IR 05000325/2007301

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July-August Exam 50-325, 324/2007301 Final Simulator Scenarios (Scenario 4 of 4) (Section 2 of 2)
ML072970108
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 01/31/2007
From:
- No Known Affiliation
To:
Office of Nuclear Reactor Regulation
References
50-324/07-301, 50-325/07-301 50-324/07-301, 50-325/07-301
Download: ML072970108 (49)
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Text

    • NRC 2007 Simulator Scenario#4 Examiner Directed Triggers Lead Examiner directs the following Triggers: Event 3: Trigger 1: IRM"C" Fails Downscale (While RO is withdrawing control rods)Event 4: Trigger 2: HCU 34-15 Accumulator Alarm (Following IRM Tech Spec Call)Event 5: Trigger 8: 28 Steam Packing Exhauster Trip (Following Accumulator Tech Spec Call)Event 6: Trigger 3: Seismic Event (Following SPE Trip Response)Event 7: Trigger 4: A TWS/RWCU Unisolable Leak (Following DG#3 and IRM"F" Response)Event 8: Trigger 6: RHR Room HI HI Alarm-ED Required (Following Response to Core Spray Room HI-HI and RHR RoomHI water level alarms)NOTE: RHR Room Hi-Hi alarm should be initiated while reactor pressure is above 400 psig.At or below 400 psig, control rods may drift in and cause the crew to exit the Level Power Control procedure, thus not requiring Terminate and Prevent prior to ED.Termination cue: After the reactor has been depressurized AND condensate injection through the Startup Level Control Valve ORV120 has commenced for level recover, THEN this scenario may be*terminate .2\Placing Off-Gas Train 2A(2B)in Service 5.2.1 Initial Conditions R Reference Use 1.All applicable prerequisites as listed in Section 4.0 are met.D 2.Main steam pressure reducing station is in operation and motive steam pressure is between 110 and 120 psig.D 3.Recombiner catalyst bed temperature is greater than 300°F.D 4.Hydrogen Water Chemistry (HWC)System has been out of service for at least 15 minutes to allow off-gas influent hydrogen concentration to return to normal.D 5.Off-Gas ANAL VZERS, OG-AIT-4284 and OG-AIT-4324, are operable, or otherwise be prepared to comply with ODCMS Table 7.3.2-1, Function 5a,b.D 6.IF Off-Gas ANAL VZERS, OG-AIT-4284 and D OG-AIT-4324, are in HOLD or CAL, THEN I&C Maintenance is prepared to support placing analyzers in serviceo NOTE: Following an outage or an extended period of time (usually greater than 3 days)with an off-gas train out of service, SJAE level instrument reference legs may have dried out and need to be refilled.7.IF Off-Gas Train 2A(2B)has been out of service for an extended period, THEN I&C Maintenance has filled the SJAE level instrument reference legs as required.D 8.Flowpath to the Main Stack has been establishedo D CAUTION Valves OG7"V10, OG-V11, OG-V12, OG-V13, SJE-V3, SJE-V4 SJE-V10, SJE-V11, SJE-\f12, SJE-V13, SJE-V15, and SJE-V17 have a remote opening maximum full stroke of 85%.If these valves must be operated manually, I&C should be contacted to ensure the disk and disk guides remain aligOned.This will require stroking the valve closed after it is opened.120P-30 Rev.79 Page 14 of 123/

(----"\5.2.2;Procedural Steps NOTE: Each off-gas train is designed for 100%capacity.Dual train operation can initiate HWC System trips during plant power changes.1.ENSURE the following Condensate System valves are open.a.SJAE A(B)INTERCNDSR COND OUTLET D VALVE, CO-V15(V17)

b.AFTER CNDSR A(B)COND OUTLET VALVE, D CO-V181(V182)

c.SPE A(B)COND INL VALVE, CO-V14(V16)

D 2.DEPRESS OFFGAS TRAIN A (B)MASTER SWITCH, D OG-CS-4290(4330), OFF/RESET push button to reset Offgas Train A(B)logic.3.PLACE Off-Gas Train A(B)in preheat mode as follows: a.DEPRESS OFFGAS TRAIN A (B)MASTER SWITCH, OG-CS-4290(4330), PREHEAT push button AND ENSURE the PREHEA TER 2A(2B)HEATING STEAM INLET VALVE, SJE-V15(V17)

opens.D 120P-30 Rev.79 Page 15 of 1231 5.2.2 Procedural Steps b.OPEN PREHEA TER A(B)COND DRAIN BYPASS 0 VALVE, OG-SV-4265(4305), to drain condensation and to aid heat-up of preheater as necessary.

c.ENSURE PRE-HEATER COND LEVEL HIGH 0 alarm UA-44 6-2(UA-45 6-2)is clear.d.CLOSE PREHEATER A(B)COND DRAIN 0 BYPASS VALVE, OG-SV-4265(4305).

4.ENSURE Off-Gas H;/02 ANAL YZER, OG-AIT-4284, in service as follows: a.b.c.DEPRESS the STREAM push button, AND THEN DEPRESS the DISPLA Y push button on OG-AIT-4284 keyboard.IF the keyboard display indicates RUN, THEN GO TO Step 5.2.2.5.IF the keyboard display indicates HOLD or CAL, THEN PLACE the analyzer in service in accordance with Section 5.3.o o o 1 20P-30 Rev.79 Page 16 of 1231 5.2.2 Procedural Steps 5.ENSURE Off-Gas H;/02 ANAL YZER, OG-AIT-4324, in service as follows: a.DEPRESS the STREAM push button AND THEN DEPRESS the DISPLA Y push button on OG-AIT-4324 keyboard.o b.IF the keyboard display indicates RUN, THEN GO TO Step 5.2.2.6.o c.IF the keyboard display indicates HOLD or CAL, THEN PLACE the analyzer in service in accordance with Section 5.3.o Operatiofl'

of one in the warrrr-up With ffie in will cause erroneoUs SJAE aclivity due to;;ample fJow dilution from the opening of the idle SJAE Sample and shou'ld 5e mitiimized.

6.PLACE Off-Gas Train 2A(2B)in warm-up mode as follows: NOTE: Green permissive light for off-gas train will NOT be on if: 1.Steam packing exhauster condensate inlet valve is NOT open.2.After condenser cooling condensate outlet valve is NOT open.3.Preheater steam inlet temperature is less than 325°F.4.Recombiner catalyst bed temperature is less than 300°F.5.Motive steam pressure is less than 50 psig.a.ENSURE Off-Gas Train 2A(2B)green PERMISSIVE light is on.o 1 2 0P-30 Rev.79 Page 17 of 1231 5.2.2 Procedural Steps b.DEPRESS OFFGAS TRAIN A(B)MASTER SWITCH, OG-CS-4290(4330), WARM-UP push button AND ENSURE the following:

o SJAE 2A(2B)STEAM ISOLATION VALVE, 0 SJE-V2(V1)

, opens.OFF-GAS TRAIN 2A(2B)OUTLET VAL VE, 0 HTOG-V2(V4), opens.NOTE: Temperature indicators PREHEATER OUTLET TEMP, OG-Tl-4279(4319), and RECOMBINER OUTLET TEMP, OG-Tl-4281(4321), should show an increase in temperature during warm-up.NOTE: IF restoring to two SJAEs in 1/2 load from one SJAE in full load, an AOG bypass may occur due to moisture build up in the H 2/0 2 analyzers.

7.PLACE Off-Gas Train A(B)in half load mode as follows: a.DEPRESS OFFGAS TRAIN A(B)MASTER SWITCH, OG-CS-4290(4330), HALF LOAD push button AND ENSURE the following:

o SJAE 2A(2B)FIRST STAGE A EJECTOR 0 STEAM INLET VALVE, SJE-V10(V12), opens.SJAE 2A(2B)FIRST STAGE A EJECTOR 0 OFF-GAS INLET VALVE, OG-V11(V13), opens.WHEN 1 minute has elapsed, THEN 0 SJAE 2A(2B)CONDENSA TE DRAIN VALVE, MVD-V55(V56), opens.120P-30 Rev.79 Page 18 of 1231

  • 5.2.2 Procedural Steps Aftercondenser condensate level is NOT 0 pegged up-scale.Intercondenser condensate level is 0 on-scale and decreasing.

SJAE second stage discharge pressure 0 indicates between 0.5 and 1.5 psig.8.NOTIFY E&RC Chemistry that SJAE A(B)has been 0 placed in service, AND to track the requirements of Technical Specification SR 3.7.5.1.9.CHECK SJAE OFF GAS RAD MONITORS A and B, 0 D12-RM-K601A and D12-RM-K601B, AND NOTIFY Chemistry to sample within four hours following a monitor reading increase of greater than or equal to 50%without an accompanying increase in thermal power in accordance with Technical Specification SR 3.7.5.1.*10.IF a Mechanical Vacuum Pump is running, THEN PERFORM the following:

a.WHEN condenser vacuum reaches 23 inches Hg, 0 THEN STOP the Mechanical Vacuum Pump.b.PLACE CNDSR HOGGING VL V, OG-V7, control 0 switch in CLOSE.c.CLOSE the following demineralized water supply valves: DEMINERALIZED WATER SUPPL Y 0 VALVE TO RESERVOIR, MUD-V21 DEMINERALIZED WATER SUPPL Y 0 VALVE TO RESERVOIR, MUD-V22*120P-30 Rev.79 Page 19 of 1231 ((

8.2 Transferring Off-Gas Train 2A(2B)from Full Load to Half Load 8.2.1 Initial Conditions R Reference Use 1.2.Off-Gas Train 2A(2B)is in operation at full load.AO is available to respond to valve or breaker problems that could be encountered during the transfer.D D CAUTION.\IF HWC,is in servic.e, a short duration H2/02 concentration transient will O*Gur when transferring one.Off-Ga's train?peratiofl at fulJ load to two 9ft-Gas tr,9in operation at half load.This transient may cause HWC to trip due to eIther High or t:ow SJAE excess Oz*.or lowflow if there any off-gas problems durifl9 the transfer evolution.

...8.2.2 Procedural Steps 1.DEPRESS OFFGAS TRAIN A (B)MASTER SWITCH, OG-CS-4290(4330), HALF LOAD push button AND ENSURE the following valves close: o a.b.c.d.SJAE 2A(2B)SECOND STAGE B EJECTOR STEAM INLET VALVE, SJE-V11(V13)

SJAE 2A(2B)SECOND STAGE B EJECTOR OUTLET VALVE, HTOG-V1(V3)

SJAE 2A(2B)FIRST STAGE B EJECTOR STEAM INLET VALVE, SJE-V4(V3)

SJAE 2A(2B)FIRST STAGE B EJECTOR OFF GAS INLET VALVE, OG-V10(V12).

D o D o 1 20 P-30 Rev.79 Page 56 of 1231

  • 8.2.2 Procedural Steps NOTE: Off-Gas Train A(B)is now operating at half load.**2.3.CHECK SJAE OFF GAS RAD MONITORS A and B, D12-RM-K601A and D12-RM-K601B, AND NOTIFY E&RC to sample within four hours following a monitor reading increase of greater than or equal to 50%without an accompanying increase in thermal power in accordance with Technical Specification SR 3.7.5.1.ENSURE there is no significant change in condenser vacuum.o o 120P-30 Rev.79 Page 57 of 1231
  • Unit 2 APP A-05 1-4 Page 1 of 2 IRM DOWNSCALE AUTO ACTIONS 1.Rod withdrawal block (bypassed when IRM range switch for the affected channel is on Range 1 or when the reactor mode switch is in RUN).2.Computer printout.CAUSE 1.IRM channel(s)

indicating less than or equal to 6.5 on the 0-125 scale when its range switch is not on Range 1.2.Improper ranging of IRM channels during reactor startup or shutdown.3.IRM detector not fully inserted.4.IRM detector failure.5.Circuit malfunction.

OBSERVATIONS

  • l.2.3.4.ACTIONS IRM channel indicating less than or equal to 6.5 on the 0-125 scale.IRM downscale (DNSC)white indicating light is on.ROD OUT BLOCK (A-OS 2-2)alarm, if affected IRM channel is not on Range1.If the affected IRM channel(s)

is not on Range 1, the rod withdrawal permissive indicating light will be off.*1.Monitor IRM indications to determine affected channel(s).

2.If the affected IRM detector white In light is not on, attempt to fully insert the detector.3.Adjust the range switch for the affected IRM channel(s)

until the indication reads more than 6.5 on the 0-125 scale.4.If the alarm still exists, perform the following:

a.Refer to technical specifications for IRM channel operability requirements.

b.Notify the Unit seo.c.Bypass the affected IRM channel using the IRM bypass switch.....12APP-A-05 Rev.52 Page 10 of 941

  • Unit 2 APP A-05 1-4 Page 2 of 2 DEVICE/SETPOINTS Relay C51-Z2A-K90 IRM A, B, C, D, E, F, G, or H downscale trip unit POSSIBLE PLANT EFFECTS Deenergized 3.5-6.5 on a 0-125 scale**1.If an IRM channel is bypassed or inoperable, a technical specification LCO may result.REFERENCES 1.LL-9364-77 2.FP-5852-8 3.Technical Specification 3.3.1.1 4.APP A-05 2-2, ROD OUT BLOCK 12APP-A-05 Rev.52 Page 11 of 941 (((
  • Unit 2 APP A-OS 2-2 Page 1 of 2 ROD OUT BLOCK AUTO ACTIONS 1.Rod withdrawal prohibited.

CAUSE l.2.3.4.5.6.7.8.9.10.ll.*12.13.14.15.16.17.18.South SDV not drained.North SDV not drained.SRM downscale and any IRM is below Range 3.IRM downscale and affected IRM channel is not on Range 1.SRM upscale/inoperative and any IRM channel is below Range 8.IRM upscale aqd the reactor system mode switch is not in the RUN position.IRM A upscale/inoperative and the reactor system mode switch is not in the RUN position.SRM detector not fully inserted and log count rate is less than or equal to 100 cps (bypassed when all IRM channels are above Range 2 or the reactor system mode switch is in the RUN position).IRM B upscale/inoperative and the reactor system mode switch is not in the RUN position.APRM downscale and the reactor system mode switch is in the RUN position.APRM UPSCALE alarm.APRM UPSCALE TRIP/INOP alarm.Less than 17 LPRM inputs to any APRM or less than 3 LPRMs per axial level for any APRM.RBM downscale and reactor system mode switch is in the RUN position.RBM upscale/inoperative.

Recirc flow signal to any APRM greater than or equal to 110%.Discharge Volume Hi Water Level Trip Bypass switch in Bypass with the Reactor System Mode Switch in Shutdown or Refuel.Reactor System Mode Switch in Refuel with a second rod selected and another rod not full in./NOTE: The Service Platform has been removed.Associated refuel interlocks are non-functional, but available.

Reactor System Mode Switch in Startup AND the refuel bridge is over the core OR the service platform is loaded.Reactor System Mode Switch in Refuel with the service platform loaded.Reactor System Mode Switch in Refuel with the refuel bridge over the core AND the grapple loaded OR not full up.Reactor System Mode Switch in Refuel with the refuel bridge over the core AND any refuel bridge hoist loaded.No power to the refuel bridge.Reactor System Mode Switch in Shutdown.Any IRM detector not fully inserted and the reactor mode switch is not in RUN.Circuit malfunction.

19.20.2l.22.23.24.

25.*26.!2APP-A-05 Rev.52 Page 20 of 941

    • Unit 2 APP A-OS 2-2 Page 2 of 2 OBSERVATIONS 1.Selected rod will not withdraw.2.Rod withdraw permissive light is off.3.SOUTH SDV NOT DRND (A-OS 1-1)alarm.4.NORTH SDV NOT DRND (A-OS 2-S)alarm.S.SRM DOWNSCALE (A-OS 1-3)alarm.6.IRM DOWNSCALE (A-OS 1-4)alarm.7.SRM UPSCALE/INOP (A-OS 2-3)alarm.8.IRM UPSCALE (A-OS 2-4)alarm.9.IRM A UPSCALE/INOP (A-OS 3-4)alarm.10.SRM DET RETRACT NOT PERMITTED (A-OS 4-3)alarm.11.IRM B UPSCALE/INOP (A-OS 4-4)alarm.12.APRM DOWNSCALE (A-06 2-7)alarm.13.APRM UPSCALE (A-06 2-8)alarm.14.APRM TROUBLE (A-06 3-7)alarm.IS.APRM UPSCALE TRIP/INOP (A-06 3-8)alarm.16.RBM DOWNSCALE/TROUBLE (A-06 4-7)alarm.17.RBM UPSC/INOP (A-06 4-8)alarm.18.FLOW REF OFF NORMAL (A-06 S-7)alarm.ACTIONS 1.Refer to appropriate Annunciator procedure listed in OBSERVATIONS

.2.Verify proper position of the Discharge Volume Hi Water Level Trip Bypass switch, refer to APP A-OS I-S.3.Verify proper positioning of the refueling equipment and power supplies.DEVICE/SETPOINTS Rod Out Block Relays C12A-Kl or C12A-K2 POSSIBLE PLANT EFFECTS Deenergized 1.Control rods may not be withdrawn from the core while the rod block is in effect.REFERENCES 1.LL-9364-74 2.FP-S0012-6*12APP-A-05 Rev.52 Page 21 of 941

  • 6-1*CRD ACCUM LO PRESS/HI LEVEL Page 1 of 1 1.0 OPERATOR ACTIONS: 1.1 CONFIRM which CRD is causing the annunciator by observation of the amber light on the affected HCU on the Full Core Display.1.2 OBSERVE Automatic Functions:

1.2.1 At the local CRD HCU Panel, the red indication light is ON for the affected HCU.1.3 PERFORM Corrective Actions: NOTE: Accumulator pressure less than 940 psig will render the accumulator inoperable.

NOTE: IF this annunciator is sealed in, THEN the other accumulator alarms will be masked, AND contingency plans should be made to monitor the other accumulator alarms at the discretion of the Unit SCO.1.3.1 DETERMINE if alarm is due to low pressure or high water level in the HCU by depressing the lighted indication on the local HCU panel and observing the status of the light (light out indicates water).1.3.2 IF nitrogen pressure is low, THEN CHARGE the accumulator per 20P-08, CRD Hydraulic System Operating Procedure.

1.3.3 IF alarm is due to high water level, THEN DRAIN the accumulator per 20P-08, CRD Hydraulic System Operating Procedure.

2.0 CAUSES: 2.1 Leaking accumulator rings.2.2 Low nitrogen charge pressure.3.0 DEVICES: 3.1 Level Switch C12-LDSH-129 (Each HCU)3.2 Pressure Switch C12-PSL-130 (Each HCU)SETPOINT: 60 cc 955 psig 4.0 REFERENCES:

4.1 LL-9364-98 4.2 Technical Specification 3.1.5 4.3 20P-08, Control Rod Drive Hydraulic System Operating Procedure*12APP-A-07 Rev.31 Page 38 of 451

  • Unit 2 APP-UA-02 2-5 Page 1 of 2 STM PACKING EXHAUSTER B OVLD TRIP AUTO ACTIONS 1.Steam Packing Exhauster B trips.2.Steam Packing Exhauster B discharge valve closes.CAUSE 1.Steam Packing Exhauster B overload due to: a.Discharge valve open too far.b.Impeller rubbing.c.Bearing damaged.d.Motor winding faulty.e.Impeller flooded due to tube leaks in heat exchanger.

f.Insufficient sealing steam to turbine.g.Operation with excessive steam seal header pressure.h.Insufficient condensate flow resulting in steam/moisture in exhauster.

2.Circuit malfunction.

OBSERVATIONS

  • 1.2.3.4.5.ACTIONS Steam packing exhauster suction header vacuum on OG-PI-EPT9 below normal (10 inches H20).Exhauster discharge valve closed indication.

Main condenser vacuum is decreasing.

Off-gas flow increasing.

Steam seal header pressure high.1.Start Steam Packing Exhauster A and verify that its suction valve opens per 20P-26.1.2.Adjust the Steam Packing Exhauster A discharge valve to maintain the vacuum on OG-PI-EPT9 at 10 inches H20.3.Reset SPE B and verify that the loop seal is drained.4.If steam seal header pressure is above 7 psig, check the Steam Seal Feed Valve MS-SSFV operating correctly as follows: a.Throttle closed, Mn Steam to Seals Vlv MVD-S1 to restore steam seal header pressure between 1.5 and 4.0 psig.b.If throttling the MVD-S1 was successful in restoring steam seal header pressure, then bypass the Steam Seal Feed Valve per 20P-26.1 Section 8.3.c.If throttling the MVD-S1 was not successful then reopen MVD-S1 and bypass the Steam Seal Unloading valve by throttling open Steam Seal Bypass Unload Vlv, MVD-B.5.If moisture is suspected in Steam Packing Exhauster instrument lines, drain per 20P-26.1 Section 8.2.*1 2 APP-UA-02 Rev.33 Page 29 of 921

  • Unit 2 APP-UA-02 2-5 Page 2 of 2 DEVICEjSETPOINTS Overload device 49 in breaker 480V MCC 2TD Compartment CM5 POSSIBLE PLANT EFFECTS Thermal overload*1.If the turbine gland seals are lost, the Turbine Building may become an airborne radiation area.2.Turbine trip due to low condenser vacuum.3.If the turbine gland sealing vacuum is lost, water vapor may be entering the main lube oil system through the shaft oil deflectors.

REFERENCES 1.LL-9353-15 2.20P-26.1, Turbine Gland Sealing Steam System*1 2APP-UA-02 Rev.33 Page 30 of 921 (((

  • Unit 2 APP-UA-02 4-5 Page 1 of 2 GLAND SEAL VACUUM LOSS AUTO ACTIONS NONE CAUSE 1.Steam packing exhauster not operating.

2.Steam packing exhauster suction/discharge valve throttled closed, so gland seal vacuum cannot be maintained.

3.Tube leaks in gland exhauster condenser.

4.Steam Seal Feed Valve or the Steam Packing Unloading valves are not controlling steam seal header pressure correctly.

5.Insufficient condensate flow through toe steam packing exhauster.

6.Circuit malfunction.

OBSERVATIONS

  • 1.Gland seal vacuum on OG-PI-EPT9-SPE below 5 inches of water.2.Main condenser vacuum decreasing.

3.Increased off-gas flow.4.Steam seal header pressure high.*ACTIONS 1.2.3.4.5.Start standby exhauster and adjust its discharge valve to maintain vacuum between 10 and 20 inches H 2 0 per 20P-26.1.If gland seal regulator is not operating properly, refer to 2APP-UA-02 3-5, STEAM SEAL REGULATOR PRESS-LOW.

Drain the loop seals on the in-service steam packing exhauster.

If steam seal header pressure is above 7 psig, check the Steam Seal Feed Valve MS-SSFV operating correctly as follows: a.Throttle closed, Mn Steam to Seals Vlv MVD-S1 to restore steam seal header pressure between 1.5 and 4.0 psig.b.If throttling the MVD-S1 was successful in restoring steam seal header pressure, then bypass the Steam Seal Feed Valve per 20P-26.1 Section 8.3.c.If throttling the MVD-S1 was not successful then reopen MVD-S1 and bypass the Steam Seal Unloading Valve by throttling open Steam Seal Bypass Unload Vlv, MVD-B.If moisture is suspected in Steam Packing Exhauster instrument lines, drain per 20P-26.1 Section 8.2.*DEVICE/SETPOINTS Pressure Switch OG-PS-VS-SPE 12APP-UA-02 Rev.33 5 inches of water.J:age 55 of 921

  • POSSIBLE PLANT EFFECTS Unit 2 APP-UA-02 4-5 Page 2 of 2*l.If the turbine gland sealing vacuum is lost, radioactive steam may be released to the Turbine Building atmosphere.

2.If the turbine gland sealing vacuum is lost, water vapor may be entering the main lube oil system through the shaft oil deflectors.

REFERENCES 1.LL-9353-15 Rev.6 2.20P-26.1, Turbine Gland and Seal System 3.2APP-UA-02 3-5, STEAM SEAL REGULATOR PRESS-LOW*12APp-UA-02 Rev.33 Page 56 of 921 (((

  • 8.0 INFREQUENT OPERATIONS R Reference Use 8.1 Shifting Steam Packing Exhausters 8.1.1 Initial Conditions 1.Gland Sealing Steam System is in operation in D accordance with Section 5.1.8.1.2 Procedural Steps 1.IF STEAM PACKING EXHAUSTER, SPE A, is operating, THEN PERFORM the following:

a.OPEN FLOAT TRAP OUTLET VALVE, MVD-V52.D b.START STEAM PACKING EXHAUSTER, SPE 8.D c.ENSURE STEAM SEAL SPE 28 MO INLET VL V, D OG-MOV-E2, is open.d.THROTTLE CLOSED STEAM SEAL SPE 2A MO D*DISCH VLV, OG-MOV-D1, AND THROTTLE OPEN STEAM SEAL SPE 28 MO DISCH VL V, OG-MOV-D2, while maintaining GLAND EXHAUST HEADER, OG-PI-EPT-9, located on Panel XU-2, between 10 and 20 inches water vacuum.e.ENSURE STEAM SEAL SPE 2A MO DISCH VL V, D OG-MOV-D1, is closed.f.STOP STEAM PACKING EXHAUSTER, SPE A.D g.CLOSE FLOAT TRAP OUTLET VALVE, MVD-V51.D h.ENSURE STEAM SEAL SPE 2A MO INLET VAL VE, D OG-MOV-E1, is closed.*120P-26.1 Rev.37 Page 13 of 281

  • 8.1.2 Procedural Steps 2.IF STEAM PACKING EXHAUSTER, SPE 8, is operating, THEN PERFORM the following:

a.OPEN FLOAT TRAP OUTLET VALVE, MVD-V51.D b.START STEAM PACKING EXHAUSTER, SPE A.D c.ENSURE STEAM SEAL SPE 2A MO INLET VL V, D OG-MOV-E1.

is open.d.THROTTLE CLOSED STEAM SEAL SPE 28 MO D DISCH VL V, OG-MOV-D2.

AND THROTTLE OPEN STEAM SEAL SPE 2A MO DISCH VL V, OG-MOV-D1.

while maintaining GLAND EXHAUST HEADER, OG-PI-EPT-9.

located on Panel XU-2, between 10 and 20 inches water vacuum.e.ENSURE STEAM SEAL SPE 28 MO DISCH VL V, D OG-MOV-D2, is closed.f.STOP STEAM PACKING EXHAUSTER, SPE 8.0*g.CLOSE FL OA T TRAP OUTLET VAL VE.MVD-V52.0 h.ENSURE STEAM SEAL SPE 28 MO INLET VAL VE, 0 OG-MOV-E2.

is closed.*120P-26.1 Rev.37 Page 14 of 281

  • Unit 2 APP UA-28 6-4 Page 1 of 1 SEISMIC EVENT AUTO ACTIONS 1.Magnetic tape recording starts and records the output of the Triaxial Time-History Accelerographs, 2-ENV-XT-823-1 (Reactor Building-North Core Spray Room-El.-17')

and 2-ENV-XT-823-2 (Reactor BUilding-Northwest side of drywell-El.89'4").

2.The Direct-Write Recording System starts and records the output of the selected triaxial time-history accelerograph (2-ENV-XT-823-1 is normally selected).CAUSE 1.Earthquake.

2.Any other event which exceeds a seismic intensity of 0.01 g horizontal acceleration.

3.Circuit malfunction.

OBSERVATIONS

  • 1.2.3.ACTIONS All seismic recorders start.Event alarm light is on for the strong motion accelerograph panel.Event indicator for the strong motion accelerograph panel is black prior to an event and white after an event.1.If possible, then contact the National Earthquake Center at 1-303-273-8500 to confirm the event.2.If an earthquake has occurred, then refer to AOP-13.0, Operation During Hurricane, Flood Conditions, Tornado, or Earthquake.

3.If a circuit or equipment malfunction is suspected, ensure that a WR/JO is prepared.DEVICE/SETPOINTS Seismic Recorder ENV-XR-823 POSSIBLE PLANT EFFECTS 1.Unit shutdown and major damage.REFERENCES Both horizontal and vertical starters set at 0.01 g*1.2.3.9527-LL-9365-11 FSAR Section 2.0 AOP-13.0, Operation During Hurricane, Flood Conditions, Tornado, or Earthquake

\2APP-UA-28 Rev.47 Page 73 of 80 I (c (

  • 3.0 OPERATOR ACTIONS 3.2.2 IF an Earthquake has occurred, THEN PERFORM the following:

1.DISPATCH an operator to determine the earthquake acceleration in accordance with Attachment 4.o*2.CHECK the following plant parameters to provide a quick check on the status of the units:-Reactor Power-Reactor Pressure-Reactor Level-Area Radiation Monitors j-Feedwater Flow-Generator Load-Condenser Vacuum-Turbine Vibration and Bearing Temperature.

3.CHECK the following for changes which may indicate core shroud movement at the top guide support ring reinforcing brackets::-

D'o o o o o o o Rising suction temperature in one or both recirculation loops.., Flux variations (determinedbythe Nuclear Engineer)....PowerlFlow relationship

/o o o 4.CHECK the following for indications of power losses:*IOAOP-13.0 5.-Electrical Distribution System-Switchyard Grid System CHECK all annunciator panels (including local panels)for indications of abnormal conditions

.Rev.37 t o o D D Page 6 of 40 I

  • 3.0 OPERATOR ACTIONS 6.CHECK the following systems for indications of abnormal conditions:

-Main Steam Leak Detection 0-RWCU System Leak Detection 0-RCIC System Leak Detection 0 HPCI System Leak Detection 0-RHR System Leak Detection 0-ADS Leak Detection 0-Radwaste Equipment Area Leak Detection 0 I.f-Reactor Recirculation Pump Leak Detection.

0 7.CONFIRM the occurrence of the seismiceventby 0 contacting the National Earthquake Center at*1-303-273-8500.

8.I IF the plant can NOT operate in a safe condition OR the acceleration exceeded 0.08g during a confirmed earthquake, THEN tNITIATE the following:-A controlled shutdown of both units in accordance

<, with OGP-05./o.,-An LCO for secondary containment integrity in 0 accordance with 001-01.08, due to possible link seal failure-A WO to inspect the core shroud in the area of the 0 core shroud brackets for evidence of shifting or movement., IOAOP-13.0 Rev.37 10.INITIATE a plan to inspect all plant equipment AND evaluate damage as soon as practical.

o o Page 7 of 40 I

    • 3.0 OPERATOR ACTIONS 11.IF damage is suspected on any system, THEN D PERFORM the appropriate testing to ensure operability as soon as practical.

12.IF a seismic event is confirmed, THEN INITIATE a WO to remove the record plates from the peak shock recorders so that they may be forwarded to the vendor for evaluation (reference TRM 3.9 condition A and bases):-OMST-SEIS21 R (after 5 days and within 10 days of D the event).-2MST-SEIS22R (after 5 days and within 10 days of D the event).13.IF Control Room Air Conditioning Units are NOT D 4ailable AND Control Room temperature is greater than or equal to 104°F, THEN EXECUTE compensatory actions in accordance with Attachment5././*IOAOP-13.0

,.Rev.37 Page 8 of 40 I ((

  • 7.0 SHUTDOWN c Continuous Use Diesel Generator No.7.1 Diesel Generator Shutdown 7.1.1 Initial Conditions 1.All applicable prerequisites as listed in Section 4.0 are 0 met.2.The diesel generator has automatically started AND: a.It is no longer required to supply electrical power, 0 OR b.The automatic start signal is NOT a valid signal.0 OR 3.The diesel generator was manually started AND is no 0*longer required to supply electrical power.The diesel generator output breaker is open in 0 4.accordance with OOP-50.1.7.1.2 Procedural Steps 1.IF the diesel generator is in the AUTO start mode AND 0 the auto start signal is clear OR the diesel generator was started locally AND is to be shut down from the Control Room, THEN DEPRESS CONTROL ROOM MANUAL push button located on Panel XU-2.2.IF it is desired to shut down the diesel generator from the 0 local Engine Control Panel, THEN DEPRESS LOCAL MANUAL push button located on Panel XU-2.3.OBSERVE governor oil level is between high and low 0 marks on governor oil sight glass.*IOOP-39 Rev.116 Page 28 of 230 I
  • 7.1.2 Procedural Steps 4.RUN diesel engine unloaded (idle)until all of the diesel D generator cylinder exhaust temperatures are less than 500°F.5.RUN diesel engine unloaded (idle)for an additional D 5 minutes for engine cooldown.6.PLACE the AUX LUBE OIL PUMP control switch in D HAND to prevent pump cycling during engine cooldown.7.PLACE MANUAL STOP START switch located on Panel D XU-2 OR ENGINE LOCAL START STOP switch located on Engine Control Panel in STOP.8.RECORD the time the diesel generator engine was D stopped.Time 9.CONFIRM locally the following automatic operations
  • occur: JACKET WATER COOLER SERVICE WATER D a.INLET VALVES, 1 (2)-SW-V679 (V680, V681, V682), close or are closed.b.FUEL OIL BOOSTER PUMP stops.D c.JACKET WA TER PUMP starts.D 10.CONFIRM the field shorting device (17-Device), located D in the rear lower left section of the Excitation Control Cubicle, is in the RESET position by observing the contacts labeled NO AUX (Normally open auxiliary contacts)are closed and the NC AUX (Normally closed auxiliary contacts)are open.11.RESET the flags on the diesel generator output breaker.D*IOOP-39 Rev.116 Page 29 of 230 I
  • 7.1.2 Procedural Steps 12.ENSURE the following valves are in the indicated position: a.LUBE OIL AUTOMA TIC-THERMOSTATIC 0 TEMPERA TURE CONTROL VALVE, LO-TCV-1463 (2054, 2077, 2100)b.JACKET WA TER-THERMOSTATIC 0 COOLER OUTLET AUTOMATIC TEMPERA TURE CONTROL VAL VE, MUD-TCV-2129 (2155, 2183, 2210)c.TEMPERA TURE-Closed 0 CONTROL VAL VE BYPASS VALVE,*MUD-V160 (V196, V232, V268)IR291 d.DG#1 JACKET WA TER**Throttled Open 0 COOLER SERVICE and Locked WA TER OUTLET VAL VE, 2-SW-V206 I R29 1 e.DG#2 JACKET WA TER**Throttled Open 0 COOLER SERVICE and Locked WA TER OUTLET VAL VE, 2-SW-V207 IR291 f.DG#3 JACKET WATER**Throttled Open 0 COOLER SERVICE and Locked WATER OUTLET VAL VE, 2-SW-V208 I R291**2%turns open from full closed position after handwheel engages gears.*IOOP-39 Rev.116 Page 30 of 230 I
  • 7.1.2 Procedural Steps IR2 9 1 g.DG#4 JACKET WATER*"Throttled Open 0 COOLER SERVICE and Locked WA TER OUTLET VALVE,2-SW-V209 13.PERFORM Steps 5.1.2.7.b through 5.1.2.16, AND 0 RETURN TO Step 7.1.2.14.14.IF any of the following conditions exist, THEN FILL the Diesel4-Day Tank in accordance with Section 8.6, a.The associated 4-Day Tank Annunciator FUEL 0 STORAGE TANK LEVEL LOW, UA-19 (20,21, 22)3-2, is in alarm.b.The Engine-Mounted Day Tank is less than 9/16 0 full.c.The Engine-Mounted Day Tank was filled 0 manually or automatically during this procedure.*15.Approximately 20 minutes after the diesel generator 0 engine has been shutdown (time recorded in Step 7.1.2.8), PLACE the AUX LUBE OIL PUMP control switch in AUTO.IR281 16.IF the diesel generator operated more than one hour OR 0 IF fuel oil was added to the 4-Day fuel Oil Storage Tank from the Main (7-day)Fuel Oil Storage Tank, THEN NOTIFY E&RC to sample the Saddle Tank AND Four-day Tank fuel oil in accordance with E&RC-1010.

17.MAKE an entry in the Control Operator's log that the 0 diesel generator has been placed in the standby mode.I R291**2Y.o turns open from full closed position after handwheel engages gears.*IOOP-39 Rev.116 Page 31 of 230 I

  • 7.1.2 Procedural Steps 18.WHEN approximately 20 minutes have elapsed, THEN CONFIRM the following automatic operations:

a.JACKET WATER PUMP stops.0 b.AUXILIARY LUBE OIL PUMP stops.0 c.CRANKCASE VACUUM pump stops.0 d.JACKET WA TER HEA TER PUMP starts.0 e.JACKET WA TER HEA TER starts.0 f.LUBE OIL FIL TER AND PRELUBE FLOW 0 CONTROL VAL VE is in the 5/8 OPEN position (solenoid valve energized)

which directs oil flow to the engine.g.LUBE OIL FIL TER HEA TER starts.0*19.PERFORM Attachment 4.0*IOOP-39 Rev.116 Page 32 of 230 I STEPS RC/O-08 through RC/O-10 CAN REACTOR POWER BE DETERMINED TO BE LESS THAN 2%STEP BASES: NO RC1Q*08 RClQ*10 If reactor power is above 2%, the operator is directed to inject boron.This is a conservative action because with power above 2%, Suppression Pool temperature will steadily increase towards 110°F.This also allows sufficient time for the Hot Shutdown Boron Weight of boron to be injected.The extra time may be needed since thealternatesystems used for boron injection require significantly more time to inject boron should the SLC System fail.The SLC system is initiated to shut down the reactor.As long as the core remains submerged (the preferred method of core cooling), fuel integrityandreactor vessel integrity are not directly challenged even under scram conditions.

A scram failure coupled with an MSIV isolation; however, results in rapid heatup of the Suppression Pool due to the steam discharged from the reactor vessel via SRVs.The challenge to containment thus becomes the limiting factor which defines the requirement for boron injection.

If Suppression Pool temperature and reactor pressure cannot be maintained below the Heat Capacity Temperature Limit, rapid depressurization of the reactor vessel will be required.To avoid depressurizing the reactor vessel with the reactor at power, it is desirable to shut down the reactor prior to reaching the Heat Capacity Temperature Limit, thus minimizing the quantity of heat rejected to the Suppression Pool.The Boron Injection Initiation Temperature is defined so as to achieve this when practicable.

1 00 1-37.5 Rev.8 Page 81 of 90 I

    • STEPS RCtO-08 through RCtO-1 0 (continued)

The Boron Injection Initiation Temperature is defined to be the greater of: a.The Suppression Pool temperature at which initiation of a reactor scram is required by Technical Specifications, or b.The highest Suppression Pool temperature at which initiation of boron injection using SLC will result in injection of the Hot Shutdown Boron Weight of boron before Suppression Pool temperature exceeds the Heat Capacity Temperature Limit.Criterionb is a function of reactor power;a higher reactor power level causes higher integrated heat energy to be rejected to the Suppression Pool thus requiring a lower Suppression Pool temperature for initiation of boron injection if theHeatCapacity Temperature Limit is not to be exceeded before reactor shut down is achieved.At Brunswick, a single value is used for Boron Injection Initiation Temperature (110°F)for procedure simplification

.*1001-37.5 Rev.8 Page 82 of 90 I

  • STEP RC/Q-15 STEP BASES: Concurrent execution of this step with the remainder of this procedure optimizes efforts to achieve reactor shutdown.EOP-01-LEP-02 (Alternate Control Rod Insertion)

addresses alternate methods of control rod insertion.

Reactor shutdown on control rod insertion alone is preferable to injecting boron for the following reasons: a.Boron injection contaminates the primary system, requiring extensive cleanup and subsequent inspection before continued plant operation is possible.b.If a leak occurs below the elevation of the reactor water level being maintained, boron injection may not be successful in shutting down the reactor.c.A reactor shutdown on boron is not necessarily a stable condition; if boron is subsequently diluted or displaced by a leak or an operational error, the reactor could return to criticality.

Several alternate methods forinsertingcontrol rods are presented in EOP-01-LEP-02.

See the Step Discussions for EOP-01-LEP-02 for a detailed discussion of these methods.*1001-37.5 Rev.8 Page 87 of 90 I

  • Feedwater Level Control Following a Reactor Scram-Reactor Feed Pump Startup NOTE: This attachment is NOT to be used for routine system operation.

FEEDWATER LEVEL CONTROL FOLLOWING A REACTOR SCRAM 1.2.3.4.5.DISPA TCH AN OPERATOR TO RFP A(B)TO RESPOND TO ANY LOCAL'ANNUNCIATOR PANEL ALARMS.PLACE FEEDWATER CONTROL MODE SELECT TO 1 ELEM.ENSURE FW-FV-177IS CLOSED.OPEN4FW-V10.

  • i IF BOTH RFPs HAVE TRIPPED, THEN ENSURE MSTR RFPT SP/RX LVL CTL, C32-SIC-R600, IN M (MANUAL).CLOSE FW-V6 AND FW-V8 (OR FW-V118 AND FW-V119).PLACE SULCV, FW-L1C-3269, IN M (MANUAL)AND CLOSE THE SULCV..ENSURE B21-FCl32A ANO B21-F032B*ARE OPEN.-.:.IF AN RFP IS RUNNING, THEN PLACE A (B)$P CTL,.C32-$JC-R601A (B), IN M (MANUAL)AND ADJUST RFP A (B)SPEED UNTIL DISCHARGE PRESSURE IS APPRGXIMA TEL Y NO PSI GREATER THAN REACTOR PRESSURE.10.ADJUST SULCV, FW-L1C-3269, FOR DESIREDREACTORWATER LEVEL.11.IF DESIRED, THEN PLACE SULCV, FW-L1C-3269, IN A (AUTO).12.ADJUST FW-FV-177 TO MAINTAIN SULCV, FW-L1C-3269, OUTPUT DEMAND SIGNAL BETWEEN 25%AND 55%.13.IF SULCV, FW-L1C-3269, FAILS TO CONTROL LEVEL, THEN USE ONE OR MORE OF THE FOLLOWING VALVES TO AID IN LEVEL CONTROL: FW-V120, (FW-V118 AND FW-V6), (FW-V119 AND FW-V8).*5-1266 (((
    • STEPS RC/P-40 and RC/P-41 I I TERMINATE AND PREVENT INJECTION TO THE REACTOR VESSEL FROM THE fOLLOWING SYSTEMS UNLESS THE SYSTEM IS BEING USED TO INJECT BORON:*CONOENSAT8FEEDWATER
  • HPCI*RHR*CORE SPRAY*ALTERNATE COOLANT\INJECTION SYSTEMS j I RCIP-40/WHEN INJECTION TO THE REACTOR VESSEL FROM THE SPECIFIED SYSTEMS HAS BEEN TERMINATED AND PREVENTED, RAPIDLY DEPRESSURIZE THE REACTOR IRRESPECTIVE OF RESULTING COOLOOWN RATE AS FOLLOWS I RCIP-41 v.--------

STEP BASES: Injection into the reactor vessel is terminated and prevented before Emergency Depressurization proceeds in order to prevent uncontrolled injection of large amount of cold water as reactor pressure decreases below the shutoff head of operating system pumps.Injection from boron injection systems and CRD is not terminated because operation of these systems may be needed to establish and maintain reactor shutdown.Further, the injection flow rates from these systems are small compared to those of the other systems used to control reactor water level.Injection from RCIC is not terminated because the injection flow rate from this system is small, continued operation of the turbine aids in depressuring the reactor vessel, and operation during reactor depressurization is not expected to result in significant injection flow rate variations.

Only when the listed systems have been terminated and prevented is emergency depressurization allowed.*1001-37.5 Rev.8 Page 66 of 90 I

  • STEPS RC/P-42 through RC/P-44 OPEN SEVEN ADS VALVES.RESTORE CONTINUOUS PNEUMATIC SUPPLY IF NECESSARY PER TABLE.RCIP-43 IF SEVEN ADS VALVES ARE NOT OPEN TABLE 4 SRV PNEUMATIC SUPPLY RESTORAnON REQUIRED SWITCH SWITCH PosmON OlV I NON-INTRPT OVERRIDE RNA-SV-5262 RESET OlV" NON-INTRPT OVERRIDE RNA-SV-5261 RESET*lliEN OPEN SRVs B.F.E OR G UNTIL SevEN VALVES ARE OPEN RClP-44 STEP BASES: The objective of these steps is to depressurize the reactor as rapidly as possible, yet within the limits of plant design.Two separate aspects must be considered in deciding how this is to be accomplished:

the means for releasing the energy from the reactor vessel and the capacity of the heat sink utilized to absorb this energy.Depressurization of the reactor is most easily and rapidly performed by opening SRVs;thus instructions for operation of these valves are specified first, in preference to steps directing the use of other depressurization systems and mechanisms.

Of the SRVs, those dedicated to the ADS function are generally the most reliable because of their qualifications, pneumatic supply systems, the design and operation of initiation circuitry, or the availability of control power.Additionally, the relative location of their discharge devices uniformly distributes the heat load around the Suppression Pool.Concurrent opening of all ADS valves is within analyzed plant design limits.Other steps in the EOPs provide instructions for maintaining sufficient Suppression Pool heat capacity to accommodate simultaneous opening of all ADS valves at any reactor pressure.If one or more ADS valves cannot be opened, other SRVs are then opened to effect the desired reactor depressurization until the total number of open SRVs equals 7 (number of SRVs dedicated to ADS).If a non-ADS SRV is stuck open, 7 ADS valves should be opened, resulting in a total of 8 open SRVs.This provides the requisite depressurization rate without exceeding any design criteria.*1001-37.5 Rev.8 Page 67 of 90 I

    • STEPS RC/P-42 through RC/P-44 (continued)

An SRV opening sequence is not specified in this step because of the desire to reduce reactor pressure as rapidly as possible.If Suppression Pool water level is below the top of the SRV discharge devices (-8 feet), opening an SRV will cause direct pressurization of the Suppression Chamber airspace.Since the extent of this pressurization cannot be predicted and may exceed the pressure capability of the Primary Containment, such operation is prohibited.

Guidance is provided for reestablishing the continuous pneumatic supply to the SRVs be defeating the Group 10 isolation of the system.Step RC/P-44 lists SRVs B, E, F, and G since these are the only non-ADS SRVs.Brunswick has a total of 11 SRVs per unit, 7 of which are dedicated to ADS.*1001-37.5 Rev.8 Page 68 of 90 I

(((
      • STEPS SC/L-1 and SC/L-2 sell SClL*1 MONITOR A NO CONTROL REA CTOR BLDG WATER LEVELS SClL*2 STEP BASES: The initial action taken to control reactor building water level employs the same method typically used duringnormalplant operations:

monitoring its status and placing available sump pumps in operation, as required, to control water level.Steps SC/L-1 and SC/L-2 thus provide a smooth transition from general plant procedures to Emergency Operating Procedures and assures that the normal method of reactor building water level control is attempted in advance of initiating more complex actions to control reactor building water levels.1001-37.9 Rev.0 Page 26 of 391 STEP SC/L-4 MAX NORM NO TABLE 4 AREA WATER LEVEL LIMITS YES PlANT MAX NORII MAX SAFE AREA OPERATING OPERATING VALUE (NOTE 1)VALUE (NOTE 2)(INCHES)(INCHES)N CORE SPRAY 6 12 SCORE SPRAY 6 12 N RHR 6 12 S RHR 6 12 HPCI 6 12 NOTE 1: RIA flOOD LEVEL HI ANNUNCIATOR INDICATES 6 INCHES WATER LEVEL NOTE 2: Rill FLOOD LEVEL H.-HI ANNUNCIATOR INDICATES 12 INCHES MTER LEVEL 1001-37.9 Rev.0 Page 28 of 391

      • STEP SC/L-4 (continued)

STEP BASES: This step is provided to direct the operator to the proper course of action.If the RM FLOOD LEVEL HI annunciators are not in alarm or locally o.",ed floor water levels.-"", are less than 6 inches (Maximum Normal Operating Water Level), then the operator continues to monitor these parameters.

If the water levels are above the Maximum Normal Operating Water Level, then further actions must be takentomitigate the consequences of the flooding, and to attempt to restore and maintain the area water level below the Maximum Normal Operating Water Level.If an area is accessible, then the area water level trend may be monitored more accurately

.1001-37.9 Rev.0 Page 29 of 391 STEPS SCCP-25 and SCCP-26 MORE THAN 1 ABOVE MAX SAFE or EQ.Ie STEP BASES: NO YES Et.ERGENCY DEPRESSURIZE lHE REACTOR PER THE RCIP SECTION OF EOP*01 SCCP-26 Should reactor building parameters exceed their maximum safe operating values in more than one area (exceeding the"E/Q envelope" in an area is equivalent to exceeding the maximum safe operating temperature in that area), the reactor must be depressurized to preclude further degradation of secondary containment conditions.

Emergency Depressurization places the primary system in its lowest possible energy state, rejects heat to the suppression pool in preference to outside the containment, and reduces the driving head and flow of primary systems that are unisolated and discharging into the Reactor Building.The criteria of more than one area specified in this step identifies the rise in reactor building parameters as a wide spread problem which may pose a direct and immediate threat to secondary containment integrity, equipment located in the Reactor Building, and continued safe operation of the plant.For high water level conditions, if a flooded area is not accessible, then the only indication that an area has reached it maximum safe operating water level is the RM FLOOD LEVEL HI-HI annunciators.

If more than one area has reached its HI-HI alarm point, then plant conditions have degraded to the point where Emergency Depressurization is needed.1001-37.9 Rev.0 Page 38 of 391 STEPS SCCP-25 and SCCP-26 (continuedl One parameter (e.g., temperature)

above its maximum safe operating value in one area and a different parameter (e.g., radiation or water level)above its maximum safe operating value in the sameoranother area is not a condition which requires Emergency Qepressurization.

A combination of parameters exceeding maximum safe operating values in one area does not necessarily indicate that control of a given parameter cannot be maintained or that previous actions have not been effective in confining the trouble to one area.Expanding the application of more than one area to encompass multiple parameters might lead to depressurization of the reactor when such action is not appropriate or needed.If the maximum safe operating radiation level is exceeded in an area (within the E/Q envelope)and then later clears, and is subsequently followed by another area exceeding maximum safe operating radiation level, action for one area exceeding maximum safe operating radiation level should be taken.If the maximum safe operating temperature is exceeded in an area and then later clears, and is subsequently followed by another area exceeding maximum safe operating temperature, action for two areas exceeding maximum safe operating temperature should be taken.If the maximum safe operating water level is exceeded in an area and then later clears, and is subsequently followed by another area exceeding maximum safe operating water level, action for two areas exceeding maximum safe operating water level should be taken.1001-37.9 Rev.0 Page 39 of 391

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