Text

Revision 19 to EAL Table of Contents, Rev. 8 to EAL EBD-A, Rev. 5 to EAL EBD-F, Rev. 8 to EAL EBD-H, and Rev. 6 to EAL EBD-S
	ML040550092
Person / Time
Site:	Duane Arnold
Issue date:	02/12/2004
From:	Peifer M; Nuclear Management Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NG-04-0093, TAM-116, TAM-117, TAM-118 EAL EBD-A, Rev 8, EAL EBD-F, Rev 5, EAL EBD-H, Rev 8, EAL EBD-S, Rev 6
	Download: ML040550092 (282)
	v • d • e

NMCA Committed to Nuclear Exellence Duane Arnold Energy Center Operated by Nuclear Management Company, LLC February 12, 2004 NG-04-0093 10 CFR 50.54 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station 0-P1-17 Washington, DC 20555-0001 DUANE ARNOLD ENERGY CENTER DOCKET 50-331 LICENSE No. DPR-49 DUANE ARNOLD ENERGY CENTER EMERGENCY PLANNING DEPARTMENT PROCEDURE TRANSMITTAL ACKNOWLEDGEMENT MEMOs TAM-1 16,117 and 118 Enclosed is the Duane Arnold Energy Center EMERGENCY PLANNING DEPARTMENT PROCEDURE TRANSMITTAL ACKNOWLEDGEMENT MEMOs TAM-116, 117 and 118 which contain revisions to various Emergency Planning Department documents. These revisions have been reviewed pursuant to 10 CFR 50.54 (q) and it has been determined they do not decrease the effectiveness of the approved emergency plan.

This letter makes no new commitments or changes to any existing commitments.

Sincerely, Mark A. Peifer Site Vice President, Duane Arnold Energy Center

Enclosures:

DAEC EMERGENCY PLANNING DEPARTMENT PROCEDURE TRANSMITTAL ACKNOWLEDGEMENT MEMOs TAM-1 16,117 and 118 CC Regional Administrator, USNRC, Region III (2 copies)

Project Manager NRC Resident Inspector 3277 DAEC Road

Palo, Iowa 52324-9785

- AcWS Telephone: 319.851.7611

NI\MC Committed to Nuclear Excellenf I

DAEC EMERGENCY PLANNING DEPARTMENT PROCEDURE TRANSMITTAL ACKNOWLEDGEMENT MEMO (TAM-1 16)

To: NRC-NRR Document Control Desk US NRC Washington DC 20555 Re: Entire EAL Basis Document (Table of Contents Rev) (Copy 91)

PSM

Title:

n/a Distribution Date: 02 /04 /2004 Effective Date of Change: 02/05/2004 Return by: 02 / 19 / 2004 Please perform the following to your assigned manual. If you have any questions regarding this TAM please contact Don A. Johnson at 319-851-7872.

REMOVE INSERT EAL Table of Contents Revision Rev. 18 Rev. 19 EAL EBD-A (PWR: 24090) Rev. 7 Rev. 8 EAL EBD-F (PWR: 24096) Rev. 4 Rev. 5 EAL EBD-H (PWR: 24092) Rev. 7 Rev. 8 EAL EBD-S (PWR: 24094) Rev. 5 Rev. 6 PERFORMED BY:

Print Name Sign Name Date Please return to: K. Dunlap PSC/Emergency Planning 3313 DAEC Rd.

Palo, IA 52324 To be completed by DAEC EP personnel only:

Date TAM returned:

EPTools updated: Page 1 of 1

N Committed to Nuclear Exceh ene Duane Arnold Energy Center Operated by Nuclear Management Company, LLC Tuesday, February 3, 2004 NRC-NRR Document Control Desk US NRC Washington, DC 20555 To: NRC-NRR Document Control Desk From: DAEC Emergency Planning Department Re: Description of changes to the following documents EAL EBD-A Abnormal Rad Levels/Radiological Effluent Category For EAL AA2: Added the IC for ARM Hi Rad Alarm back to ensure consistency with intial NRR approved EAL and NEI 99-01 rev 4.

EAL EBD-F Fission Product Barrier Degradation Category For the RPV Level column: remove refernce to RPV Levels that "cannot be restored" or have "no injection source available". These statements could cause a delay in classification and were specifically asked by NRR to not be used.

EAL EBD-H Hazards and Other Conditions Affecting Plant Safety Category For EAL HUI: Returned the IC for earthquakes back to the initial NRR approved wording to remove any potential overclassfication issues.

EAL EBD-S System Malfunction Category For EAL SU1: Removed the word 'unplanned' as this could potentially result in an underclassification issue and is inconsistent with NEI 99-01 rev 4.

For EAL SU6: Removed 'sound powered phones' as a viable routine communications method as this system is unreliable at DAEC.

For EAL SA3: Returned this EAL to the original NRR approved wording to remove any potential underclassification issues.

Please contact Paul Sullivan, Manager of Emergency Preparedness at DAEC, (319)851-7191, if you require further information.

3313 DAEC Road - Palo, lowa 52324-9785 Telephone: 319.851.7191 - Fax: 319.851.7364

EAL BASES DOCUMENT Rev. 19 INDEX Page 1 of 1 PROCEDURE TITLE REV # REV. DATE Introduction 1 2/01/2000 Definitions 3 11/21/2003 Organization of Basis Information 3 8/5/2003 EBD-A Abnormal Rad Levels/Radiological Effluent 8 2/5/2004 Category EBD-F Fission Product Barrier Degradation 4 2/5/2004 Category EBD-H Hazards and Other Conditions Affecting 8 2/5/2004 Plant Safety Category EBD-S System Malfunction Category 5 2/5/2004 EBD-E ISFSI Abnormal Events Category 0 8/5/2003

\

^l EAL BASES DOCUMENT.

.e..- I

.EBD-A Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 1 of 27 Usage Level Reference Use j lEffective Date: >2 /§ /og l TECHNICAL REVIEW Prepared by: Qo-I A.4LO Date: 1 1tz./o Reviewed by: Date: c1 ;fq' o Independent Ril wer Reviewed by: Date: I lze ((q O~perations Reviewer PROCEDURE APPROVAL I am responsible for the technical content of this procedure and for obtaining the necessary approval from the State and County Emergency Management officials prior to implementation.

Documentation of State and County Emergency Management approval is via NEP-2004-0005.

Approved by: y : _ Date: I Manager, Emergency Planning I /

EBD-A EAL BASES DOCUMENT- E -

. - - i;-io - -eva. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 2 of 27j-Table of Contents AU1 - Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment That Exceeds Two Times the Offsite Dose Assessment Manual (ODAM) and is Expected to Continue For 60 Minutes or Longer .......................................................... A-3 AU2 - Unexpected Increase in Plant Radiation ................................................. A-8 AA1 - Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times the Offsite Dose Assessment Manual (ODAM) and is Expected to Continue for 15 Minutes or Longer ......................................................... A-1 1 AA2 - Major Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel ......................................................... A -16 AA3 - Release of Radioactive Material or Increases in Radiation Levels Within the Facility That Impedes Operation of Systems Required to Maintain Safe Operations or to Establish or to Maintain Cold Shutdow n ......................................................... A -19 AS1 - Site Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mrem TEDE or 500 mrem CDE Thyroid for the Actual or Projected Duration of the Release ................. A-21 AGI - Site Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 1,000 mrem TEDE or 5,000 mrem CDE Thyroid for the Actual or Projected Duration of the Release ......................................................... A-24

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELSIRADIOLOGICAL EFFLUENT CATEGORY PAGE 3 of 27 AU1 Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment That Exceeds Two Times the Offsite Dose Assessment Manual (ODAM) Limit and is Expected to Continue For 60 Minutes or Longer EVENT TYPE: Offsite Rad Conditions OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE: (I or 2 or 3 or 4)

1. Valid Reactor Building ventilation rad monitor (Kaman 3/4, 5/6, 7/8) or Turbine Building ventilation rad monitor (Kaman 1/2) reading above I E-3 [tCi/cc and is expected to continue for 60 minutes or longer.

OR Valid Offgas Stack rad monitor (Kaman 9/10) reading above 2.0 E-l pCi/cc and is expected to continue for 60 minutes or longer.

OR Valid LLRPSF rad monitor (Kaman 12) reading above 1.0 E-3 ptCi/cc and is expected to continue for 60 minutes or longer.

OR Valid GSW rad monitor (RIS-4767) reading above 3E+3 CPS and is expected to continue for 60 minutes or longer.

OR Valid RH-IRSW & ESW rad monitor (RM-1997)reading above 8E+2 CPS and is expected to continue for 60 minutes or longer.

OR Valid RHRSW & ESW Rupture Disc rad monitor (RM4268) reading above I E+3 CPS and is expected to continue for 60 minutes or longer.

OR

2. Confirmed sample analyses for gaseous or liquid releases indicates concentrations or release rates in excess of 2 times ODAM limit and is expected to continue for 60 minutes or longer.

OR

3. Valid dose assessment indicating dose rates beyond the site boundary above 0.1 mremlhr TEDE and is expected to continue for 60 minutes or longer.

AU1

EBD-A, EAL BASES DOCUMENT .B.

Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 4 of 27 DAEC EAL INFORMATION:

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

UNPLANNED, as used in this context, includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g.,

minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit. The EC/OSM should not wait until 60 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or will likely exceed 60 minutes. Also, if an ongoing release is detected and the starting time for that release is unknown, the EC/OSM should, in the absence of data to the contrary, assume that the release has exceeded 60 minutes.

The approach taken for calculation of gaseous radioactive effluent EAL setpoints includes use of the ODAM Table 3-2 source term computed by BWR-GALE for the DAEC Base Case. The release is assumed to be from a single release point. Multiple release points would be difficult to present as explicit EAL threshold values and in any case, are addressed by off-site dose assessment by MIDAS, which is the preferred method for determining this condition. The calculation methods for setpoint determination are from ODAM Section 3.4 and are based on Regulatory Guide 1.109 methodology. The table below lists the results of the gaseous effluent EAL calculations. The Kaman extended range capability is used because the General Electric Offgas Stack monitor has a limited range.

GASEOUS EFFLUENT EALS l AU1

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 5 of 27 Turbine Bldg (Kaman 1/2) and Offgas Stack Kaman 9110 Reactor Bldg (Kaman 3/4, 5/6, 7/8)

Maximum flow (CFM) 10,000 72,000 Release Limits Concentration Release Rate Concentration Release Rate (ViCi/cc) (uiCi/sec) (pCi/cc) (pCi/sec)

Tech Spec l .E-I 5.2E+5 6.2E-4 2.1 E+4 Unusual Event (2 x TS) 2.0E-1 1.OE+6 l .2E-3 4.2E+4 Alert (60 x TS) 6.OE+0 3.OE+7 3.7E-2 l .3E+6 LLRPSF Kaman 12 Maximum flow (CFM) 99,000 Release Limits Concentration Release Rate (tLCi/cc) ([LCi/sec)

Tech Spec 5.9E-4 2.8E+4 Unusual Event (2 x 1.OE-3 5.6E+4 TS/ODAM)

Alert (200 x TS) 1.OE-l 5.6E+6 The off-gas stack is treated as an elevated release and the turbine building and reactor building vents are treated as mixed-mode releases. The ground level setpoints are taken from the default setpoint calculations from the quarterly surveillance tests performed by DAEC Chemistry teclnicians. Reactor Building, Turbine Building, LLRPSF (Low Level Radwaste Processing and Storage Facility) and Offgas Stack Noble Gas Monitor alarm setpoints are calculated based on achieving the Tech Spec/ODAM instantaneous release limit, assuming annual average meteorology as defined in the ODAM. The Tech Spec/ODAM Limit currently corresponds to a reactor building or turbine building ventilation alarm setpoint of 6.2 E-04 pCi/cc. The monitor alarm setpoint can be periodically adjusted but typically does not vary by much. The DAEC EAL therefore addresses valid radiation levels exceeding 2 times the alarm setpoint for greater than 60 minutes. Rounded off, this corresponds to I E-3 p.Ci/cc. The corresponding offigas stack monitor value is l.IE-l pICi/cc, rounded off to I E-l ltCi/cc. The Tech Spec Limit currently for the LLRPSF building ventilation alarm setpoint is 5.9 E-04 pCi/cc. The DAEC EAL therefore addresses valid radiation levels exceeding 2 times the alarm setpoint for greater thlan 60 minutes. This corresponds to I E-3 pCi/cc.

Technical specification setpoints for radioactive liquid radiation monitors are 10 times the 10 CFR 20 Appendix B, Table 2, Water Effluent Concentration (WEC) limits. It is the policy of DAEC to process all liquid radwaste so that no release of radioactive liquid to the environment is allowed. The radwaste effluent line which could be used as a batch release mechanism has a trip function that prevents exceeding the DAEC release limit, however, an EAL has been provided. The other pathways to the environment (RHRSW - to cooling tower, RHRSW - to discharge canal) have radiation monitors with readouts going to the AU1

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 6 of 27 I--

Control Room. These systems could become contaminated if heat exchanger leaks develop; however, historically this has not occurred in the service water systems at DAEC. These monitors are displayed on panels I C02 and I C I0.

Reactor water is the likely source of contamination through the service water systems as opposed to floor drain, detergent drain, and chemical waste discharge. The floor drain and detergent drains go to Radwaste Processing and would be batch released to the Radwaste effluent discharge line (if such a release were to occur). The chemical discharge sump is normally a radioactivity clean system and is tested by Chemistry to ensure no contamination prior to discharging to the canal.

The setpoints for the three service water radiation effluent monitors vary because of differences in detector efficiencies and background. Setpoints based on the same reactor water sample are listed below to show the differences. The rounded off readings will be used for the EALs for ease of reading the monitor scales.

Monitor TS Limit Reading UE Level Alert Level GSW 1,555 CPS 1.5E+3 CPS 3E+3 CPS 33E+5 CPS l RHRSW & ESW to cooling 413 CPS 413+2 CPS 813+2 CPS 8E+4 CPS RHRSW & ESW to 507 CPS 513+2 CPS I E+3 CPS I E+5 CPS Discharge Canal _____

There are no significant deviations from the generic EALs. However, DAEC does not have a telemetered radiation monitoring system. As an alternative, use of field instruments was considered. It is not practical to establish an EAL based on field survey readings of 0.1 mr/hr for greater than 60 minutes because field instruments in use for emergency response do not have a threshold of detection to meet such criteria.

Hourly Whole Body Dose Corresponding to 2 x ODAMI Limit for Gaseous Release ODAM limit = 500 mrem/year Whole Body Dose (10CFR20, Appendix B limit = 50 mrem/year Whole Body Dose) 2 x ODAM limit = [2 x 500 mrem/year]/8760 hours/year = 0.114 mrem Whole Body, in one hour Rounded off to 0.1 mrem/hr Dose assessment using MIDAS is based on the EPA-400 methodology, e.g., use of Total Effective Dose Equivalent (TEDE). This is somewhat different from whole body dose from AUI

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 7 of 27 gaseous effluents determined by ODAM methodology which forms the basis for the radiation monitor readings calculated in accordance with the generic methodology. The gaseous effluent radiation monitors can only detect noble gases. The contribution of iodine's to TEDE could therefore only be determined either by: (I) utilizing MIDAS, or (2) gaseous effluent sampling. DAEC EAL 4 is written in terms of TEDE and the gaseous effluent radiation monitor readings are determined based on ODAM.

REFERENCES:

1. Offsite Dose Assessment Manual Section 6.0, 6.1.2 and 7.1.2 Bases

2. Emergency Plan Implementing Procedure (EPIP) 3.3, Dose Assessment and Protective Action

3. Radiation Protection Calculation No. 95-001-C, Emergency Actions Levels Based on Effluent Radiation Monitors, January 24, 1995

4. UFSAR Section 11.5, Process and Effluent Radiation Monitoring and Sampling Systems

5. ATE!Ifetlhodologyfor Development of Emergency Action Levels NUAMRCANESSP-00 7 Revision 4, May 1999 AUI

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 8 of 27 AU2 Unexpected Increase in Plant Radiation EVENT TYPE: Onsite Rad Conditions OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE: (I or 2)

1. Uncontrolled loss of reactor cavity or fuel pool water level with all spent fuel assemblies remaining covered by water as indicated by ANY of the following:

Report to the control room.

Valid fuel pool level indication (LI-3413) below 36 feet and lowering.

Valid WR GEMAC Floodup indication (LI-4541) coming on scale.

OR

2. Unexpected ARM reading offscale ligh or above 1000 times normnal* readings.

Normal levels can be considered as the highest reading in the past twenty-four hours excluding the current peak value.

DAEC EAL INFORMATION:

There are no significant deviations from the generic EALs. DAEC does not have a spent fuel transfer canal.

Uncontrolledmeans that the condition is not the result of planned actions by the plant staff in accordance with procedures. Valid means that the reading is from instrumentation determined to be operable in accordance with the Technical Specifications or has been verified by other independent methods such as indications displayed on the control panels, reports from plant personnel, or radiological survey results.

There are three methods to determine water level decreases of concern. The first method is by report to the control room. The other methods include use of the Floodup level indicator and the spent fuel pool level indicator. These are further described below.

During preparation for reactor cavity flood up prior to entry into refuel mode, reactor vessel level instrument LI-4541 (WR GEMAC, FLOODUP) on control room panel IC04 is placed AU2

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 9 of 27 in service by I&C personnel connecting a compensating air signal after the reference leg is disconnected from the reactor head. Normal refuel water level is above the top of the span of this flood up level indicator. A valid indication (e.g., not due to loss of compensating air signal or other instrument channel failure) of reactor cavity level coming on span for this instrument is used at DAEC as an indicator of uncontrolled reactor cavity level decrease.

DAEC Technical Specifications require a minimum of 36 feet of 'water in the spent fuel pool. During refueling, the gates between the reactor cavity and the refueling cavity are removed and the spent fuel pool level indicator LI 3413 is used to monitor refueling water level. Procedures require that a normal refueling water level be maintained at 37 feet 5 inches. A lowv level alarm actuates when spent fuel pool level drops below 37 feet I inch.

Symptoms of inventory loss at DAEC include visual observation of decreasing water levels in reactor cavity or spent fuel storage pool, Reactor Building (RB) fuel storage pool radiation monitor or refueling area radiation monitor alarms, observation of a decreasing trend on the spent fuel pool water level indicator, and actuation of the spent fuel pool low water level alarm. To eliminate minor level perturbations from concern, DAEC uses LI 3413 indicated water level below 36 feet and lowering.

Increased radiation levels can be detected by the local refueling floor area radiation monitors, the refueling floor Continuous Air Monitor (CAM) alarm, refueling areas radiation monitors, fuel pool ventilation exhaust monitors, and by Standby Gas Treatment (SGBT) System automatic start. Applicable area radiation monitors include those that are displayed on Panel I C02 and alarmed on Panel I C04B. The DAEC EAL has also been written to reflect the case where an ARM may go offscale high prior to reaching 1,000 times the normal reading.

NOTE: On Annunciator Panel IC04B, the indicators listed below are expected alarms during pre-planned transfers of highly radioactive material through the affected area. If anl HP Technician is present, sending an Operator is not required. Radiation levels other than those expected should be promptly investigated. The indicators are high radiation alarms from the Hot Laboratory or Administrative Building, the new fuel storage area, and the radwaste building.

AU2

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 10 of 27p'

REFERENCES:

1. Alarm Response Procedure (ARP) IC04B, Reactor Water Cleanup and Isolation

2. Technical Specification 3.7.8, Spent Fuel Pool Water Level

3. Emergency Plan Implementing Procedure (EPIP) 3.1, Inplant Radiological Monitoring, Attachment 1, ARM Locations

4. Emergency Operating Procedures (EOP) Basis Document, Breakpoints for RC/L & L

5. Surveillance Test Procedure (STP) 3.0.0.0-OIPA, Daily and Shift Instrument Checks

6. Integrated Plant Operating Instruction (IPOI) 8 , Outage and Refueling Operations

7. Core Alterations, RFP403, Procedure for Moving Core Components Between Reactor Core and Spent Fuel Pool, Within the Reactor Core, or Within the Spent Fuel Pool

8. NEI MIethodologyfor Development of Emergency Action Levels NUAJARC'/NE SP-007 Revision 4, May 1999 AU2

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 11 of 27 AA1 Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200X the Offsite Dose Assessment Manual (ODAM) Limit and is Expected to Continue for 15 Minutes or Longer EVENT TYPE: Offsite Rad Conditions OPERATING MOD)E APPLICABILITY: All EAL THIRESIIOLD VALUE: (I or 2 or 3 or 4)

1. Valid Reactor Building ventilation rad monitor (Kaman 3/4, 5/6, 7/8 ) or Turbine Building ventilation rad monitor (Kaman 1/2) reading above 3 1.-2 jiCi/cc and is expected to continue for 15 minutes or longer.

OR Valid Offgas Stack rad monitor (Kaman 9/10) reading above 6 E+-0 jCi/cc and is expected to continue for 15 minutes or longer.

OR Valid LLRPSF rad monitor (Kaman 12) reading above I E-l tCi/cc and is expected to continue for 15 minutes or longer.

OR Valid GSW rad monitor (RIS-4767) reading above 3E+5 CPS and expected to continue for 15 minutes or longer.

OR Valid RHIRSW & ESW rad monitor (RM-1997) reading above 8E+4 CI'S and expected to continue for 15 minutes or longer.

OR Valid RH-IRSW & ESW Rupture Disc rad monitor (RM-4268) reading above I E+5 CPS and expected to continue for 15 minutes or longer.

OR

2. Confirmed sample analyses for gaseous or liquid releases indicates concentrations or release rates writh a release duration expected to continue for 15 minutes or longer in excess of 200 times ODAM limit.

OR AA1

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 12 of 27 1-

3. Valid site boundary radiation reading of greater than 10 mremlhr above normal background and is expected to continue for 15 minutes or longer.

OR

4. Valid dose assessment indicating dose rates beyond the site boundary above 10 mrenl/hr TEDE and is expected to continue for 15 minutes or longer.

DAEC EAL INFORNM TION:

Valid means that the reading is from instrumentation determined to be operable in accordance with the Technical Specifications or has been verified by other independent methods such as indications displayed on the control panels, reports from plant personnel, or radiological survey results. In a case where data from Kaman readings is being used to determine whether an EAL threshold value has been exceeded, Valid means that flow through the associated Kaman Monitor has been verified and does exist as indicated in

[tCi/sec on SPRAD.

UNPLANNED, as used in this context, includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g.,

minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit. The EC/OSM should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or wvill likely exceed 15 minutes. Also, if an ongoing release is detected and the starting time for that release is unknown, the EC/OSM should, in the absence of data to the contrary, assume that the release has exceeded 15 minutes.

AA1

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 13 of 27 Gaseous Effluent EALs Offgas Stack Kaman 9/1 0 Turbine Bldg (Kaman 1/2) and Reactor Bldg (Kaman 3/4, 5/6, 7/8)

MaLximum flow (CFM) 10,000 72,000 Release Limits Concentration Release Rate Concentration Release Rate (iCifcc) -(Ci/sec) (LCi/cc) (piCi/sec)

Tech Spec 1.113-1 5.213+5 6.213-4 2.1 13+4 Unusual Event (2 x TS) 2.013-1 1.OE+6 1.213-3 4.213+4 Alert (60 x TS) 6.0E+0 3.OE+7 3.7E-2 1.31E+6 LLRPSF Kaman 12 Maximum flow (CFM) 99,000 Release Limits Concentration Release Rate (pCi/cc) (ylCi/sec)

Tech Spec 5.913-4 2.8E1+4 Untustual Event (2 x TS) 1.013-3 5.6E1+4 Alert (200 x TS) 1.013- I 5.6E+6 The off-gas stack is treated as an elevated release and the turbine building and reactor building vents are treated as mixed-mode releases. The ground level setpoints are taken from the default setpoint calculations from the quarterly surveillance tests pcrformed by DAEC Chemistry technicians. Reactor Building, Turbine Building, LLRPSF (Low Level Radwaste Processing and Storage Facility) and Offgas Stack Noble Gas Monitor alann setpoints are calculated based on achieving the Tech Spec instantaneous release limit assuming annual average meteorology as defined in the ODAM. The Tech Spec Limit currently corresponds to a reactor building or turbine building ventilation alarm sctpoint of 6.2 E-4 ,uCi/cc. The monitor alarm setpoint can be periodically adjusted but typically does not vary by much. For the Offgas Stack, Reactor Building and Turbine building KAMAN monitor readings, DAEC chose to multiply the technical specification concentration by a factor of 60 (instead of 200) in order to allow for a logical step progression in monitor setpoints from the AU 1 through AA 1 to AS 1. The DAEC EAL therefore addresses valid radiation levels exceeding 60 times the alarm setpoint for greater than 15 minutes. Rounded down, this corresponds to 3 E-2 pCi/cc. The corresponding offgas stack monitor value is 6.6 pCi/cc, rounded down to 6 13+0 p[Ci/cc. The Tech Spec/ODAM Limit currently for thle LLRPSF building ventilation alarm setpoint is 5.9 E-04 pLCi/cc. Thie DAI C EAL therefore addresses valid radiation levels exceeding 200 times the alarm setpoint for greater than 15 minutes. This corresponds to I E-1 pCi/cc.

Technical specification setpoints for radioactive liquid radiation monitors are 10 times the 10 CFR 20 Appendix B, Table 2, Water Effluent Concentration (WEC) limits. It is the policy of DAEC to process all liquid radwaste so that no release of radioactive liquid to the AA1

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 14 of 27 l-environment is allowed. The radwaste effluent line which could be used as a batch release mechanism has a trip function that prevents exceeding the DAEC release limit, and therefore no EAL limits are provided. The other pathways to the environment (RHRSW - to cooling tower, RHIRSW - to discharge canal) have radiation monitors with readouts going to the Control Room. These systems could become contaminated if heat exchanger leaks develop; however, historically this has not occurred in the service water systems at DAEC.

These monitors are displayed on panels 1C02 and I C 10.

Reactor water is the likely source of contamination through the service water systems as opposed to floor drain, detergent drain, and chemical waste discharge. The floor drain and detergent drains go to Radwaste Processing and would be batch released to the Radwaste effluent discharge line (if such a release were to occur). The chemical discharge sump is normally a radioactivity clean system and is tested by Chemistry to ensure no contamination prior to discharging to the canal.

The setpoints for the three service wvater radiation effluent monitors vary because of differences in detector efficiencies and background. Setpoints based on the same reactor water sample are listed below to show the differences. The rounded off readings will be used for the EALs for ease of reading the monitor scales.

Monitor TS/ODAM Limit Reading UE Level Alert Level GSW 1,555 CPS 1.5E+3 CPS 3E+3 CPS 3E+5 CPS RFIRSW & ESW to cooling 413 CPS 4E+2 CPS 8E+2 CPS 8E+4 CPS tower RHRSW & ESW to 507 CPS 5E+2 CPS I E+3 CPS IE+5 CPS Discharge Canal DAEC does not have a telemetered radiation monitoring system. As an alternative, DAEC uses valid field survey readings outside the site boundary greater than 10 mr/hr or greater than 50 mr/hr CDE Thyroid.

Hourly Whole Body Dose Corresponding to 200 x ODAMNI Limit for Gaseous Release ODAM limit = 500 mrem/year Whole Body Dose (IOCFR20, Appendix B limit = 50 mremn/year Whole Body Dose) 200 x ODAE limit = [200 x 500 mrem/year]/8760 hours/year = 11.4 mrem Whole Body in one hour Rounded off to 10 mremlhr AA1

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 15 of 27 Dose assessment using MIDAS is based on the EPA-400 methodology, e.g., use of Total Effective Dose Equivalent (TEDE). This is somewhat different from whole body dose from gaseous effluents determined by ODAM methodology which forms the basis for the radiation monitor readings calculated in AUI in accordance with the generic methodology.

The gaseous effluent radiation monitors can only detect noble gases. The contribution of iodine's to TEDE could therefore only be determined either by: (I) utilizing MIDAS, or (2) gaseous effluent sampling. DAEC EAL 4 is written in terms of TEDE and the gaseous effluent radiation monitor readings are determined based on ODAM.

REFERENCES:

1. Offisite Dose Assessment Manual Section 6.0, 6.1.2 and 7.1.2 Bases

2. Emergency Plan Implementing Procedure (EPIP) 3.3, Dose Assessment and Protective Action

3. Radiation Protection Calculation No.95-001 -C, Emergency Actions Levels Based on Effluent Radiation Monitors, January 24, 1995

4. UFSAR Section 11.5, Process and Effluent Radiation Monitoring and Sampling Systems

5. EPA 400-R-92-00 1, Alanual of ProtectiveAction Guides and J'rolecaiheActions/for Aluclear Incidents

6. ANEI AMetlhodology for Development of Emergency, Action Levels A'UAIA RCC/AESP-007 Revision 4, May 1999 AA1

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 16 of 27 AA2 Major Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel EVENT TYPE: Onsite Rad Conditions OPERATING MODE APPLICABILITY: All EAL THRESHOLD VALUE: (I or 2 or 3 or 4)

I. Report of either of the following:

Valid ARM Fli Rad alarn for the Refueling Floor North End (RNM 9163), Refueling Floor South End (RM 9164), New Fuel Storage (RM 9153), or Spcnt Fuel Storage Area (RM 9178).

Valid Refueling Floor North End (RM-91 63), Refueling Floor South End (RM-9164), or New Fuel Storage Area (RM-9153) ARM Reading above I0 mr/hr

Valid Spent Fuel Storage Area ARM (RM-9178) Reading above 100 mr/hr OR

2. Report of Visual observation of irradiated fuel uncovered.

OR

3. Valid water level reading below 450" as indicated on LI-4541 (floodup) for the Reactor Refueling Cavity that will result in Irradiated Fuel uncovering.

OR

4. 4. Valid Fuel Pool water level indication (11-3413) below 16 feet that will result in Irradiated Fuel uncovering.

DAEC EAL INFORINIATION:

Valid means that the reading is from instrumentation determined to be operable in accordance with the Technical Specifications or has been verified by other independent methods such as indications displayed on the control panels, reports from plant personnel, or radiological survey results. Valid alarms are solely due to damage to irradiated fuel or loss of water level that has or will result in the uncovering of irradiated fuel.

There are no significant deviations from the generic EALs. Increased radiation levels can be detected by the local radiation monitors, in-plant radiological surveys, new fuel and spent fuel storage area radiation monitor alarms displayed on panel 1C04B, fuel pool ventilation exhaust monitors, and by Standby Gas Treatment (SBGT) System automatic start.

AA2

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 17 of 27 Applicable area radiation monitors include RM-9163, RM-9164, RM-9153, and RM-9178.

These monitors are located in the north end of the refuel floor, the south end of the refuel floor, the new fuel vault area, and near the spent fuel pool, respectively.

Per ARP IC04B, the applicable area radiation monitor alarms actuate when radiation levels increase above 100 mr/hr in the spent fuel pool area or above 10 mr/hr in the other three areas of concern. If a valid actuation of these alarms Nvere to occur, the refileling floor would be immediately evacuated. 'Thus, a report ofa fuel handling accident with either valid actuation of the fuel area alarms on panel I C04B or with measured radiation levels in the spent fuel pool or north fuel area are used to address the generic concern consistent with DAEC design and procedures.

During preparation for reactor cavity flood up prior to entry into refuel mode, reactor vessel level instrument 1,1-4541 (W\VR GEMAC, FLOODUP) oln control room panel IC04 is placed in service by I&C personnel connecting a compensating air signal after the reference leg is disconnected from the reactor head. Normal refuel water level is above the top of the span of this flood up level indicator. A valid on-scale indication (e.g., not due to loss of compensating air signal or other instrument channel failure) from this instrument can be used to determine uncontrolled loss of water level in the reactor cavity.

During refuieling, the gates between the reactor cavity and the refueling cavity are removed and the spent fuel pool level indicator LI 3413 is used to monitor refueling water level. This measures the common water level in the reactor cavity and the fuel pool. The bottom of the fitiel transfer slot between the spent fuel pool and the reactor cavity is 16 feet above the bottom of the spent fuel pool. The top of the active fuel in the spent fuel storage racks is slightly less than 13 feet 9 inches above the bottom of the spent fuel pool. Therefore, postulated failures which drain the reactor cavity through the reactor vessel cannot uncover Fuel in the spent fuel storage racks. HIowever, valid indication ofspent fuel pool level less than 16 feet would indicate that spent fuel in the storage racks may potentially become uncovered.

RF1P403 requires that upon a loss of water level situation, that the refueling crew on the refueling floor shall discharge any fuel assembly on the fuel grapple as follows:

If a fuel assembly is currently being withdrawn from a slot in the core or spent fiuel pool, immediately reinsert it into that slot.

Ifia fuel assembly is being transferred and is still over or near the core, insert it into the closest available slot in the core.

If a fuel assembly is being transferred and is over or near the spent fuel pool, insert it into the closest available slot in the spent fuel racks.

AA2

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 18 of 27 Following these actions, the refueling floor is to be evacuated of all personnel. The DAEC EAL is written to address the generic concern that a spent fuel assembly was not fuilly covered by water. This can either be by visual observation of an uncovered spent fuel assembly or by trending fuel pool level in the control room if a spent fuel assembly could not be placed in a safe storage location specified by RFP 403 as described above.

REFERENCES:

1. Alarn Response Procedure (ARP) I C04B, Reactor Water Cleanup and Isolation

2. Technical Specification 3.7.8, Spent Fuel Pool Water Level

3. Emergency Operating Procedures (EOP) Basis Document, Breakpoints for RC/L & L

4. Emergency Plan Implementing Procedure (EPIP) 3.1, Inplant Radiological Monitoring, Attachment 1, ARM Locations

5. Surveillance Test Procedure (STP) 3.0.0.0-01, Daily and Shift Instrument Checks

6. Integrated Plant Operating Instruction (IPOI) 8 , Outage and Refueling Operations

7. Core Alterations, RFP403, Procedure for Moving Core Components Between Reactor Core and Spent Fuel Pool, Within the Reactor Core, or Within the Spent Fuel Pool

8. Bechtel Drawing C-492, Reactor Building - Reactor Well, Spent Fuel & Dryer-Separator Pool General Arrangement, Rev. 6

9. Bechtel Drawing C-493, Reactor Building - Spent Fuel Liner Plan Elevations and Details, Sheet 1, Rev. 6

10. Holtec International Drawing No. 1045, Rack Construction - Spent Fuel Storage Racks, Rev. 3

11. NEI Mfethodologyfor Development of Emtergency Action Levels NUMfARC/NVESP-007 Revision 4, May 1999 AA2

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 19 of 27 AA3 Release of Radioactive Material or Increases in Radiation Levels Within the Facility That Impedes Operation of Systems Required to Maintain Safe Operations or to Establish or to Maintain Cold Shutdown EVENT TYPE: Onsite Rad Conditions OPEIRATING MODE APPLICA1I1LITY: All EAL THIRESIIOLI) VALUE: (1 or 2)

1. Valid Control Room Area Radiation Monitor (RM-9162) reading above 15 mr/hr.

OR

2. Valic North CRD Module Area Radiation Monitor (RM-9 168) reading above 500) mr/hr.

affecting the Remote Shutdown Panel, 1C388.

I)AEC EAL INFORMATION:

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

There are no significant deviations from the generic EALs. Per the UFSAR, the control room is the only area that is required to be continuously occupied to achieve and maintain safe shUtdoxvn following design basis accidents. The capability exists ior plant shutdown from outside the main control room in the event that the control room becomes uninhabitable using remote shutdown panel IC388. The RB 757 CRD North AIRM-9168 is in the vicinity of the Remote Shutdown Panel and is used to monitor radiation levels to determine habitability for that area.

Expected increases in monitor readings due to controlled evolutions (such as lifting thie steam dryer during refueling) do not result in emergency declaration. Nor should momentary increases due to events such as resin transfers or controlled movement of radioactive sources result in emergency declaration. In-plant radiation level increases that would result in emergency declaration, are also tOnplanne1Cd, e.g., outside the limits established by an existing radioactive discharge permit.

AA3

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 20 of 27

REFERENCES:

1. Alarm Response Procedure (ARP) 1C04B, Reactor Water Cleanup and Isolation

2. Abnormnal Operating Procedure (AOP) 913, Fire

3. Abnornal Operating Procedure (AOP) 914, Security

4. Abnormal Operating Procedure (AOP) 915, Shutdown Outside Control Room

5. Surveillance Test Procedure (STP) 3.0.0.0-01, Daily and Shift Instrument Checks

6. Integrated Plant Operating Instruction (IPOI) 8 , Outage and Refueling Operations

7. Emergency Plan Implementing Procedure (EPIP) 3.1, Inplant Radiological Monitoring

8. UFSAR Section 6.4, Habitability Systems

9. Bechtel Calculation DA-4, Project Number 265-002, Control Room Habitability, 9/3/80

10. NE! I fetlhodologyfor Development of Em nergency Action Levels NUM1RC/NERSII-007 Revision 4, May 1999 AA3

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 21 of 27 ASI Site Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mrem TEDE or 500 mrem CDE Thyroid for the Actual or 1Projected l)uration of the Release EVENT TYP'E: Orfsitc Rad Conditions OPERATING MOI)E AlPP'LICABILITY: All EAL TIHRESHIOLI) VALUE: (I or 2 or 3)

I. Valid Reactor Building ventilation rad monitor (Kaman 3/4, 5/6, 7/8) or Turbinc Building ventilation rad monitor (Kaman 1/2) reading above 6 E-2 FICi/cc and is expected to continue for 15 minutes or longer. (Dose assessment not available.)

O1R Valid Offgas Stack rad monitor (Kaman 9/10) reading above 4 E+l pCi/cc and is expected to continue for 15 minutes or longer. (Dose assessmcnt not available)

OR

2. Field sunrcy results indicate site boundary dose rates exceeding 100 mrerlh/r expected to continue for more than one hour; or analyses of field survey samples indicate CDE Thyroid of 500 mrem for one hour of inhalation.

OR

3. I)ose assessment determines integrated accident dose projection outside the site boundary above 100 mrem TEDE or above 500 mrem CDE Thyroid.

I)AEC EAL INFORMATION:

ailidl means that the reading is from instrumentation determined to be operable in accordance wvith the Technical Specifications or has been verified by other independent methods such as indications displayed on the control panels, reports from plant personnel, or radiological survcy results. In a case where data from Kaman readings is being used to determine whether an EAL threshold value has been exceeded, 'ialidlmeans that flow through the associated Kaman Monitor has been verified and does exist as indicated in

[tCi/sec on SI'RAD.

The preferred method for declaration of AS I is by means of Dose Assessment using the MIDAS computer model. Ilowever, if Kaman monitor readings are sustained for longer than 15 minutes and the required MIDAS dose assessments cannot be completed wvithin this period, then the declaration can be made using Kaman readings PROVIDEID the readings ASI

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 22 of 27 are not from an isolated flow path. If Kaman readings are not valid, field survey results may be utilized.

DAEC's Meteorological Information and Dose Assessment System (MIDAS) wvzas utilized to determine the Kaman monitor limits. Eight separate combinations of release point, source term, meteorological conditions and equipment status were analyzed. Pathways considered were the offgas stack, the turbine building exhaust vent and a single reactor building exhaust vent. Multiple release points were not considered. In this same vein, it was assumed that only one of the three reactor building vents is on during the release.

The source terms used have been pre-loaded into MIDAS and are the default mixes associated with a loss of coolant accident (LOCA) and a control rod drop (CRD). The LOCA mix. was used in conjunction with a release via the offgas stack while the CRD mllix was used for releases via the turbine or reactor building vents. The source term for a release via the offgas stack is further impacted by the status of the standby gas treatment system.

The status of that system was also taken into consideration.

Based on 1995 data (NG-96-0987), the atmospheric stability was classified as Pascal E 33%

of the time. Consequently, both classifications were evaluated. Based on the stune report, the most common wind speeds were:

Pascal Class Altitude Speed (mph)

D 156' 8-12 D 33' 8-12 E 156' 8-12 E 33' 4-7 Though the temperature setting has no impact on the MIDAS calculations, a value must be entered in order for the program to run. Consequently, the temperature was arbitrarily set at 50 F.

The rain estimate was set at zero, to eliminate any on site washout of radioactive material.

For the first MIDAS runs a I Ci/cc concentration was assumed. The results of these runs were then normalized to the limits, thus generating a theoretical Kaman limit. Additional MIDAS runs were made with these theoretical limits as input to verify the normalization process. In addition to the total integrated dose, MIDAS calculates a peak whole body DDE rate resulting from the plume and a peak thyroid CDE rate resulting from inhalation.

Because the AS I and AGI KAMAN limits are to be based on a one-hour exposure, establishing concentration limits so these peak values match the NUMARC limits is acceptable.

ASI

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 23 of 27 Site Area Geneml Initiating Condition Emergency' Eiergency ASI AGI Valid Turbine or Reactor Building ventilation rad monitor (KAMAN) reading for more than 15 0.06 [tCi/cc 0.6 fCi/cc millutes above:

I)AEC does not have a telemetered radiation monitoring systemi. As an alternative, )AElC uses valid field survey readings outside the site boundary to determine il'doses are greater than 100 mrhAr TEDE or greater than 500 mr/lr CDE Thyroid.

Dose assessment using MIDAS is based on the EPA-400 methodology, e.g., use of Iotal Eflective Dose Equivalent (T[IDE) and Committed I)ose Equivalent (C)lE) Thyroid.

TEDE is somewhat different from whole body dose from gaseous effluents determ-ined by ODlAM methodology which forms the basis for the radiation monitor readings calculated in AU 1. These factors can introduce differences that are at least as large as those introduced by using T'll)E versus whole body dose. The gaseous elffluent radiation monitors can only detect noble gases. The contribution of iodine's to TEDE and C)E Th1yroid could therefore only be determnined either by: (1) utilizing the source term mixture in MII)AS, or (2) gaseous effluent sampling. Therefore, DAEC EAL Threshold \Talue 3 is xvritten in terms of' TEDE and CDE Thyroid.

REFERrENCES:

I. Olffsite Dose Assessment Manual, Section 6.0, 6.1.2 and 7.1.2, Bases

2. EImergency Plan Implementing Procedure (EPIP) 3.3, Dose Assessment and lProtective Action

3. Radiation Protection Calculation No. 95-001-C, Emergency Actions Levels Based on Iffluent Radiation Monitors, January 24, 1995

4. Radiation E-ngineering Calculation No. 96-007-A, Determination of DAIC Radioactive Release Initiating Conditions for AS I & AG I Emergency Classifications, July 3, 1996

5. UFSAR Section 11.5, Process and Effluent Radiation Monitoring and Sampling Systems

6. EPA 400-R-92-00 1, iA'anucl of Protective Action Guides and Ih-otectii e Actions fir Nuclear Incidents

7. NEI AlkthotiologyJfi Dei elopnient of Eniergency Action Lcvels NUA IA RCYNESP-00 7 RIeision 4, May 1999 ASI

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY 24 of 27 AGI Site Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 1,000 mrem TEDE or 5,000 mrem CDE Thyroid for the Actual or Projected Duration of the Release EVENT TYPE: Offsite Rad Conditions OPERATING NIODE APPLICABILITY: All EAL THRESHOLD VALUE: (1 or 2 or 3)

1. Valid Reactor Building ventilation rad monitor (Kaman 3/4, 5/6, 7/8) or Turbille Building ventilation rad monitor (Kaman 1/2) reading above 6 E-l ttCi/cc and expected to continue for 15 minutes or longer. (Dose assessment not available)

OR Valid Offgas Stack rad monitor (Kaman 9/10) reading above 4 E+2 pCi/cc and expected to continue for 15 minutes or longer. (Dose assessment not available)

OR

2. Field survey results indicate site boundary dose rates exceeding 1,000 mrem/hr expected to continue for more than one hour; or analyses of field survey samples indicate CDE Thyroid of 5,000 mrem for one hour of inhalation.

OR

3. Dose assessment determines integrated accident dose projection outside the site boundary above 1,000 mrem TEDE or above 5,000 mrem CDE Thyroid.

DAEC EAL INFORMATION:

Valid means that the reading is from instrumentation determined to be operable in accordance with the Technical Specifications or has been verified by other independent methods such as indications displayed on the control panels, reports from plant personnel, or radiological survey results. In a case where data from Kaman readings is being used to determine whether an EAL threshold value has been exceeded, Valid means that flow through the associated Kaman Monitor has been verified and does exist as indicated in pCi/sec on SPRAD.

AGI

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 25 of 27 The preferred method for declaration of AGI is by means of Dose Assessment using the MIDAS computer model. H-lowever, if Kaman monitor readings are sustained for longer than 15 minutes and the required MIDAS dose assessments cannot be completed within this period, then the declaration can be made using Kaman readings PROVIDEI) the readings are not from an isolated flow path. If Kaman readings are not valid. field survey results may be utilized.

DAEC's Meteorological Information and Dose Assessment System (MIDAS) wvas utilized to determine the Kaman monitor limits. Eight separate combinations of release point, source term, meteorological conditions and equipment status were analyzed. Iathways considered wvere the offgas stack, the turbine building exhaust vent and a single reactor building exhaust vent. Multiple release points were not considered. In this same vein, it was assumed that only one of the three reactor building vents is on during the release.

The source terms used have been pre-loaded into MIDAS and are the deflault mixes associated with a loss of coolant accident (LOCA) and a control rod drop (CRD). 'l'he LOCA mix was used in conjunction With a release via the offgas stack while the CR) mlix was used for releases via the turbine or reactor building vents. The source term lor a release via the offgas stack is further impacted by the status of the standby gas treatment system.

The status of that system wvas also taken into consideration.

Based of 1995 data (NG-96-0987), the atmospheric stability was classified as Pascal B 33%

of the time. Consequently, both classifications were evaluated. Based oln the same report, the most common wind speeds were:

Pascal Class Altitude Speed (mrph)

1) 156' 8- 12

1) 33' 8- 12 E 156' 8- 12 1 33' 4-7 Though the temperature setting has no impact on the MIDAS calculations, a value must be entered in order for the program to rin. Consequently, the temperature auras arbitrarily set at 50 F.

Tile rain estimate was set at zero, to eliminate any on site wvashout of radioactive material.

I-or the first MIDAS runs a ICi/ec concentration was assumed. The results of these runs were then normalized to the limits, thus generating a theoretical Kaman limit. Additional MIDAS runs were made with these theoretical limits as input to verify the normalization process.

AG1

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 26 of 27 1-'

In addition to the total integrated dose, MIDAS calculates a peak whole body DDE rate resulting from the plume and a peak thyroid CDE rate resulting from inhalation. Because the ASI and AGI Kaman limits are to be based on a one-hour exposure, establishing concentration limits so these peak values match the NUMARC limits is acceptable.

Site Area General Initiating Condition Emergency Emergency ASI AGI Valid Turbine or RB ventilation rad monitor (Kaman) reading for more than 15 minutes above: 0.06 pCi/cc 0.6 pCi/cc Valid Offgas Stack ventilation rad monitor (Kaman) reading for more than 15 minutes above: 40 pCi/cc 400 pCi/cc DAEC does not have a telemetered radiation monitoring system. As an alternative, DAEC uses valid field survey readings outside the site boundary to determine if doses are greater than 1,000 mr/hr TEDE or greater than 5,000 mr/hr CDE to the Thyroid.

Dose assessment using MIDAS is based on the EPA-400 methodology, e.g., use of Total Effective Dose Equivalent (TEDE) and Committed Dose Equivalent (CDE) Thyroid.

TEDE is somewhat different from whole body dose from gaseous effluents determined by ODAM methodology which forms the basis for the radiation monitor readings calculated in AU 1. These factors can introduce differences that are at least as large as those introduced by using TEDE versus whole body dose. The gaseous effluent radiation monitors can only detect noble gases. The contribution of iodine's to TEDE and CDE Thyroid could therefore only be determined either by: (1) utilizing the source term mixture in MlIDAS, or (2) gaseous effluent sampling. Therefore, DAEC EAL Threshold Value 4 is xvritten in terms of TEDE and CDE Thyroid.

REFERENCES:

I. Offsite Dose Assessment Manual, Section 6.1.2 and 7.1.2, Bases

2. Emergency Plan Implementing Procedure (E'PIP) 3.3, Dose Assessment and Protective Action

3. Radiation Protection Calculation No. 95-001-C, Emergency Actions Levels Based on Effluent Radiation Monitors, January 24, 1995

4. Radiation Engineering Calculation No. 96-007-A, Determination of DAEC Radioactive Release Initiating Conditions for AS I & AGI Emergency Classifications, July 3, 1996

5. UFSAR Section 11.5, Process and Effluent Radiation Monitoring and Sampling Systems AG1

EBD-A EAL BASES DOCUMENT Rev. 8 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT CATEGORY PAGE 27 of 27

6. EPA 400-R-92-001, Alrnuatrl ofProtectiv ct iion Giciies (anc lIr olectiie Actionis.oI Ai'tclear Inciclenis

7. ATEI Ajfethodlology for Deilelopemenn of EmzerpygencjyAction Levels \UAIAR(/S'I/I\'S'vI-OO7 Revision 4, May 1999.

AG1

EBD-F EAL BASES DOCUMENT Rev. 5 FISSION PRODUCT BARRIER DEGRADATION CATEGORY PAGE 1 of 29 Usage Level Reference Use

[Effective Date: X ]

TECHNICAL REVIEW Prepared by: i ) l Date: IL? /o Reviewed by: H a&0.

Independent Reflwer Date: 01i2q Reviewed by: Date: i (Zq /01 U J Operations Staff PROCEDURE APPROVAL I am responsible for the technical content of this procedure and for obtaining the necessary approval from the State and County Emergency Management officials prior to implementation.

Documentation of State and County Emergency Management approval is via NEP-2004-0005 Approved by: C2.e4D Date: I /-3/ov '

Manager, Emergency Planning I I

EBD-F EAL BASES DOCUMENT Rev. 5 FISSION PRODUCT BARRIER DEGRADATION CATEGORY PAGE 2 of 29l Table of Contents FU1 - Any Loss or Any Potential Loss of Primary Containment Barrier ................... 3 FAI - Any Loss or Any Potential Loss of Either Fuel Clad Or RCS Barrier .............. 4 FS1 - Loss Or Potential Loss of Any Two Barriers ................................................ 5 FG1 - Loss of Any Two Barriers AND Potential Loss of the Third Barrier ............. 6 FUEL CLAD BARRIER INDICATORS ........................................................ 7 RCS BARRIER INDICATORS ............. .......................................... 14 PRIMARY CONTAINMENT BARRIER INDICATORS ........................................ 22

EBD-F EAL BASES DOCUMENT Rev. 5 FISSION PRODUCT BARRIER DEGRADATION CATEGORY PAGE 3 of 29l FUI Any Loss or Any Potential Loss of Primary Containment Barrier EVENT TYPE: See Fission Barrier Table OPERATING MODE APPLICABILITY: Run, Startup, Hot Shutdown EAL Threshold Values: