This EAL is intended to address events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report is not interpreted as mandating a lengthy damage assessment prior to classification and no attempt is made to asses the actual magritude of the damage. I If the ability to achieve and maintain safe shutdown exists, item 2 of the EAL is nnt met.

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

Reference:

IIAI l'

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Emergency Action Level Basis Document

> NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT l

Tcxic or Flammable Gas

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MODES: ALL Classification:

Unusual Event 1

Initiatine Condition:

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

(1 or 2)

1. Report or detection of toxic or flammable gases within the SITE BOUNDARY that could enter the Protected  !

Area in amounts that can affect normal operation of the plant na

2. Confirmed notification by FPC, County, or State personnel of a potential evacuation of the site based on an offsite event Basis:

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

Gases within the Site Boundary that are below life-threatening or flammable concentrations are not applicable to this initiating Condition. Concentrations at these levels would not affect plant personnel or the safe operation of the plant.

Gases at the site boundary that are above life-threatening or flammable concentrations, yet have not exceeded those concentrations within a facility structure, would satisfy the first EAL and wruld require the declaration of an Unusual Event.

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

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

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

Reference:

IIU3 1

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L Emergency Action Level Basis Document l NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Tcxic or Flammable Gas MODES: ALL Classification:

Alert Initiatine Condition:

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

1 Flammable Gas levels >25% Lower Explosive Limits or Toxic gas levels > IDLII levels within the Protected Area l such that plant personnel are unable to perform actions necessary to maintain safe operations or establish and maintain cold shutdown using personal protective equipment i

Basis:

This initiating Condition is based on gases that have entered a plant structure affecting the safe operation of the plant.

This Initiating Condition applies to buildings and areas contiguous to plant vital areas or other significant buildings or ,

areas.

Concentrations at these amounts will restrict or prevent normal actions from being taken to operate the plant. This

! EAL is not intended to include precautionary general evacuation of personnel, if personnel can safely enter areas necessary to establish and maintain safe shutdown using protective equipment, this j Initiating Condition /EAL is not met.

1 IDLH - Immediately Dangerous to Life or Health l

l CR-3 Matrix Reference Number: 2.11 l- NEI 97-03

Reference:

IIA 3 l

l I

1 I I i

1 I

24 i

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

Unusual Event Initiatine Condition:

UNPLANNED EXPLOSION within the Protected Area Emercency Action Level:

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

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

The occurrence of the explosion with reports of evidence of damage (e.g., deformation, scorching) is sufficient for declaration.

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

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

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

Reference:

HUI i

i 25

Emergency Action Level Basis Document l

l NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT 1 Explosions / Pressurized System Failure MODES: ALL Classification:

j Alert '

Initiatinn Condition: q EXPLOSION within the plant affecting the operability of plant safety systems required to establish or maintain safe )

shutdown l l

Emernency Action Level:

l. )

(1 and 2) {

i

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

• Auxiliary Building, e BWST,

. Control Complex,

. EFT-2 Building, I

. Diesel Generator Building, e Intermediate Building, e Reactor Building AND

2. (a or b)

a. Report by plant personnel of EXPLOSION or catastrophic failure of pressurized equipment causing l

, VISIBLE DAMAGE to SAFE SHUTDOWN EQUIPMENT 1

! i I

QE \

l

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

pressurized equipment failure Basis:

. This EAL is intended to address events that inay have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safe shutdown equipment. The initial report

should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this l

EAL to assess the actual magnitude of the damage. The observation of damage to a structure is sufficient to make a l declaration. I p

If the ability to achieve and maintain safe shutdown exists, item 2b of the EAL is Dat met.

CR-3 Matrix Reference Number: 2,13 NEI 97-03

Reference:

IIA 2

?.

I I

I 26 l

\ -. .________u

l Emergency Action Level Basis Document 1

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

Unusual Event initiatine Condition FIRE within the PROTECTED AREA that could affect SAFE SilUTDOWN EQUIPMENT Emereenev Action Level:

(I and 2)

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

• Auxiliary Building.

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

• Diesel Generator Building, i e Intermediate Building, e Reactor Building AND

2. FIRE not extinguished within 15 minutes from Control Room notification er receipt of a verified Control Room fire alarm Basisi s

' This EAL is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. This excludes such items as fires within administration buildings, waste-basket fires, and other small fires of no safety consequence. This initiating Condition applies to buildings and areas contiguous to plant vital areas or other significant buildings or areas.

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

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

The 15 minute time period begins with the time when a credible notification that a fire is occurring or a verified fire  !

detection system alarm is received. The intent of the 15 minute duration is to discriminate against small fires that are readily extinguished.

CR-3 Matrix Reference Number: 2.14 l

l NEl 97-03

Reference:

IlU2 1

27

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

Alert Initiatine Condition:

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

(1 or 2)

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

2. Indications show degraded SAFE SHUTDOWN EQUIPMENT performance due to the FIRE D3Jilsi /f

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

If the ability to achieve and maintain shutdown exists, the Initiating Condition and EAL is net met.

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

Reference:

IIA 2 4

1 28

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

Alert Initiatine Condition:

Evacuation of Control Room is Required Emereenev Action Level:

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

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

Declaration of an Alert is appropriate only after the transfer to remote shutdown is completed.

CR-3 Matrix Reference Number: 2.16 NEI 97-03 Referei.te: IIAS l

l 29 I

Emergency Action Level Basis Document.

NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Control Romu Evacuation MODES: ALL Classification:

Site Area Emergency

, Initiatine Condition:

I Evacuation of Control Room is initiated and Plant Control cannot be established Emereency Action Level:

(1 and 2)

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

2. Control of the necessary equipment n01 established per AP-990 within 15 minutes huh 1 The 15 minutes begins at the ficst attempt ta turn the transfer switch to transfer control from the Main Control Room to the Remote Shutdown Panel.

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

The determination of whether or not control is established at the Remote Shutdown Panel i'. based upon the judgment of the Nuclear Shift Manager. The Nuclear Sh;ft Manager is expected to make a reasonable, informed judgment ,

within nfteen minutes of the transfer from t'. ; Control Room that the operating crew has control of the plant from the '

Remote Shutdown Panel.

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

Reference:

IIS2 I

l l

30

Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT l

l Security Event j MODES: ALL Classification:

Unusual Event Initiatine Conditions Confirmed Security event within the PROTECTED AREA indicating a potential degradation in the level of safety of the plant Emereency Action Level:

(1 or 2)

1. Discovery of a BOMB within the PROTECTED AREA DE

2. (a or b or c)

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

a. Occurrence of SABOTAGE / INTRUSION M

b. IlOSTAGE/ EXTORTION situation threatening to interrupt plant operations M

c. A violent CIVIL DISTURBANCE ongoing outside the PROTECTED AREA but within the Owner Controlled Area (SITE BOUNDARY)

Basis A bomb found inside the Protected Area indicates a potential degradation of the safety of the plant. The location of the bomb device is in an area that, if exploded, would not affect systems needed for safe operation of the plant.

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

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

Reference:

11U4 1

31 )

i e-_-_____-__. . _ _ . 1

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

i Alert 1

l Initiatine Condition:

Confirmed Security Event indicating an actual et potential substantial degradation in the level of safety of the plant Emereency Action Level:

(1 or 2)

I

1. Discovery of BOMB within the following areas:

• Auxiliary Building, 1

• BWST, e Control Complex,

• EFT-2 Building, ,

e Diesel Generator Building, Intermediate Building,

• Reactor Building ,

OR I

2. INTRUDER (S) penetrates the PROTECTED AREA I

Basis: l This class of security events represents an escalated threat to plant safety above that contained in the Unusual Event.

For the purposes of this initiating Condition, a civil disturbance which penetrates the protected area boundary can be considered an intrusion.

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

Reference:

IIA 4 L

I 32

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

Site Area Emergency Initiatine Condition:

Confirmed Security Event has at is occurring resulting in actual nt likely failures of plant functions needed to protect the public Emernency Action Level:

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

• Auxiliary Building,

• BWST,

= Control Complex (excluding the Control Room and Remote Shutdown Room),

• EFT-2 Building,

= Diesel Generator Building, e Intermediate Building, e Reactor Building Basis:

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

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

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

Reference:

11 S 1 l

l 33

Emergency Action Level Basis Document l NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Security Event l

MODES: ALL Qassification:

General Emergency Initiatine Condition:

Security Event resulting in loss of physical control of the facility Emereency Action Level:

INTRUDER (S) has taken control of the Control Room, or Remote Shutdown Room or plant equipment such that plant personnel are unable to operate equipment required to establish and maintain safe shutdown conditions Basisi This initiating Condition encompasses conditions under which a hostile force has taken physical control of a vital area required to reach and maintain safe shutdown.

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

Reference:

IIG1 1

34

Emergency Action Level Basis Document NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT i Internal Flooding MODES: ALL classification:

Unusual Event Initiatinn Condition:

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

(1 and 2) ,

I

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

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

Basis: ]

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

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

Reference:

11U1 l

I e

l l

t 35

I Emergency Action Level Basis Document

]

NATURAL / MAN-MADE HAZARI>S AND EC JUDGMENT Internal Flooding MODES: ALL Classification:

Alert l

{

l Initiatine Condition: j Internal flooding affecting SAFE SilUTDOWN EQUIPMENT

]

Emernency Action Level:

(1 and 2)

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

2. (a or b)

a. Indications show degraded SAFE SIIUTDOWN EQUIPMENT due to the flooding DR

h. Electrical hazards prevent plant personnel normal access to areas of plant containing SAFE SilUTDOWN EQUIPMENT Bastu I This addresses the possible effects of flooding from system malfunctions, component failures, or repair activity mishaps that has either threatened the safe operation of the plant or resulted in a complete loss of function required for cold shutdown. )

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

If the ability to achieve and maintain safe shutdown exists, item 2 of the EAL is D01 met.

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

Reference:

IIAI ,

l i

36 l

l Emergency Action Level Basis Document l

l NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT Emergency Coordinator Judgment MODES: ALL Classification:

Unusual Event initiatine Conditions:

Other conditions existing, which in the judgment of the Emergency Coordinator, warrant declaration of an Unusual Event Emereency Action Level:

Other conditions exist which indicate a potential degradation in the level of safety of the plant Basis:

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

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

CR-3 Matrix Reference Number: 2.24 l

NEl 97-03

Reference:

IIUS i l

l f

37 l l

_ _ _ _ . _ _ _ - - - - _ - - - - _ _ _ _ _ _ _ 1

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

Alert initiatine Conditions:

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

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

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

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

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

CR-3 Matrix Reference Number: 2.25 "

NEl-97-03

Reference:

IIA 6 1

(

l f

l l .

1 38 i l

E

Emergency Action Level Basis Document l

l l NATURAL / MAN-MADE HAZARDS AND EC JUDGMENT  !

l Emergency Coordinator Judgment MODES: ALL Classification:

Site Area Emergency Initiatine Conditions:

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

Other conditions exist which indicate actual or likely major failures of plant functions needed for the protection of the public i 34 SIS This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the emergency class description for Site Area Emergency.

A release is not expected to result in exposure levels exceeding EPA plume Protective Action Guideline Exposure Levels beyond the Site Boundary (1 Rem TEDE or 5 Rem Thyroid CDE).

The site boundary is defined as 0.83 miles radially from the center of the Reactor Building.

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

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

Reference:

ilS3 39

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

General Emergency l

Initiatine Condition: I Other conditions existing, which in the judgment of the Emergency Coordinator, warrant declaration of a General Emergency Emergeucy3ction Level: j (1 or 2) {

Other conditions exist which indicate:

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

2. The potential for uncontrolled radionuclides releases that can be expected to exceed EPA Protective Action !

Guidelines Plume Exposure Levels beyond the SITE BOUNDARY Basis: l This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under  !

the General Emergency class. ]

)

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

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

Reference:

HG2 l

l l

i l

I 40 1

(

w____-_______-____

Emergency Action Level Basis Document SYSTEM MALFUNCTION Loss of Communication MODES: ALL Classificathm:

Unusual Event Initiatine Condition:

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

(1 or 2)

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

• FPC Internal Telephone System

• PAX

• Portable UHF Radios DE

2. Loss of M the following offsite communications capability:

• FPC Telephone System

• State Hot Ring Down (SHRD)

• State-Wide Emergency Satellite Communication (ESATCOM) System

• ALL FTS 2000 NRC Phones (Emergency Notification System (ENS), Health Physics Network (HPN),

Counterpart Links) e Control Room Cellular Phone Bas.ls The purpose of this initiating Condition and its associated EALs is to recognize a loss of communications capability either defeating the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate problems with offsite authorities. The loss of offsite communications ability is expected to be significantly more comprehensive than the condition addressed by 10 CFR 50.72.

The onsite or offsite communications loss must encompass the loss of all means of routine direct communications with intended parties. This includes the ENS, Commercial lines, Microwave, and FAX transmissions. This EAL is used only when extraordinary means are used to make communications possible (relaying of information from radio transmissions, individuals being sent to offsite locations, etc.). Credit is not taken for portable satellite phones due to the ti.me it takes to establish a communications link. Once a link is established with a portable satellite phone, the event may be terminated.

CR-3 Matrix Reference Number: 3.1

.NEI 97-03

Reference:

SU6 l

I f

l 41 i i I L-_____________________________-- - - - - - - - - - -  !

Emergency Action Level Basis Document SYSTEM MALFUNCTION Failure of Reactor Protection MODES: 1,2,3 Classification:

Alert Initiatine Condition:

Failure of Reactor Protection System (RPS) instrumentation to complete or initiate an automatic reactor trip once an RPS setpoint has been exceeded and manual trip was successful i

?

Emergency Action Level:

(I and 2)

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

AND

2. Manual Reactor trip from Control Room was successful and reactor power is < 5% and decreasing Halbl This condition indicates failure of the Reactor Protection System to trip the reactor. This condition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient and thus the plant safety has been compromised, and design limits of the fuel may have been exceeded.

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

drive rods or other actions taken or occurring outside the control room does not constitute a reactor trip because it  !

does not meet the rapid insertion criterion.

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

CR-3 Matrix Reference Number: 3.2 NEI 9743

Reference:

SA2 l

1 1 42

Emergency Action Level Basis Document

! SYSTEM MALFUNCTION

! Failure of Reactor Protection

! MODES: 1,2 Classification:

Site Area Emergency Initiatine Condition:

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

(I and 2)

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

2. Manual Reactor trip from Control Room was Dat successful in reducing reactor power to < 5% and decreasing liasis:

Automatic and manual trips are not considered successful if action away from the Control Room was required to trip the reactor Manual trip is successful if the trip push button or de-energizing control rod power in the Control Room results in reactor power <5% and decreasing.

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

The trip is considered unsuccessful when enough control rods have not inserted to cause the reactor power to fall below that percent power associated with the ability of the safety systems to remove heat and continue to decrease.

Subsequent actions necessary for the reactor to be prepared for a cooldown and depressurization are not to be considered.

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

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

Reference:

SS2 i

1 13

1 l Emergency Action Level Basis Document I l SYSTEM MALFUNCTION

- Failure of Reactor Protection

! MODES: 1,2 Classification:

General Emergency Initiatine Condition:

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

(1 and 2)

1. (a and b)

I

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

b. Manual Reactor trip from Control Room was But successful in reducing reactor power to < 5% and decreasing j

2. Average of the five highest core exit thermocouple temperatures > 700 F l

BallSi 700 F is a good indicator of an extreme challenge to the ability to cool the core and is consistent with the " potential loss" factor in the Fission Product Barrier Matrix.

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

Another consideration is the inability to initially remove heat during the early stages cf this sequence. 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.

In the event either of these challenges exist at a time the reactor has not been brought below the power associated with the safety system design 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 j J

declaration to permit maimum offsite intervention time.

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

Reference:

SG2 I

44

l Emergency Action Level Basis Document SYSTEM MALFUNCTION i

l Improved Technical Specification l

l MODES: 1.,2,3,4 Class 8/ication:

l 'inusual Event initiatine Condition:

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

(1 and 2)

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

2. The plant is nat brought to the required operating mode within the time prescribed by the LCO required action Basis:

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

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

CR-3 Matrix Reference Number: 3.S l NEI 97-03

Reference:

SU2 l

i I

i F

45 t - - - - - - - - _ _ _

L Emergency Action Level Basis Document i

L SYSTEM MALFUNCTION l

Loss of Indications

! hjODES: 1,2,3,4 f_ classification:

Unusual Event Initiatine Condition:

UNPLANNED loss of most m all Control Room Annunciators for 15 minutes or longer Opernency Action Level:

(I and 2 and 3)

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

2. Increased surveillance beyond shift compliment is required to safely operate the plant AND

3. Plant Computer m SPDS is operable and capable of displaying requested data )

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

Annunciator panels A-G contain the major control systems (RPS, ES, ICS, etc.). Increased surveillance requirement is based upon the judgment that additional operating personnel beyond the normal shift compliment is required to provide increased monitoring of system operation to safely operate the unit.

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

l 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.

i CR-3 Matrix Reference Number: 3.6 l

NEl 97-03

Reference:

SU3 i

l 46

Emergency Action Level Basis Document I 1

1 SYSTEM MALFUNCTION Loss of Indications MODES: 1,2,3,4 Classification:

Alert jnitiatine Condition: ,

UNPLANNED loss of most m all Control Room Annunciators for 15 minutes or longer with either a SIGNIFICANT j TRANSIENT in progresa m Plant Computer and SPDS unavailable Emernency Action Level: I (1 and 2)

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

2. (a or b)

a. SIGNIFICANT TRANSIENT in progress DR

b. Loss of Plant Computer and SPDS Basis:

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

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

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

' Annunciator.

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

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

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

Reference:

SA4 I

47 a_____-_-__. _ _ _ _ _ _ _ _ . _

Emergency Action Level Basis Document SYSTEM MALFUNCTION Loss of Indications MODES: 1,2,3,4 l

i Qassificatio_n; Site Area Emergency Lnitiatine Condition:

Inability to monitor a SIGNIFICANT TRANSIENT in progress Emereenev Action Level:

_ (1 and 2 and 3 and 4)

1. Loss of Annunciator panels A-G and Annunciator printer AND

2. SIGNIFICANT TRANSIENT in progress AND

3. Loss of Plant Computer and SPDS 1

i AND l i l

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

'.iberiticality Core Cooling Containment Conditions j RCS Inventory l Basis: l This initiating Condition and its associated EAL are intended to recognize the inability of the control room staff to monitor the plant response to a transient.

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

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

l Indications needed to monitor safety functions necessary for protection of the public must include control room

! indicatiom, computer generated indications and dedicated annunciation capability. The specific indications should be l those used to determine such functions as the ability to shut down the reactor, maintain the core cooled and in a l coolable geometry, to remove heat from the core, to maintain the reactor coolant system intact, and to maintain containment intact.

Flanned and unplanned actions are not differentiated in this EAL since the loss of instrumentation of this magnitude is of such significance during a transient, that the cause of tne loss does not make the condition more tolerable.

CR-3 Mat. 2 Reference Number

3.8 l NEl 97-03

Reference:

SS6

(

48

Emergency Action Level Basis Document SYSTEM MALFUNCTION Fuel Clad Degradation MODES: ALL Classification:

Unusual Event Initiatine Condition:

RCS specific activity exceeds LCO Emereency Action Level:

Radiochemistry analysis indicates:

(a or b)

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

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

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

RCS purification will provide for lodine and crud cleanup in the reactor coolant system and reduce activity to <

l.0 'pCilgm within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

The EAL values are based on Improved Technical Specification Limits.

)

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

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

Reference:

SU4 l

l i

l

! i l )

1  :

49 l-L___.______._

Emergency Action Level Basit Document SYSTEM MALFUNCTION Turbine Failure MODES: 1,2,3 l

Classification: I Unusual Event 1

Initiatine Condition:

Turbine failure results in casing penetration Emernency Action Level:

Report by plant personnel of turbine failure causing penetration of the turbine casing nr damage to main generator seals 1

Basis:

This EAL is intend.J :o address main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Of major concern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen) to the plant environs. Actual fires and flammable gas build up are appropriately classified via Fire and Flammable Gas EALs. This EAL is consistent with the definition of an )

Unusual Event while maintaining the anticipatory nature desired and recognizing the risk to non-safety related I equipment. I Escalation of the emergency classification is based on the potential damage done by missiles generated by the failure.

It is not the intent of this initiating Condition to declare an event based on damage discovered in a maintenance evolution. Generator seal damage observed after generator purge does not meet the intent of this EAL because it did not impact normal opaation of the plant.

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

Reference:

11U1 l

l 50

Emergency Action Level Basis Document SYSTEM MALFUNCTION

! 1 i I

! Turbine Failure MODES: 1,2,3 Classification: 1 Alert l Initiatine Condition:

Turbine failure generated projectiles cause significant visible damage to SAFE S11UTDOWN EQUIPMENT l

Emernency Action Level:

(1 or 2)

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

of the following structures:

• Auxiliary Building,

• BWST, e Control Complex, e Diesel Generator Building, l

• EFT-2 Building,

• Intermediate Building, e Reactor Building

OR f

2. Indications show degraded SAFE SHUTDOWN EQUIPMENT performance due to turbine generated l projectiles j l

Basis: j l This EAL is intended to address the threat to safe shutdown eg'iipment imposed by missiles generated by main turbine l l rotating component failures. The list of areas includes all areas umtaining safe shutdown equipment, their controls, i and their power supplies. This EAL is, therefore, consistent with :he 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. l This EAL is intended to address events that may have resulted in a plant vital area being subjected to forces beyond j design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report is not interpreted as mandating a lengthy damage assessment prior to classification and no attempt is made to asses the actual magnitude of the damage. This EAL is not intended to be used for temporary loss of control room habitability where timely repairs can be affected.

If the ability to achieve and maintain safe shutdown exists, item 2 of the EAL is nnt met.

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

Reference:

IIAl l

I 51

Emergency Action Level Basis Document SYSTEM MALFUNCTION RCS Leakage MODFJJ 1,2,3,4 Classification:

Unusual Event l

Initiatine Condition:

RCS leakage i

Emergency Action Level:

(I or 2)

1. Unidentified Leakage qt Pressure Boundary Leakage 10 gpm DE l

2. Identified Leakage 25 gpm Basis:

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

l This initiating Condition is included as an Unusual Event because it may be a precursor of more serious conditions l and, as result, is considered to be a potential degradation of the level of safety of the plant. The 10 gpm value for the unidentified and pressure boundary leakage was selected as it is observable with normal control room indications.

Lesser values must generally be determined through time-consuming surveillance tests (e.g., mass balances). The

. EAL for identified leakage is set at a higher value due to the lesser significance of identified leakage in comparison to unidentified or pressure boundary leakage.

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

Reference:

SUS 4

i I

52 m_- m

Emergency Action Level Basis Document SYSTEM MALFUNCTION Loss of Function (Hot Shutdown)

MORES; 1,2,3,4 Classification:

Site Area Emergency initiatine Condition 1 Complete loss of core heat removal capability Emernency Action I,evel:

(1 and 2)

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

2. Loss of Subcooling Margin (SCM)

Basis:

This EAL addresses complete loss of functions, including loss of heat removal capability, required for hot shutdown.

Under these conditions, there is an actual major failure of a system intended for protection of the public. Thus, declaration of a Site Area Emergency is warranted. The EALs will allow for 11Pl/PORV cooling upon loss of all feedwater. Subcooling margin may be lost momentarily during this evolution but the ability to establish 11PI cooling will not have been lost.

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

Reference:

SS4 53

Emergency Action Level Basis Document SYSTEM MALFUNCTION L

! Inadvertent Criticality l MODES: 2,3,4,5,6 Gassification:

Unusual Event initiatine Condition: i Inadvertent criticality during refueling or shutdown Emergency Action Level:

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

This condition can be identified using the startup rate monitor. The term " extended" is used to allow for exclusion of cxpected short term positive startup rates from planned fuel bundle or control rod movements during core alterations.

The short term startup rates are the result of the increase in neutron population due to suberitical multiplication.

This initiating Condition /EAL is not intended to classify an early criticality during reactor startup. This type event is indicative of errors in reactivity data / calculations and/or mis-operation. The loss of the required shutdown margin can {

be quickly restored by manual actions or automatic reactor trip.

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

Reference:

SUS i

f I

54

Emergency Action Level Basis Document l 1

1 LOSS OF POWER '

Loss of AC Power MODES: ALL l Classification:

l Unusual Event l

Initiatice Condition.1 l Loss of ALL Offsite Power for 15 minutes or longer Emernency Action Level:

(1 and 2)

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

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

Basis:

Prolonged loss of AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete Luss of AC Power (Station Blackout). Fifteen minutes is used as a threshold to exclude transient or momentary power losses.

Available indicates transformers are capable of energizing required busses.

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

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

CR-3 Matrix Reference Number: 4.1 NEl 97 03

Reference:

SU1 55

Emergency Action Level Basis Document LOSS OF POWER Loss of AC Power (Power Operations)

MODES: 1,2,3,4 Classification:

Alert Initiatine Condition:

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

AC power capability to the ES 4160V busses reduced to a single power source for 15 minutes or longer such that only one of the following is available; o "A" EDG e "B" EDG o Offsite Power Transformer (OPT) o Backup ES Transformer (BEST) o Aux Transformer Basis:

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

Available indicates transformers are capable of energizing required busses.

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

Reference:

SA5

)

I l

h t

56

Emergency Action Level Basis Document LOSS OF POWER Loss of AC Power (Power Operations)

MODES: 1,2,3,4 Classification:

Site Area Emergency initiatine Condition:

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

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

Loss of all AC power compromises all plant safety systems requiring electric power including ECCS, Containment Heat Removal and the Ultimate 11 eat Sink. Prolonged loss of all AC power will cause core uncovering and may challenge containment in'.egrity. The fifteen minute time duration is to exclude transient or momentary power losses.

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

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

Reference:

SSI r

i 57 l - - - - ----- ---- a

Emergency Action Level Basis Document LOSS OF POWER l

l Loss of AC Power (Power Operations)

MODES: 1,2,3,4 Classification:

General Emergency Initiatine Condition:

Prolonged Loss of2LL Offsite and Onsite AC power i

Emereenev Action Level:

1 (1 and 2)

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

2. (a or b)

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

b. Average of five highest core exit thermocouple > 700*F RasLs1 700 F is a good indicator of an extreme challenge to the ability to cool the core and is consistent with the " potential loss" factor in the Fission Product Barrier Matrix.

l l Loss of all AC power compromises all plant safety systems requiring electric power including ECCS and the Ultimate Heat Sink. Prolonged loss of all AC power will lead to loss of fuel clad, RCS, and may challenge containment integrity. The four hours to restore AC power is based on the CR-3 station blackout coping analysis performed in conformance with 10 CFR 50.63 and Regulatory Guide 1.155, " Station Blackout." Although this Initiating Condition may be viewed as redundant to the Fission Product Barrier Matrix, its inclusion is necessary to better assure timely recognition and emergency response.

This Initiating Condition is specified to assure that in the unlikely event of a prolonged station blackout, timely recognition of the seriousness of the event occurs and that declaration of a General Emergency occurs as early as is appropriate, based on a reasonable assessment of the event trajectory.

1 The likelihood of restoring at least one emergency bus should be based on a realistic appraisal of the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions.

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

Reference:

SGI 58

Emergency Action Level Basis Document LOSS OF POWER

( Loss of AC Power i

(Shutdown conditions)

MODES: 5, 6, No Mode (defueled)

Classification:

Alert initiatine Condition:

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

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

Loss of all AC power compromises all plant safety systems requiring electric power including ECCS, Containment fleat Removal and the Ultimate IIeat Sink. When in cold shutdown, refueling, or defueled mode the event can be classified as an Alert, because of the significantly reduced decay heat, lower temperature and pressure, increasing the  ;

time to restore one of the emergency busses, relative to that specified for the Site Area Emergency EAL. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

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

Reference:

SAI l

59 L_________________-_.__ _ _ - _ _ . - _

l Emergency Action Level Basis Document l

l LOSS OF POWER l

Loss of DC Power 1 (Pawer Operatioas)  !

l l

MODES: I,2,3,4 Classification:

I Site Area Emergency i I

Initiatine Condition:

Loss of all Vital DC Power for 15 minutes or longer

! Emereenev Action Level:

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

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

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

Reference:

SS3 l

60 L - - .- _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Emergency Action Level Basis Document FISSION PRODUCT BARRIER MATRIX BASIS t

i

, FUEL CLAD LOSS FACTORS l

1. CORE CONDITIONS IN REGION TilREE OR FOUR OFINADEQUATE CORE COOLING l CURVES (EOP-07) l The initial core damage assessment curve is used to relate the observable parameters of incore temperature and RCS pressure to clad temperature. In region three or four, elevated

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

! failure of the clad will occur if not halted.

i l

Eta.

..+.. ..+.. ..+..

.. ..+.. ..+..

..+..

acs actr#v=ca4**

3

..?!?S* ' 8 R. , .

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,,, ..J.. .

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..+.. ..!...

3- .+. p;;;;;;. l

,,, . [ .' ..+.. ..+.. ..+.. ..-..

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2. RCS ACTIVITY > 300 pCilgm 1*

This amount of coolant activity is well above that expected for iodine spikes and corresponds to about 2% to 5% fuel clad damage. This amount of clad damage indicates significant clad heating and thus the Fuel Clad Barrier is considered lost.

3. RM-G29 OR 30 > 100 Rnr Monitor readings have increased and are sustained, not spikes. Readings of > 100 R/hr on these monitors indicate activity in the Reactor Building above what would be expected for normal reactor coolant.

.t. EC DEEMS FUEL CLAD BARRIER IS LOST Based on Emergency Coordinator judgment.

61

l Emergency Action Level Basis Document l

l FISSION PRODUCT BARRIER BASIS FUEL CLAD POTENTIAL LOSS FACTORS l

1. RCS CONDITIONS WARRANT ENTRY INTO E0P-07 EOP-07 is the " Inadequate Core Coohng" procedure which indicates that there are superheated conditions in the core which may lead to clad degradation.

2. CORE EXIT 1HERSIOCOUPLES > 700*F 700 F is a good indicator of an extreme challenge to the ability to cool the core.

Temperatures are determined using guidance in EOP-07.

3. EC DEESIS FUEL CLAD BARRIER IN JEOPARDY Based on Emergency Coordinator judgment.

i 62

Emcrgency Action Level Basis Document

FISSION PRODUCT BARRIER BASIS RCS LOSS FACTOR

1. RCS LEAK RESULTING IN LOSS OF ADEQUATE SUBCOOLING AfARGIN (SCA1)

A loss of adequate SCM resulting from RCS leakage would indicate that the rate of leakage from the RCS is exceeding the rate of addition from the injection system.

Therefore, the RCS boundary should be considered lost any time adequate SCM is lost due to leakage.

2. OTSG TUBE LEAK RESULTING IN LOSS OF ADEQUATE SUBC00 LING A1ARGIN (SCA1)

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

3. EC DEEAIS RCS BARRIER IS LOST Based on Emergency Coordinator judgment.

NOTE: Containment Radiation Monitoring is not used as an RCS lots factor due to the potential for inconsistent readings due to uneven mixing that will lead to erroneous assumptions. An elevated reading on these monitors is indicative of an RCS leak but it would be difficult to differentiate between a leak that was less than a leak requiring one or more injection valves (RCS Potential Loss) and less than a leak resulting in a loss of subcooling margin. It would take an

extended period of time for the activity in containment to achieve an even mix that would provide consistent rad monitor readings.

l l

l i 1

63 L_________.________

Emergency Action Level Basis Document FISSION PRODUCT BARRIER BASIS RCS POTENTIAL LOSS FACTORS L. RCS LEAK REQUIRING ONE OR RIORE INJECTION VALVES By procedure, the HPI injection valves will be used to increase RCS inventory if pressurizer level cannot be maintained greater than 50 inches with letdown isolated.

Thus, the use of one or capability and therefore a potential less of the RCS barrier.

2. OTSG TUBE LEAK REQUIRING ONE OR A10RE INJECTION VALVES By procedure (EOP-06), the HPl injection valves will be used to increase RCS inventory if pressurizer level cannot be maintained at =220 inches during a tube leak event. Thus, the use of one or more injection valves would indicate leakage in excess of the normal makeup capability and therefore a potential loss of the RCS barrier.

3. RCS LEAK RESULTS IN ES ACTUATION ON LOlV RCS PRESSURE Should the injection system fail or the operator fail to open the injection valves upon a failure of the Makeup system to maintain RCS inventory, RCS pressure will decrease to the ES actuation setpoint. This potential loss factor in addition to number one (above) will ensure that the kCS barrier will be considered potentially lost for any inability of the makeup system to maintain adequate inventory during a loss of coolant event.

.t. OTSG TUBE LEAK RESULTS IN ES ACTUATION ON LOW RCS PRESSURE Should the injection system fail or the operator fail to open the injection valves upon a failure of the Makeup system to maintain RCS inventory, RCS pressure will decrease to the ES actuation setpoint. This potential loss factor in addition to number one (above) will ensure that the RCS barrier will be considered potentially lost for any inability of the Makeup system to maintain adequate inventory during an OTSG tube leak event.

5. EC DEEhtS RCS BARRIER IN JEOPARDY Based on Emergency Coordinator judgment.

l l

l u________ _ _ _ _ _ _ _ - . _ __ _ _ _ _ . - - -

I

l Emergency Action Level Basis Document FISSION PRODUCT BARRIER BASIS l

CONTAINMENT LOSS FACTORS l

l i

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

2. AN OTSG llAS TUBE LEAK AND UNISOLABLE STEAni LEAK OUTSIDE RB PER E0P-06, "STEAh! GENERATOR TUBE RUPTURE" An unisolable steam leak outside the RB on an OTSG with a tube leak would provide a direct leakage path to the environment from the RCS.

3. CONTAINhfENTISOLATION IS INContPLETE AND RELEASE PATil TO Tile ENVIRONhiENT EXISTS This factor should be used any time an incomplete RB isolation results in a direct path from the RB atmosphere to the environment. The conditions expected for this EAL would be a known path or a visual indication of the failure or path. Confirmation may be from elevated radiation readings in areas adjacent to the RB.

4. EC DEEniS CONTAINhfENT BARRIER IS LOST l Based on Emergency Coordinator judgment.

I l

l l

i 65

____________-_J

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

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

2. RB llYDROGEN CONCENTRATION >4%

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

3. RB PRESSURE > 30 psig WITil NO BUILDING SPRAY A VAILABLE The RB spray actuation setpoint is 30 psig. With RB pressure above this value and no spray available, the potential exists to exceed the RB design values.  !

4. UNEXPLAINED VALID RADIATION A10NITOR INCREASE IN AREAS ADJACENT TO RB WITil LOCA l

Unexplained radiation readings in areas adjacent to the RB during a LOCA may indicate a potential unknown release path and therefore a potential loss of containment.

5. RafG-29 OR 30 READINGS >25,000 R/hr This monitor reading is indicative of severe core damage conditions and is consistent with the monitor indication listed on the Protective Action Recommendations Table for

" core damage indications." Monitor readings have increased and are sustained, not spikes. Regardless of whether containment is challenged, this amount of activity in containment, if released, could have such severe consequences that it is prudent to treat i this as a potential loss of containment, such that a General Emergency declaration is warranted.

6. EC DEEnfS CONTAINhlENT BARRIER IN JEOPARDY Based on Emergency Coordinator judgment.

l 4

I l

1 66 i N

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

BOMB: An explosive device (See EXPLOSION)

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

or activities at the site. A civil disturbance is considered violent when force has been used in an j attempt to injure site personnel or damage plant property. 1 EXPLOSION

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

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

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated e:ectrical equipment do not constitute tires. Observation of flame is preferred but is NOT I

required if large quantities of smoke and heat are observed.

l GENERAL EMERGENCY: Events are in process or have occurred which involve actual or I imminent substantial core degradation or melting with potential loss of containment integrity. Releases l

can be reasonably be expected to exceed EPA Protective Action Guidelines exposure levels at the SITE BOUNDARY.

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

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

authorization.

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

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

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

67

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

(1) Automatic turbine trip at > 25% reactor thermal power (2) Electrical load rejection > 25% full electrical load (3) Plant runback (4) Reactor trip l (5) Safety injection system actuation l (6) > 10% thermal power oscillations

, (7) Loss of decay heat removal in Modes 5 or 6

SITE AREA EMERGENCY

Events are in process or have occurred which involve actual or likely l failures of plant functions needed for the protection of the public. Any releases are p;.g expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels at the SITE BOUNDARY.

l SITE BOUNDARY: That area, including the PROTECTED AREA, that extends 4400 ft. or 0.83 j miles in a circle around the Reactor Building. Also referred to as the Owner Controlled Area. 1 UNPLANNED: An event or action is UNPLANNED if it is not the expected result of normal operations, testing, or maintenance. Events that result in corrective or mitigative actions being taken in accordance with abnormal or emergency procedures are UNPLANNED.

i NOTE - With specific regard to radioactive releases, a release of radioactivity is

! UNPLANNED if the release is not authorized by a Release Permit or exceeds the l conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, l etc.) on the applicable permit.

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

l VALID: An indication or report or condition is considered VALID when it is conclusively verified by l (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment (e.g., within 15 minutes).

l VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analyses. Damage is sufficient to cause concern regarding the continued  !

operability or reliability of affected safety structure, system, or component. Example damage includes: l deformation due to heat or impact, denting, penetration, rupture, cracking, paint blistering. Surface

, blemishing (e.g., paint chipping, scratches) should not be included.

l 68

i 1

l FLORIDA POWER CORPORATION I

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 i

ATTACHMENT C LIST OF COMMITMENTS i

c

)

l U.S. Nuclear Regulatory Commission Attachment C 3F0798-20 Page1 ofI ATTACIIMENT C l

l LIST OF COMMITMENTS The following table identifies those actions committed to by Florida Power Corporation in this document. Any other actions discussed in the submittal represent intended or planned actions ,

by Florida Power Corporation. They are described to the NRC for the NRC's information j and are not regulatory commitments. Please notify the Manager, Nuclear Licensing, of any l questions regarding this document or any associated regulatory commitments.

I 1

Commitment Due Date i

Upon finalization of the EAL changes, FPC will obtain Prior to implementation j formal concurrence of the CR-3 site emergency l classification system from the State of Florida and affected l counties.  ;

! I l

1 I

1 m_.._____ __ _ _ _ _ . . . _ _ . _ _ _ _ . . _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _