ML022050831
| ML022050831 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/02/2002 |
| From: | Susquehanna |
| To: | Document Control Desk, Office of Nuclear Security and Incident Response |
| References | |
| Download: ML022050831 (70) | |
Text
Jul. 02, 2002 Page 1 of 1 MANUAL HARD COPY DISTRIBUTION DOCUMENT TRANSMITTAL 2002-319/8 USER INFORMATION:
FT LuREL B EMPL#:23244 CA#: 0386 Phone#: 254-3658 TRANSMITTAL INFORMATION:
TO.. FLAIii LAUR!EL D 07/02/2002 LOCATION: DOCUMENT CONTROL DESK FROM: NUCLEAR RECORDS DOCUMENT CONTROL CENTER
'NUCSA-2)
.HE FOLLOWING CHANGES HAVE OCCURRED TO THE HARDCOPY OR ELECTRONIC MANUAL ASSIGNED TO YOU:
126 - 126 - CONTROL ROOM (CR) COMMUNICATOR REMOVE MANUAL TABLE OF CONTENTS DATE: 05/08/2002 ADD MANUAL TABLE OF CONTENTS DATE: 07/01/2002 CATEGORY: PROCEDURES TYPE: EP ID: EP-PS-126 ADD: PCAF 2002-1441 REV: N/A UPDATES FOR HARD COPY MANUALS WILL BE DISTRIBUTED WITHIN 5 DAYS IN ACCORDANCE WITH DEPARTMENT PROCEDURES. PLEASE MAKE ALL CHANGES AND ACKNOWLEDGE COMPLETE IN YOUR NIMS INBOX UPON RECEIPT OF HARD COPY. FOR ELECTRONIC MANUAL USERS, ELECTRONICALLY REVIEW THE APPROPRIATE DOCUMENTS AND ACKNOWLEDGE COMPLETE IN YOUR NIMS INBOX.
PROCEDURE CHANGE PROCESS FORM
- 4. FORMSREVISED - R , RR-, - - R-, - - R - - R
- 5. PROCEDURE TITLE CONTROL ROOM COMMUNICATOR: Emergency-Plan-Position-Specific Instruction
- 6. REQUESTED CHANGE PERIODIC REVIEW [ NO L- YES INCORPORATEPCAFS [ NO [I YES # # #
REVISION LI PCAF Z DELETION E] ( . ONLY)
- 7.
SUMMARY
OF/ REASON FOR CHANGE 'h4, i
- 1) Tab A: Changed "Assembly Area" to "Accountability Area" t I A
- 2) Tabi: New tab added to address Security threat or event con nicationr,§,,Asuiting from issuance of NRC order for "Interim Safeguards and Compensatory '4 #urSSES".
T' I:% !ii *,
.: .., .Continued I
- 8. DETERMINE COMMITTEE REVIEW REQUIR.... .
(Refer to Section 6.1.4) ,
PORO REVIEW REQ'D? NO YES 9. PORC MTG# NA BLOCKS 11 THRU 16 ARE ON PAigE 2 FF.IM
- 17. William Tabor 4 36,,. 06/04/2002 18. COMMUNICATION OF CHANGE REQUIRED?
PREPARER ETN DATE F-" NO Z YES (TYPE) OPS Buttetin (Print or Type) 'ii
- 19. "-SIGNATURE ATTESTS THAT RESPONSIBLE SUPERVISOR HAS
- 19. CONDUCTED QADR AND TECHNICAL REVIEW UNLESS OTHERWSE S, DOCUMENTED IN BLOCK 16 OR ATTACHED REVIEW FORMS.
CROSS DISCIPLINE REVIEW (IFREQUIRED) HAS BEEN COMPLETED RESSATISOR BY SIGNATURE IN BLOCK 16 OR ATTACHED REVIEW FORMS.
- 20. , . fIilo*
I. AFPPR-OVAL DATE
- 21. RESPONSIBLE APPROVER ENTER N/A IF FUM HAS APPROVAL AUTHORITY 7INITIALS /DATE FORM NDAP-QA-0002-8, Rev. 8, Page 1 of 2 (Electronic Form)
I PROCEDURE CHANGE PROCESS FORM
- 1. PCAF NO. 2002-1441 12. PAGE 2 OF 6 13. PROC. NO. EP-PS-126 REV. 17
- 11. This question documents the outcome of the 50.59 and 72.48 Review required by NDAP-QA-0726. Either 1a, b, c or d must be checked "YES" and the appropriate form attached or referenced.
- a. This change is an Administrative Correction for which 50.59 and 72.48 are not F-1 YES 0 N/A applicable.
- b. This change is a change to any surveillance, maintenance or administrative Z YES Ij N/A procedure for which 50.59 and 72.48 are not applicable..
- c. This change is bounded by a 50.59/72.48 Screen/Evaluation, therefore, no new - YES I N/A 50.59/72.48 .Evaluation is required.
Screen/Evaluation No.
- d. 50.59 and/or 72.48 are applicable to this change and a 50.59/72.48 [ YES [ N/A Screen/Evaluation is attached.
- 13. Should this change be reviewed for potential effects on Training Needs or Material? rl YES [ NO IfYES, enter an Action Item @ NIMS/Action/Gen Work Mech/PICN
- 14. Is a Surveillance Procedure Review Checklist required per NDAP-QA-0722? r] YES [ NO
- 15. Is a Special, Infrequent or Complex Test/Evolution Analysis Form required per ] YES [ NO NDAP-QA-0320? (SICT/E form does not need to be attached.)
- 16. Reviews may be documented below or by attaching Document Review Forms NDAP-QA-01 01-1.
REVIEWED BY WITH DATE REVIEW NO COMMENTS QADR TECHNICAL REVIEW REACTOR ENGINEERING/NUCLEAR FUELS *"
IST **
OPERATIONS NUCLEAR SYSTEMS ENGINEERING NUCLEAR MODIFICATIONS MAINTENANCE HEALTH PHYSICS NUCLEAR TECHNOLOGY CHEMISTRY OTHER 10CFR50.54q Required for changes that affect, or have potential for affecting core reactivity, nuclear fuel, core power level indication or impact the thermal power heat balance. (58)
- Required for changes to Section XI Inservice Test Acceptance Criteria.
FORM NDAP-QA-0002-8, Rev. 8, Page 2 of 2 (Electronic Form)
pABL-OF~.-
Revision 17 Page 2 of 3 CONTROL ROOM COMMUNICATOR: Emergency Plan-Position Specific Procedure WHEN: Emergency plan is activated HOW NOTIFIED: Assigned while on duty REPORT TO: Shift Supervisor/ED WHERE TO REPORT: Control Room OVERALL DUTY:
Communicate information on emergency to specified personnel, agencies, and organizations, until the Technical Support Center (TSC) takes over communications.
MAJOR TASKS: TAB: REVISION:
Using the "Control Room Communicator's Flowchart," TAB A "-*-" PecA F make initial notifications to off-site agencies and emergency personnel.
Pass on information and documentation when your TAB B 3 communications job is finished, due to shift turnover, transfer of control to the TSC, or termination.
Perform notifications during a hazardous materials TAB C 3 spill.
Perform Security Threat or Event communications as TAB F 0 lFCA F directed by Emergency Director
EP-PS-126 Revision 17 PCAF 4 2002-144.1 Page 3 of 3 PA.GL.+/-L..OP 6 SUPPORTING INFORMATION: TAB:
Emergency Telephone Instructions TAB I Emergency Organization TAB 2 Logkeeping TAB 3 Notification Matrix TAB 4 Emergency Forms TAB 5
- Emergency Notification Report
- Emergency Notification Logsheet
- Protective Action Recommendation Form Brief Non-Technical Descriptions of EAL TAB 6 Emergency Classification TAB 7
REFERENCES:
NUREG-0654, Planning Standards and Evaluation Criteria NUREG-0696, Functional Criteria for Emergency Response Facilities NUREG-0731, Guidelines for Utility Management Structure and Technical Resources, September 1980
-SSES Emergency Plan NDAP-00-0316, Station Communications NDAP-QA-0300, Conduct of Operations OP-AD-003, Shift Routine - Log taking Letter dated February 25,2002 from Samuel J. Collins, Director, Office ofNuclear Reactor Regulations, IPC.A F to Robert G. Byram, Senior Vice President and Chief Nuclear Officer.
Shift Supersor Qeciares )
Site Evaouation Ordered By ED D Eretg-ncy Clessifilation EP-PS-tOO EP-PS-1 26 CDONTROL ROOM (A.ttionl0)1NERD pagers using the ..... .. . . ..M or g.g. .. .
SheAccountabillty Pedorme telephone'HOiTBUTTO Notifythe following that a Site E,Vacuraton Make Plant Announcement Attenln all Personnel
,OMMUNICATOR o00allnon-em0rgency personnel hhas been ordered:
Dial CTN lot
'--* I -£MAl... . FLOW CHART I_ PENNEMA 6Re 0ove the telephone headset from .-Colaro i C-nty EMA the twenty button telephone on the center -Lt-r CourtyEMA Has".bn declared at console SSES cl [ RepeallAnnouncement)
- Press the "GREEN"activation butlon. (the fifth button in the first Donument on Emergaeny [] YES /Isitan 0 NO row.Otten) NolyiloationLog Sheet Ceoilons and Notes Ea0C
_After approxrimnaly thirty secods A lency Emergecy Telephone Numbers reset the GREEN" buon by pressing any other button and hang up the telephone handsel use CTN t191"to transmit using telephone HOT BUTTON' ccMA
- 4440o/~' ~o~.7 the ENRIo:. re mn e -0C2. 0 cnr... .. ... .. ...
__ ,mi. x mncyWA nl-NOTE: ,RP5 (W)32-.64 o 0 0L.-..... t.r n tr...... . 4 Conteot the ASOC: -- A Ytllhrntw0 043Jofdiclttl0n Itthe green pagers button is not reset, the wit activate ml.45.hey6.0l (717)233.5704 again when the i cot 3 - _ Veriy pager activation handsel Is picking a N (,.6ls 0)561-0433 roaert up Peirt,- Site Accountability.it requested - - Reest TNS activation
'pL+ InBUWrel~ 4.OIaKoeeiann{ 260-4061 (W) 0ýE by the EmergencyDirectorI 0')
Withinfifeen win.ot aeciaratl, - -LI F9Ii T. N00.7ik 220-46W2 use CTN"' tOttn1transmit ________ 60704 fO... 100.rO1 r 1(00 ISt. O14(0-Or.
C210 by the Emergency Director _- L-- C E U~ne4.w~rlt clmlErnergqe rto:.I ounty AA - {i
~VHF SCCEMA,&
I-W .nLCEMA TSW. ý IlW W -ont As ý~O Direc trq uest f0o additional Information Conta the ASCC and reoestSiteSAccountability From the NRC to the Sh/ED
[ From other agencies to the MOC Call Transmission Power Dispatcher "
It MOCdoes n0. answer, do not "Rwl. trnsmit C3e0 and give emergency cleasitication hSoe Accountability orderad [] message to emergenoy agenc6es By ED dorectedby W=thon 60 r Ofdenterath.tton, transmi --.
EP-PS-126 Fiow Chart Emergency notittcation Rape0 and Protective Action Recommendation Form. (if release In progress), to the Ensure "Page Merge' pushbutton c,,r] NRCusing the ENS telephone 1:3 depressed at Unit2 US dask At Panel OC695
-Turn the siren teno generator switch to
'pulsed' position
-Pull out evacuation alarm switch, turn to -Plant Alarm' position and push In Evacuation Alarm switch
-Aeter 30 seconds pua1out Evacuation Alarm switch, turn 10'to position and 440 push In Evacuation Alarm switch Itupgrading tromanLUnusualiEoest:
MAKE PLANTANNOUNCEMENT - ActhvateNERD Pagersusing Telephone "Hotbutton" "Aitention lit personnel. a Site Turn TSC over notiticatlon towhen Communletor(s) the Accountability Is ordered. Al ..- call TSC conditions allow - Contaoct ASCC to verity pager ermrgency personnel report to your duty activation and request TNS
.Iateens. Allother personnel report to youl activation designated ar~teas."
litblgv Enery bearonthe 112hoar transmit - Perform site accountabeity, ifnot PC_
PBCCOU (Add an, additional Information regarding the Emergency NotillcallonReport previously pe[ rmne habitabilty as requested by the ED) providing a static update to:
- Peni..EMA (Repeat Announcement) - C4oumfi County EMA MAKE PLANTANNOUNCEMENT
-- LueM.nCoanty 70
[--
CT0 MedtOe~raeen Carttr ATTENTIONALL PERSONNEL Dument on Emergency THE EMERGENCYHAS BEEN UPGRADEOIDOWNGRADEDTO:
El ar0 Notitlcatlon Log sheet Everyhour on the 1/2 hour, insmEt the Emergency Notficahton Report, U-070i344)E.nt (providinga status update), and the - - - Sit. - E9r.eey Protective Acilon Recommendation 0-1rereiEmrg.ney Form, (y1 e release Is In progress). to: REPEATANNOUNCEMENT icu tI" 4660)
P-- / cr00 3- DEPIRP (CTN496464965) 0e __ORC(IENSnirn*M.r n hlnd04)
-]
- 1. Dial CTN 191:
L--1..Corn CountyElMA
- MI l-1Operation. Center
- 2. Refer toOn-Call List:
- E-rggy.ra irMtr, TSC
-- RecovryM-r0ge
- 3. TPD Hotlne:
- Trensmrinsl P-oer O llthar
- 4. ENS Telephone:
- NRC(6nuneron handst)
S. INPO
- 6. Allegheny Electrlc
- 7. ANI
- 8. PPL Insurance Department eemswi I.eeeunsseeco.ael ecea
-lLi
Tab A EP-PS-126-A Revision 22 Page 1 of 1
TAB F EP-PS-126-F p # 2002 - 1441 Revision 0 B, Page 1 of 1 MAJOR TASK; Perform SiteSpecific Security Threat of Event emergency communications as directed by the Emergency Director.
SPECIFIC TASK: HOW:
- 1. Commence logging communication actions. 1a. Use Tab 5 Log Sheet.
- 2. Transmit Emergency Notification Report for 2a. Dial 191 conference bridge on CTN extension EAL and Site Evacuation. or USE Tab 4 backup phone numbers 2b.
Contact:
- 1) Pennsylvania EMA
- 2) Columbia County EMA
- 3) Luzeme County EMA
- 3. If directed by the Emergency Director. 3a. For evacuation, make a page announcement twice: "Attention all personnel, a security emergency has been declared, all non essential personnel evacuate the site. All NERO responders report to the Emergency Operations Facility.
- 4. When a site accountability is ordered by the 4a. Ensure the "Page Merge" button is depressed.
Emergency Director.
4b. Go to Panel OC695:
- 1) Turn siren tone generator switch to "pulsed".
- 2) Pull out evacuation alarm switch.
- 3) Turn evacuation alarm switch to "plant alarm".
- 4) Push in evacuation alarm switch
- 5) Wait 30 seconds.
- 6) Pull out evacuation alarm switch.
- 7) Turn evacuation alarm switch to "off".
- 8) Push in evacuation alarm switch.
4c. Make a page announcement twice: "Attention all personnel, a site accountability is ordered. All personnel report to the nearest accountability area."
- 5. When Tasks 3 and 4 are completed. 5a. Enter Communicator Flowchart step C3.
'TAB 6 EP-PS-1 26-6 BRIEF NON-TECHNICAL DESCRIPTIONS OF EAL EAL# 1.1: Aircraft/Train Activity Unusual Event I Brief Non-Technical
Description:
(Aircraft crash/Train derailment) within the plant security fence (protected area). Based on current plant conditions, the safety of the general public is not threatened.
EAL# 1.2: Aircraft/Train Activity Alert Brief Non-Technical
Description:
(Aircraft crash/Projectile strike) onto a permanent plant structure. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 1.3: Aircraft/Train Activity Site Emergency Brief Non-Technical
Description:
(Aircraft crash/Projectile strike) which caused damage to some equipment used to safely shut down the reactor.
EP-AD-000-201, Revision 4, Page 1 of 23
'TAB 6 EP-PS-1 26-6 EAL# 2.2: Control Room Evacuation Alert Brief Non-Technical
Description:
The Control Room was evacuated, then control of plant systems was established from another location within the plant. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 2.3: Control Room Evacuation Site Emergency I Brief Non-Technical
Description:
Within 15 minutes of evacuating the Control Room, operators have been unable to establish remote stations for controlling plant systems.
EP-AD-000-201, Revision 4, Page 2 of 23
- TAB 6 EP-PS-1 26-6 EAL# 3.1: Fuel Cladding Degradation UnusualEvent Brief Non-Technical
Description:
Minor damage has occurred to the metal tubes that hold uranium fuel pellets. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 3.2: Fuel Cladding Degradation Alert I Brief Non-Technical
Description:
There has been significant damage to metal tubes that hold uranium fuel pellets. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 3.3: Fuel Cladding Degradation Site Emergency Brief Non-Technical
Description:
Severe damage has taken place to the metal tubes that hold uranium fuel pellets.
Abnormally high radiation levels are present in the water which acts as a reactor coolant or in the containment structure surrounding the reactor.
EAL# 3.4.a: Fuel Cladding Degradation GeneralEmergency Brief Non-Technical
Description:
Severe damage to metal tubes that hold uranium fuel pellets. Higher than normal radiation levels in reactor coolant or containment structure surrounding reactor, with a potential for off-site radioactivity release.
EP-AD-000-201, Revision 4, Page 3 of 23
'TAB 6 EP-PS-1 26-6 EAL# 3.4.b: Fuel Cladding Degradation GeneralEmergency Brief Non-Technicar
Description:
Indication of uranium fuel melting. Potential for off-site radioactivity release.
EP-AD-000-201, Revision 4, Page 4 of 23
TAB 6 EP-PS-1 26-6 EAL# 4.1: General Unusual Event Brief Non-Technical
Description:
( Specific Event ) which potentially threatens the safety of the plant. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 4.2- General Alert Brief Non-Technical
Description:
( Specific Event ) which actually threatens the safety of the plant. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 4.3: General Site Emergency Brief Non-Technical
Description:
Specific Event ) has occurred which indicates an (actual/imminent) loss of important plant safety systems.
EAL# 4.4: General GeneralEmergency Brief Non-Technical
Description:
( Specific Event ) has occurred which indicates an (actual/imminent) major release of radioactivity.
EP-AD-000-201, Revision 4, Page 5 of 23
'TAB 6 EP-PS-1 26-6 EAL# 5.1: Injured/Contaminated Personnel UnusualEvent Brief Non-Technical
Description:
An injured person(s), contaminated with radioactive material, is or has been moved outside the immediate area of the plant. Based on current plant conditions, the safety of the general public is not threatened.
EP-AD-000-201, Revision 4, Page 6 of 23
"TAB 6 EP-PS-1 26-6 EAL# 6. 1: In-plant High Radiationl Unusual Event II Brief Non-Technical
Description:
High levels of airborne radioactivity have been detected inside the plant. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 6.2f In-plant High Radiation Alert I Brief Non-Technical
Description:
Very high levels of radiation have been detected in the plant. Based on current plant conditions, the safety of the general public is not threatened.
EP-AD-000-201, Revision 4, Page 7 of 23
"TAB 6 EP-PS-1 26-6 EAL# 7.1: Loss of AC Power Unusual Event Brief Non-Technical
Description:
AC electrical power from either off-site or on-site sources is needed to operate plant safety equipment. Either the off-site or on-site source has been lost; however, power is still available from the other source. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 7.2: Loss of AC Power Alert Brief Non-Technical
Description:
All AC electrical power (from both on-site and off-site) needed to operate plant safety equipment has been temporarily lost. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 7.3: Loss of AC Power Site Emergency Brief Non-Technical
Description:
All AC electrical power (from both on-site and off-site) needed to operate plant safety equipment has been lost for a sustained period of time (15 minutes). Based on current plant conditions, the safety of the general public is not threatened.
EP-AD-000-201, Revision 4, Page 8 of 23
'TAB 6 EP-PS-1 26-6 EAL# 8.2: Loss of Control Room Alarms and Annunciators Alert Brief Non-Technical
Description:
All control room alarms have been lost. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 8.3: Loss of Control Room Alarms and Annunciators Site Emergency I Brief Non-Technical
Description:
All control room alarms have been lost in combination with another plant operating problem (plant transient).
EP-AD-000-201, Revision 4, Page 9 of 23
°TAB 6 EP-PS-126-6 EAL# 9.2: Loss of DC Power Alert Brief Non-Technical
Description:
All DC electrical power in the plant has been lost temporarily. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 9.3: Loss of DC Power Site Emergency Brief Non-Technical
Description:
All DC electrical power-needed to operate some plant safety equipment-has been lost for more than 15 minutes.
EP-AD-000-201, Revision 4, Page 10 of 23
"TAB 6 EP-PS-1 26-6 EAL# 10.2: Loss of Decay Heat Removal Capability Alert Brief Non-Technical
Description:
While the reactor is shutdown (cold shutdown), equipment needed to maintain reactor water temperature below 2000 F has been lost. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 10.3: Loss of Decay Heat Removal Capability Site Emergency Brief Non-Technical
Description:
While the unit is shutdown, operators are unable to effectively cool the reactor.
EAL# 10.4: Loss of Decay Heat Removal Capability General Emergency I Brief Non-Technical
Description:
Operators are unable to cool the reactor; a release of radioactivity is possible.
EP-AD-000-201, Revision 4, Page 11 of 23
'TAB 6 EP-PS-126-6 EAL# 11.1: Loss of Reactivity Control Unusual Event Brief Non-Technical
Description:
Reactor power has increased in a way that was not anticipated. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 11.2: Loss of Reactivity Control Alert Brief Non-Technical
Description:
During attempted reactor shutdown, the reactor's control rods failed to insert fully (scram).
Based on current plant conditions, the safety of the general public is not threatened.
EAL# 11.3: Loss of Reactivity Control Site Emergency Brief Non-Technical
Description:
Operators are unable to shut down and cool the reactor. Reactor control rods failed to fully insert. A back-up chemical control system also failed.
EAL# 11.4: Loss of Reactivity Control GeneralEmergency I Brief Non-Technical
Description:
Operators are unable to shut down and cool down the reactor. Reactor control rods failed to fully insert. The back-up chemical control system also failed. The situation could lead to a radioactivity release.
EP-AD-000-201, Revision 4, Page 12 of 23
TAB 6 EP-PS-126-6 EAL# 12.1: Loss of Reactor Vessel Inventory UnusualEvent Brief Non-Technical
Description:
To maintain reactor water level, an emergency cooling system has been activated.
Based on current plant conditions, the safety of the general public is not threatened.
EAL# 12.2: Loss of Reactor Vessel Inventory Alert I Brief Non-Technical
Description:
Excessive water is leaking from the reactor coolant systems into the containment structure surrounding the reactor vessel. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 12.3: Loss of Reactor Vessel Inventory Site Emergency I Brief Non-Technical
Description:
The ability to maintain water level above the fuel has been lost.
EP-AD-000-201, Revision 4, Page 13 of 23
" TAB 6 EP-PS-126-6 EAL# 12.4.a: Loss of Reactor Vessel Inventory GeneralEmergency Brief Non-Technical
Description:
The ability to maintain an adequate water level in the reactor vessel has been lost; severe fuel damage and release of radioactivity are possible.
EAL# 12.4.b: Loss of Reactor Vessel Inventory GeneralEmergency Brief Non-Technical
Description:
Fuel damage and a reactor coolant leak have occurred, with a potential loss of the ability to contain radioactive releases.
EP-AD-000-201, Revision 4, Page 14 of 23
'TAB 6 EP-PS-1 26-6 EAL# 13.1: Natural Phenomena Unusual Event Brief Non-Technical
Description:
(Tornado/ Hurricane/ Earthquake) has struck the plant site. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 13.2: Natural Phenomena Alert Brief Non-Technical
Description:
(Tornado/ Hurricane/ Earthquake) has struck the plant and could affect plant safety.
Based on current plant conditions, the safety of the general public is not threatened. The event may be severe enough to impact plant equipment.
EAL# 13.3: Natural Phenomena Site Emergency Brief Non-Technical
Description:
Severe (Tornado/ Hurricane/ Earthquake) is affecting plant safety while plant is not in cold shutdown.
EP-AD-000-201, Revision 4, Page 15 of 23
'TAB 6 EP-PS-1 26-6 EAL# 14.1: On-site Fire/Explosion Unusual Event Brief Non-Technical
Description:
A (fire/ explosion) has occurred on-site, within the (plant/ security fence). Based on current plant conditions, the safety of the general public is not threatened.
EAL# 14.2:On-Site Fire/Explosion Alert I Brief Non-Technical
Description:
A (fire/ explosion) has occurred on-site that has affected plant operation. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 14.3: On-site Fire/Explosion Site Emergency Brief Non-Technical
Description:
A (fire/ explosion) has damaged equipment needed to safely shut down the reactor.
EP-AD-000-201, Revision 4, Page 16 of 23
"TAB 6 EP-PS-126-6 EAL# 15.1: Radiological Effluent Unusual Event Brief Non-Technical
Description:
Radioactivity is being released from the plant that exceeds plant operating license limits (Technical Specifications) for liquid releases or exceeds 2 times plant operating license limits for gaseous releases. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 15.2: Radiological Effluent Alert Brief Non-Technical
Description:
Radioactivity is being released at levels at least ten times higher than those allowed by the plant operating license limits (Technical Specifications) for liquid release or exceeds 200 times plant operating license limits for gaseous limits. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 15.3: Radiological Effluent Site Emergency Brief Non-Technical
Description:
Radioactivity is being or has been released which may result in low levels of exposure to people outside the immediate plant area (emergency planning boundary).
EAL# 15.4: Radiological Effluent General Emergency Brief Non-Technical
Description:
Radioactivity is being released that exceeds federal guidelines which specify actions like sheltering or evacuation to protect the public.
EP-AD-000-201, Revision 4, Page 17 of 23
TAB 6 EP-PS-1 26-6 EAL# 16.1: Security Event Unusual Event I Brief Non-Technical
Description:
I An attempt has been made to breach station security or a site-specific credible threat has been received. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 16.2: Security Event Alert Brief Non-Technical
Description:
A compromise of Station security has occurred or is imminent. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 16.3: Security Event Site Emergency Brief Non-Technical
Description:
Security has-been compromised in a way that threatens plant safety systems.
EAL# 16.4: Security Event General Emergency Brief Non-Technical
Description:
Security has been compromised in a way that has caused loss of control of some or all vital areas of the plant.
EP-AD-000-201, Revision 4, Page 18 of 23
"TAB 6 EP-PS-1 26-6 EAL# 17.1: Spent Fuel Related Incident Unusual Event Brief Non-Technical
Description:
Used fuel assemblies (groups of the metal rods containing irradiated uranium fuel pellets), being stored in the unit's spent fuel pool, are leaking radioactive material. This is causing abnormally high radiation levels in some areas of the plant. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 17.2: Spent Fuel Related Incident Alert Brief Non-Technical
Description:
Used fuel assemblies (groups of the metal rods containing irradiated uranium fuel pellets), being stored in the unit's spent fuel pool are leaking radioactive material. This is causing very high radiation levels in some areas of the plant. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 17.3.a: Spent Fuel Related Incident Site Emergency Brief Non-Technical
Description:
Severe damage has occurred to some used fuel assemblies (metal rods containing irradiated uranium fuel pellets) stored in the unit's spent fuel pool. A radioactivity release is possible.
EAL# 17.3.b: Spent Fuel Related Incident Site Emergency I Brief Non-Technical
Description:
Used (irradiated) fuel assemblies in the unit's spent fuel pool are damaged and no longer covered with cooling water. A radioactive release is possible.
EP-AD-000-201, Revision 4, Page 19 of 23
I TAB 6 EP-PS-1 26-6 EAL# 18.2: Steam Line Break Alert Brief Non-Technical
Description:
Isolation valves have failed to completely shut off the flow of radioactive steam from the reactor to the turbine-generator. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 18.3: Steam Line Break Site Emergency Brief Non-Technical
Description:
Isolation valves have failed to properly shut and there is significant flow of radioactive steam from the reactor to areas outside the primary containment.
EP-AD-000-201, Revision 4, Page 20 of 23
'TAB 6 EP-PS-1 26-6 EAL# 19.1: Toxic/Flammable Gases UnusualEvent Brief Non-Technical
Description:
(Toxic/ flammable) gas has been released (near-site/ on-site). Based on current plant conditions, the safety of the general public is not threatened.
EAL# 19.2: Toxic/Flammable Gases Alert Brief Non-Technical
Description:
(Toxic/ flammable) gas has entered plant facilities. Based on current plant conditions, the safety of the general public is not threatened.
EAL# 19.3: Toxic/Flammable Gases Site Emergency Brief Non-Technical
Description:
(Toxic/ flammable) gas has entered areas within plant buildings which contain vital safety equipment (plant vital areas).
EP-AD-000-201, Revision 4, Page 21 of 23
'TAB 6 EP-PS-126-6 EAL# 20.1: Technical Specification Safety Limit Unusual Event Brief Non-Technical
Description:
An abnormal plant condition has occurred. Based on current plant conditions, the safety of the general public is not threatened.
EP-AD-000-201, Revision 4, Page 22 of 23
'TAB 6 EP-PS-126-6 EAL# 21.1 .a: Irradiated Spent Fuel in Dry Storage Unusual Event I Brief Non-Technical
Description:
While transporting the used (spent) fuel assemblies (groups of rods containing irradiated uranium fuel pellets) from the spent fuel pool to the onsite storage facility, radiological readings indicate that the spent fuel or its container may be damaged.
EAL# 21.1 .b: Irradiated Spent Fuel in Dry Storage UnusualEvent Brief Non-Technical
Description:
After the used (spent) fuel assemblies (groups of rods containing irradiated uranium fuel pellets) have been transported from the spent fuel pool and placed in the horizontal storage module (a concrete structure which will house the steel canister of spent fuel),
radiological readings indicate that the fuel storage system may be damaged.
EP-AD-000-201, Revision 4, Page 23 of 23
TAB 7 EP-PS-1 26-7 EMERGENCY CLASSIFICATION CHECK 0 1.0 TIMING OF CLASSIFICATION 0 1.1 UNUSUAL EVENT An UNUSUAL EVENT shall be declared within 15 minutes of having information necessary to make a declaration.
o 1.2 ALERT An ALERT shall be declared within 15 minutes of having information necessary to make a declaration.
o 1.3 SITE AREA EMERGENCY A SITE AREA EMERGENCY shall be declared within 15 minutes of having information necessary to make a declaration.
o 1.4 GENERAL EMERGENCY A GENERAL EMERGENCY shall be declared within 15 minutes of having information necessary to make a declaration.
EP-AD-000-200, Revision 16, Page 1 of 39
TAB 7 EP-PS-126-7 CLASSIFICATION OF EMERGENCY CONDITIONS USE OF EMERGENCY CLASSIFICATION MATRIX NOTE: CONFIRM THAT INDICATORS AND/OR ALARMS REFLECT ACTUAL CONDITIONS PRIOR TO TAKING ACTION BASED ON THE INDICATOR OR ALARM.
The matrix is worded in a manner that assumes parameter values indicated are the actual conditions present in the plant.
The matrix is designed to make it possible to precisely classify an abnormal occurrence into the proper emergency classification based on detailed Emergency Action Level (EAL) descriptions. It is impossible to anticipate every abnormal occurrence.
Therefore, before classifying any abnormal occurrence based on the EALs in the matrix, one should verify that the general conditions prevalent in-plant and offsite meet the general class description of the emergency classification. In addition, prior to classification, one should be aware of the ramifications in-plant and particularly offsite of that classification. Special consideration of offsite consequences should be made prior to declaring a GENERAL EMERGENCY.
EP-AD-000-200, Revision 16, Page 2 of 39
TAB 7 EP-PS-126-7 POLICY STATEMENT ON EMERGENCY DECLARATIONS Policy When an emergency action level (EAL) is exceeded but the plant quickly returns below the EAL, the emergency should be declared. If appropriate, the emergency can also be downgraded or terminated at essentially the same time and the Emergency Notification Form can say the emergency was declared and terminated (or downgraded) minutes later.
Example The main steam lines isolate on high radiation due to a large oil intrusion into the vessel. The isolation on high radiation is a trigger to declare an Alert. If it can quickly be determined that the cause was not damage to the fuel and we should not be in an Alert, then the Alert should be declared and terminated with the same notification report.
Basis Declaring the emergency will notify interested offsite personnel and will demonstrate that we recognize that we exceeded an EAL. Immediately terminating or downgrading will avoid activation of company and offsite facilities that are not required for this event.
EP-AD-000-200, Revision 16, Page 3 of 39
TAB 7 EP-PS-126-7 CLASS DESCRIPTIONS UNUSUAL EVENT Events that are occurring or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.
ALERT Events that are occurring or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.
SITE AREA EMERGENCY Events that are occurring or have occurred which involve actual or imminent major failures of plant functions needed for protection of the public. Any releases are not expected to exceed EPA Protective Action Guideline exposure levels except inside the emergency planning boundary.
GENERAL EMERGENCY - Events that are occurring or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity. Expectation is that releases will exceed EPA Protective Action Guideline exposure levels beyond the emergency planning boundary.
EP-AD-000-200, Revision 16, Page 4 of 39
TAB 7 EP-PS-126-7 CATEGORY INDEX TO THE MATRIX FOR THE CLASSIFICATION OF EMERGENCY CONDITIONS TABLE OF CONTENTS CATEGORY EVENT PAGE 1 AI RCRAFT/TRAI N ACTIVITY ........................................................... 6 2 CONTROL ROOM EVACUATION .................................................... 7 3 FUEL CLADDING DEGRADATION .................................................. 8 4 G EN ERA L ...................................................................................... 11 5 INJURED/CONTAMINATED PERSONNEL .................................... 12 6 IN-PLANT HIGH RADIATION .......................................................... 13 7 LOSS OF AC POW ER ...................................................................... 14 8 LOSS OF CONTROL ROOM ALARMS AND ANNUNCIATORS ....... 15 9 LOSS OF DC POW ER ..................................................................... 16 10 LOSS OF DECAY HEAT REMOVAL CAPABILITY ......................... 17 11 LOSS OF REACTIVITY CONTROL .................................................. 18 12 LOSS OF REACTOR VESSEL INVENTORY .................................. 20 13 NATURAL PHENOMENA ................................................................ 22 14 ONSITE FIRE/EXPLOSION .................................. .............................. 24 15 RADIOLOGICAL EFFLUENT .......................................................... 26 16 SECURITY EVENT .......................................................................... 30 17 SPENT FUEL RELATED INCIDENT ............................................... 32 18 STEAM LINE BREAK ..................................................................... 34 19 TOXIC/FLAMMABLE GASES .......................................................... 37 20 TECHNICAL SPECIFICATION SAFETY LIMIT ............................... 38 21 DRY FUEL STORAGE ................................................................... 39 EP-AD-000-200, Revision 16, Page 5 of 39
TAB 7 EP-PS-126-7 1 - AIRCRAFT/TRAIN ACTIVITY UNUSUAL EVENT EAL# 1.1 Aircraft crash or train derailment onsite as indicated by:
Visual observation or notification received by control room operator.
ALERT EAL# 1.2 Aircraft or missile strikes a station structure as indicated by:
Direct observation or notification received by control room operator.
SITE AREA EMERGENCY EAL# 1.3 Severe damage to safe shutdown equipment from aircraft crash or missile impact when not in cold shutdown, determined by:
(A and B and C)
A. Direct observation or notification received by control room operator.
and B. Shift Supervisor evaluation.
and C. Reactor Coolant temperature greater than 200°F as indicated on Panel 1C651 (2C651).
GENERAL EMERGENCY EAL# 1.4 None.
EP-AD-000-200, Revision 16, Page 6 of 39
TAB 7 EP-PS-126-7 2 - CONTROL ROOM EVACUATION UNUSUAL EVENT EAL# 2.1 None.
ALERT EAL# 2.2 Control Room evacuation as indicated by:
(A and B)
A. Initiation of control room evacuation procedures.
and B. Establishment of control of shutdown systems from local stations.
SITE AREA EMERGENCY EAL# 2.3 Delayed Control Room Evacuation as indicated by:
(A and B)
A. Initiation of control room evacuation procedures.
and B. Shutdown systems control at local stations not established within 15 minutes.
GENERAL EMERGENCY EAL# 2.4 None.
EP-AD-000-200, Revision 16, Page 7 of 39
TAB 7 EP-PS-126-7 3 - FUEL CLADDING DEGRADATION UNUSUAL EVENT EAL# 3.1 Core degradation as indicated by:
(A or B)
A. Valid Off-gas Pre-treatment Monitor high radiation alarm annunciation on Panel 1C651 (2C651) or indication on Panel 1C600 (2C600).
or B. Reactor coolant activity, determined by sample analysis greater than or equal to 2 jtCi/cc of 1-131 equivalent.
ALERT EAL# 3.2 Severe fuel cladding degradation as indicated by:
(A or B or C or D)
A. Valid Off-gas Pre-treatment monitor High-High radiation alarm annunciation on Panel 1C651 (2C651) or indication on Panel 1C600 (2C600).
or B. Valid Reactor coolant activity greater than 300 jxCi/cc of equivalent 1-131, as determined by sample analysis.
or C. Valid Main Steam Line High radiation trip annunciation or indication on Panel 1C651 (2C651).
or D. Valid containment post accident monitor indication on Panel 1C601 (2C601) greater than 200 R/hr. (An 8R/hr correction factor must be added manually to the indication to offset a downscale error if primary containment temperature exceeds 225 degrees Fahrenheit.
Reference EC-079-0521.)
(CONTINUED ON NEXT PAGE)
EP-AD-000-200, Revision 16, Page 8 of 39
TAB 7 EP-PS-126-7 3 - FUEL CLADDING DEGRADATION (continued)
SITE AREA EMERGENCY EAL# 3.3 Severely degraded core as indicated by:
(A or B)
A. Reactor coolant activity greater than 1,000 jtCi/cc of equivalent 1-131 as determined by sample analysis.
or B. Valid containment post accident monitor indication on Panel 1C601 (2C601) greater than 400 R/hr. (An 8 R/hr correction factor must be added manually to the indication to offset a downscale error if primary containment temperature exceeds 225 degrees Fahrenheit.
Reference EC-079-0521.)
(CONTINUED ON NEXT PAGE)
EP-AD-000-200, Revision 16, Page 9 of 39
TAB 7 EP-PS-126-7 3 - FUEL CLADDING DEGRADATION (continued)
GENERAL EMERGENCY EAL# 3.4.a Fuel cladding degradation. Loss of 2 out of 3 fission product barriers (fuel cladding and reactor coolant pressure boundary) with potential loss of the third barrier (primary containment) as indicated by:
(A or B)
A. (1 and 2)
- 1. Valid containment post accident monitor indication on Panel 1C601 (2C601) greater than 400 R/hr. (An 8 R/hr correction factor must be added manually to the indication to offset a downscale error if primary containment temperature exceeds 225 degrees Fahrenheit. Reference EC-079-0521.)
and
- 2. (aorborc)
- a. Containment pressure greater than 40.4 PSIG, indicated on Panel 1C601 (2C601).
or
- b. A visual inspection of the containment indicates a potential for loss of containment (e.g. anchorage or penetration failure, a crack in containment concrete at tendon).
or
- c. Other indications of potential or actual loss of primary containment.
or B. (1 and 2)
- 1. Reactor coolant activity greater than 1,000 jLCi/cc of equivalent 1-131 as determined by sample analysis.
and
- 2. Actual or potential failure of reactor coolant isolation valves to isolate a coolant leak outside containment as determined by valve position indication on Panel 1C601 (2C601) or visual inspection.
OR EAL# 3.4.b Core melt as indicated by:
(A and B)
A. Valid containment post accident monitor indication on Panel 1C601 (2C601) greater than 2000 R/hr. (An 8 R/hr correction factor must be added manually to the indication to offset a downscale error if primary containment temperature exceeds 225 degrees Fahrenheit. Reference EC-079-0521.)
and B. Containment high pressure indication or annunciation on Panel 1C601 (2C601).
EP-AD-000-200, Revision 16, Page 10 of 39
TAB 7 EP-PS-1 26-7 4-GENERAL UNUSUAL EVENT EAL# 4.1 Plant conditions exist that warrant increased awareness on the part of plant operating staff or state and/or local offsite authorities as indicated by:
Events that are occurring or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.
ALERT EAL# 4.2 Other plant conditions exist that warrant precautionary activation of PP&L, State, County, and local emergency centers as indicated by:
Events that are occurring or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.
SITE AREA EMERGENCY EAL# 4.3 Other plant conditions exist that warrant activation of emergency centers and monitoring teams or a precautionary notification to the public near the site as indicated by:
Events that are occurring or have occurred which involve actual or imminent major failures of plant functions needed for protection of the public. Any releases are not expected to exceed EPA Protective Action Guideline exposure levels except inside the emergency planning boundary.
GENERAL EMERGENCY EAL# 4.4 Other plant conditions exist, from whatever, source, that make release of large amounts of radioactivity in a short time period available as indicated by:
Events that are occurring or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity. Expectation is that releases will exceed EPA Protective Action Guideline exposure levels beyond the emergency planning boundary.
EP-AD-000-200, Revision 16, Page 11 of 39
TAB 7 EP-PS-126-7 5.- INJURED/CONTAMINATED PERSONNEL UNUSUAL EVENT EAL# 5.1 Transportation of externally contaminated injured individual from site to offsite medical facility as deemed appropriate by Shift Supervisor.
ALERT EAL# 5.2 None.
SITE AREA EMERGENCY EAL# 5.3 None.
GENERAL EMERGENCY EAL# 5.4 None.
EP-AD-000-200, Revision 16, Page 12 of 39
TAB 7 EP-PS-126-7 6 - IN-PLANT HIGH RADIATION UNUSUAL EVENT EAL# 6.1 Unanticipated or unplanned concentrations of airborne activity exist in normally accessible areas, which are not due to planned maintenance activities, as indicated by:
Concentrations exceed 500 times the DAC values of IOCFR20 Appendix B, Table I values for a single isotope, or for multiple isotopes where CA
+ C8 + CC... CN _>500 DACA DAC 8 DACc DAC 0 ALERT EAL# 6.2 Unexpected in-plant high radiation levels or airborne contamination which indicates a severe degradation in the control of radioactive material as indicated by:
Area Radiation Monitor reading 1000 times normal annunciation on Panel 1C601 (2C601) or indication on Panel 1C600 (2C600).
SITE AREA EMERGENCY EAL# 6.3 None.
GENERAL EMERGENCY EAL# 6.4 None.
EP-AD-000-200, Revision 16, Page 13 of 39
TAB 7 EP-PS-126-7 7 - LOSS OF AC POWER UNUSUAL EVENT EAL# 7.1 Loss of offsite power or loss of all onsite AC power supplies as indicated by:
(A or B)
A. Loss of power to Startup Transformer 10 and 20 annunciation or indication on Panel 0C653.
or B. Failure of all diesel generators to start or synchronize to the emergency buses by indication or annunciation on Panel 0C653.
ALERT EAL# 7.2 Loss of all offsite power and all onsite AC power supplies as indicated by:
(A and B)
A. Loss of power to Startup Transformer 10 and 20 annunciation or indication on Panel 0C653.
and B. Failure of all diesel generators to start or synchronize to the emergency buses by annunciation or indication on Panel 0C653.
SITE AREA EMERGENCY EAL# 7.3 Loss of all offsite power and loss of all onsite AC power supplies for greater than 15 minutes as indicated by:
(A and B and C)
A. Loss of offsite power.
and B. Failure of all diesel generators to startup or synchronize to the emergency buses by indication or annunciation on 0C653.
and C. The above conditions exist for greater than 15 minutes.
GENERAL EMERGENCY EAL# 7.4 None.
EP-AD-000-200, Revision 16, Page 14 of 39
TAB 7 EP-PS-126-7 8 - LOSS OF CONTROL ROOM ALARMS AND ANNUNCIATORS UNUSUAL EVENT EAL# 8.1 None.
ALERT EAL# 8.2 Loss of all control room annunciators as indicated by:
In the opinion of the Shift Supervisor, all Control Room annunciators and the Plant Process Computer are lost, or insufficient annunciators are available to safely operate the unit(s) without supplemental observation of plant systems.
SITE AREA EMERGENCY EAL# 8.3 All annunciators lost and plant transient initiated while annunciators are lost as indicated by:
(A and B)
A. In the opinion of the Shift Supervisor, all Control Room annunciators and the Plant Process Computer are lost, or insufficient annunciators are available to safely operate the unit(s) without supplemental observation of plant systems.
and B. (1 or2 or3 or4)
- 1. Low-Low reactor water level indication on Panel 1C651-(2C651) followed by ECCS initiation on Panel 1C601 (2C601).
or
- 2. Reactor coolant temperature change greater than 100OF per hour indication on recorder TR-1 R006 on Panel 1C007 (2C007) (Reactor Building elevation 683').
or
- 3. High reactor pressure indication on Panel 1C651 (2C651) and followed by scram indication on Panel 1C651 (2C651).
or
- 4. Any indication that transient has occurred or is in progress.
GENERAL EMERGENCY EAL# 8.4 None.
EP-AD-000-200, Revision 16, Page 15 of 39
TAB 7 EP-PS-126-7 9 - LOSS OF DC POWER UNUSUAL EVENT EAL# 9.1 None.
ALERT EAL# 9.2 Loss of onsite vital DC power as indicated by:
(A and B)
A. Less than 210 volts on the 250 VDC main distribution Panel buses, 1D652 (2D652) and 1D662 (2D662) as indicated by trouble alarms on Panel 1C651 (2C651).
and B. Less than 105 volts on the 125 VDC main distribution buses 1D612 (2D612), 1D622 (2D622), 1 D632 (2D632), and 1D642 (2D642) as indicated by trouble alarms on Panel 1C651 (2C651).
NOTE: Buses are not tripped on undervoltage condition.
SITE AREA EMERGENCY EAL# 9.3 Loss of all vital onsite DC power sustained for greater than 15 minutes as indicated by:
(A and Band C)
A. Less than 210 volts on the 250 VDC main distribution Panel buses, 1D652 (2D652) and 1D662 (2D662) as indicated by trouble alarms on Panel 1C651 (2C651).
and B. Less than 105 volts on the 125 VDC main distribution buses 1D612 (2D612), 1D622 (2D622), 1D632 (2D632), and 1D642 (2D642) as indicated by trouble alarms on Panel 1C651 (2C651).
and C. The above condition exists for greater than 15 minutes.
NOTE: Buses are not tripped on undervoltage condition.
GENERAL EMERGENCY EAL# 9.4 None.
EP-AD-000-200, Revision 16, Page 16 of 39
TAB 7 EP-PS-126-7 10 - LOSS OF DECAY HEAT REMOVAL CAPABILITY UNUSUAL EVENT EAL# 10.1 None.
ALERT EAL# 10.2 Inability to remove decay heat while in plant condition 4, inability to maintain the plant in cold shutdown as indicated by:
Inability to maintain reactor coolant temperature less than 200OF with the reactor mode switch in shutdown; exception is when testing per Special Test Exception TS 3.10.1 which allows maximum temperature of 212 0 F.
SITE AREA EMERGENCY EAL# 10.3 Inability to remove decay heat while the plant is shutdown as indicated by:
(A and B and C)
A. Reactor Mode switch in shutdown.
and B. Reactor Coolant System temperature greater than 200OF and rising.
and C. Suppression Pool temperature greater than 120OF and rising.
GENERAL EMERGENCY EAL# 10.4 Inability to remove decay heat while the plant is shutdown with possible release of large amounts of radioactivity as indicated by:
(A and B and C)
A. Reactor mode switch in shutdown.
and B. Reactor coolant system temperature greater than 200OF and rising.
and C. Suppression pool temperature greater than 290°F indicated on the computer output (MAT 12,13,14,15 or 16).
EP-AD-000-200, Revision 16, Page 17 of 39
TAB 7 EP-PS-126-7 11 - LOSS OF REACTIVITY CONTROL UNUSUAL EVENT EAL# 11.1 Inadvertent Criticality as indicated by:
Unexpected increasing neutron flux indication on Panel 1C651 (2C651).
ALERT EAL# 11.2 Failure of the Reactor Protection System or the Alternate Rod Insertion System to initiate and complete a scram that brings the reactor subcritical as indicated by:
(A or B) and (C and D and E)
A. Trip of at least one sub-channel in each trip system (RPS A and RPS B) as indicated by annunciators and trip status lights on Panel 1C651 (2C651).
or B. Trip of both trip systems (ARI A and ARI B) as indicated by annunciators on Panel 1C601 (2C601).
and C. Failure of control rods to insert, confirmed by the full core display indication on Panel 1C651 (2C651) or process computer indications.
and D. Failure to bring the reactor subcritical confirmed by neutron count rate on the neutron monitoring indication on Panel 1C651 (2C651).
andd E. Reactor power >5% as indicated on Panel 1C651 (2C651).
(CONTINUED ON NEXT PAGE)
EP-AD-000-200, Revision 16, Page 18 of 39
TAB 7 EP-PS-126-7 11 - LOSS OF REACTIVITY CONTROL (continued)
SITE AREA EMERGENCY EAL# 11.3 Loss of functions needed to bring the reactor subcritical and loss of ability to bring the reactor to cold shutdown as indicated by:
(A and B and C and D)
A. Inability to insert sufficient control rods to bring the reactor subcritical as indicated by count rate on the neutron monitoring instrumentation on Panel 1C651 (2C651).
and B. (1 or2)
Failure of both loops of standby liquid control to inject into the vessel indicated by:
- 1. Low pump discharge pressure indication on Panel 1C601 (2C601).
or
- 2. Low flow indication on Panel 1C601 (2C601).
and C. Reactor coolant temperature greater than 200 0 F, indicated on Panel 1C651 (2C651).
and D. Reactor power >5% indicated on Panel 1C651 (2C651).
GENERAL EMERGENCY EAL# 11.4 Loss of functions needed to bring the reactor subcritical and transient in progress that makes release of large amounts of radioactivity in a short period possible as indicated by:
(A or B) and (C and D)
A. Trip of at least one sub-channel in each trip system (RPS A and RPS B), indicated by annunciation or trip status lights on Panel 1C651 (2C651).
or B. Trip of both systems (ARI A and ARI B) as indicated by annunciators on Panel 1C601 (2C601).
and C. Loss of SLC system capability to inject, indicated by instrumentation on Panel 1C601 (2C601).
and D. Reactor power greater than 25% of rated, indicated on Panel 1C651 (2C651).
EP-AD-000-200, Revision 16, Page 19 of 39
TAB 7 EP-PS-126-7 12 - LOSS OF REACTOR VESSEL INVENTORY UNUSUAL EVENT EAL# 12.1 Valid initiation of an Emergency Core Cooling System (ECCS) System as indicated by:
(A or B)
A. Initiation of an ECCS System and low, low, low reactor water level (-129) annunciation or indication on Panel 1C651 (2C651).
or B. Initiation of an ECCS System and High Drywell Pressure annunciation or indication on Panel 1C601 (2C601).
ALERT EAL# 12.2 Reactor coolant system leak rate greater than 50 gpm as indicated by:
(A or B)
A. Drywell floor drain sump A or B Hi-Hi alarm on Panel 1C601 (2C601) and 2 or more drywell floor drain pumps continuously running as indicated on Panel 1C601 (2C601).
or B. Other estimates of Reactor coolant system leakage indicating greater than 50 gpm.
SITE AREA EMERGENCY EAL# 12.3 Known loss of coolant accident greater than make-up capacity as indicated by:
Water level below (and failure to return to) top of active fuel for greater than three minutes as indicated on fuel zone level indicator on Panel 1C601 (2C601).
(CONTINUED ON NEXT PAGE)
EP-AD-000-200, Revision 16, Page 20 of 39
TAB 7 EP-PS-126-7 12 - LOSS OF REACTOR VESSEL INVENTORY (continued)
GENERAL EMERGENCY EAL# 12.4.a Loss of coolant accident with possibility of imminent release of large amounts of radioactivity as indicated by:
Water level below (and failure to return to) top of active fuel for greater than 20 minutes as indicated on fuel zone level indicator on Panel 1C601 (2C601).
OR EAL# 12.4.b Loss of Reactor Vessel inventory. Loss of 2 out of 3 fission product barriers (fuel cladding & reactor coolant pressure boundary) with potential loss of the third barrier (primary containment), as indicated by:
(A or B)
A. (1 and 2 and 3)
- 1. High drywell pressure annunciation or indication on Panel 1C601 (2C601).
and
- 2. (a orb orc)
- a. Containment pressure exceeds 40.4 PSIG as indicated on Panel 1C601 (2C601).
or
- b. A visual inspection of the containment indicates a potential or actual loss of containment (e.g. anchorage or penetration failure).
or
- c. Containment isolation valve(s) fail to close as indicated by valve position
- indication on Panel 1C601 (2C601).
and
- 3. Reactor Vessel level drops below (and fails to return to) top of active fuel for greater than three minutes as indicated on fuel zone level indicator on Panel 1C601 (2C601).
or B. (1 and 2)
- 1. Failure of reactor pressure vessel isolation valves to isolate coolant break outside containment as indicated by valve position indication on Panel 1C601 (2C601) or visual inspection.
and
- 2. Reactor vessel level drops below (and fails to return to) top of active fuel for greater than three minutes as indicated on fuel zone level indicator on Panel 1C601 (2C601).
EP-AD-000-200, Revision 16, Page 21 of 39
TAB 7 EP-PS-126-7 13 - NATURAL PHENOMENA UNUSUAL EVENT EAL# 13.1 Natural phenomenon occurrence as indicated by:
(A or B or C)
A. Tornado impact on site.
or B. Hurricane impact on site.
or C. Earthquake detected by seismic instrumentation systems on Panel 0C696.
ALERT EAL# 13.2 Natural Phenomenon Occurrence as indicated by:
(A or B or C)
A. Tornado with reported wind velocities greater than 200 mph impacting on site.*
or B. Reported hurricane or sustained winds greater than 70 mph.*
or C. Earthquake at greater than operating basis earthquake (OBE) levels as indicated on Panel 0C696.
- Telephone numbers for the National Weather Bureau are located in the Emergency Telephone Directory.
(CONTINUED ON NEXT PAGE)
EP-AD-000-200, Revision 16, Page 22 of 39
TAB 7 EP-PS-126-7 13 - NATURAL PHENOMENA (continued)
SITE AREA EMERGENCY EAL# 13.3 Severe natural phenomenon occurrence, with plant not in cold shutdown, as indicated by:
(A and B)
A. Reactor Coolant Temperature greater than 200OF as indicated on Panel 1C651 (2C651).
and B. (1 or2 or3)
- 1. Reported hurricane or sustained winds greater than 80 mph.*
or
- 2. Earthquake with greater than Safe Shutdown Earthquake (SSE) levels as indicated on Panel 0C696.
or
- 3. Tornado with reported wind velocities greater than 220 mph impacting on site.*
GENERAL EMERGENCY EAL# 13.4 None.
- Telephone niumbers for the National Weather Bureau are located in the Emergency Telephone Directory.
EP-AD-000-200, Revision 16, Page 23 of 39
TAB 7 EP-PS-126-7 14 - ONSITE FIREIEXPLOSION UNUSUAL EVENT EAL# 14.1 Significant fire within the plant as indicated by:
(A and B)
A. Activation of fire brigade by Shift Supervisor.
and B. Duration of fire longer than 15 minutes after time of notification.
OR Explosion inside security protected area, with no significant damage to station facilities, as indicated by:
Visual observation or notification received by control room operator and Shift Supervisor evaluation.
ALERT EAL# 14.2 On-site Fire/Explosion as indicated by:
(A or B)
A. Fire lasting more than 15 minutes and fire is in the vicinity of equipment required for safe shutdown of the plant and the fire is damaging or is threatening to damage the equipfnent due to heat, smoke, flame, or other hazard.
or B. (1 and 2)
Explosion damage to facility affecting plant operation as determined by:
- 1. Direct observation or notification received by control room operator.
and
- 2. Shift Supervisor observation.
(CONTINUED ON NEXT PAGE)
EP-AD-000-200, Revision 16, Page 24 of 39
TAB 7 EP-PS-126-7 14 - ONSITE FIRE/EXPLOSION (continued)
SITE AREA EMERGENCY EAL# 14.3 Damage to safe shutdown equipment due to fire or explosion has occurred when plant is not in cold shutdown, and damage is causing or threatens malfunction of equipment required for safe shutdown of the plant as determined by:
(A and B and C)
A. Direct -observation or notification received by control room operator.
and B. Shift Supervisor evaluation.
and C. Reactor Coolant Temperature greater than 200OF as indicated on Panel 1C651 (2C651).
GENERAL EMERGENCY EAL# 14.4 None.
EP-AD-000-200, Revision 16, Page 25 of 39
TAB 7 EP-PS-126-7 15 - RADIOLOGICAL EFFLUENT UNUSUAL EVENT EAL# 15.1.a Radiological gaseous effluents exceed 2 times the Technical Requirement Limits for 60 minutes or longer as indicated by:
(A or B)
A. Valid Building Vent Stack Monitoring System (SPING) indications on Panel 0C630 or 0C677.
- 1. Noble gases >1.70E+6 jiCi/min., or
- 2. 1-131 >2.08E+2 p4Ci/min., or
- 3. Particulate >1.54E+3 pCi/min., or or B. Confirmed sample analyses for gaseous releases indicating total site release rates exceed:
- 1. Noble gases >1000 mrem/year whole body, or
- 2. Noble gases >6000 mrem/year skin, or
- 3. 1-131, 1-133, H-3, and particulates with half-lives >8 days >3000 mrem/year to any organ (inhalation pathways only).
OR EAL# 15.1.b Radiological liquid effluents exceed Technical Requirement Limits for instantaneous release as indicated by:
Report of radiological liquid effluent exceeding Technical RequLrement Limits. This includes effluent sources such as Service Water or RHR Service Water Loops A or B.
(CONTINUED ON NEXT PAGE)
EP-AD-000-200, Revision 16, Page 26 of 39
TAB 7 EP-PS-126-7 15- RADIOLOGICAL EFFLUENT (continued)
ALERT EAL# 15.2.a Radiological gaseous effluents exceed 200 times the Technical Requirement Limits for 15 minutes or longer as indicated by:
(A or B)
A. Valid Building Vent Stack Monitoring System (SPING) indications on Panel 0C630 or 0C677.
- 1. Noble gases >1.70E+8 gCi/min., or
- 2. 1-131 >2.08E+4 jgCi/min., or 3., Particulate >1.54E+5 gCi/min.
or B. Confirmed sample analyses for gaseous releases indicating total site release rates exceed:
- 1. Noble gases >1.0E+5 mrem/year whole body, or
- 2. Noble gases >6.OE+5 mrem/year skin, or
- 3. 1-131, 1-133, H-3, and particulates with half-lives >8 days >3.OE+5 mrem/year to any organ (inhalation pathways only).
OR EAL# 15.2.b Radiological liquid effluents exceed 10 times Technical Requirement Limits for instantaneous release as indicated by:
Report of radiological liquid effluent release exceeding 10 tines Technical Requirement Limits. This includes effluent sources such as Service Water or RHR Service Water Loops AorB.
(CONTINUED ON NEXT PAGE)
EP-AD-000-200, Revision 16, Page 27 of 39
TAB 7 EP-PS-126-7 15- RADIOLOGICAL EFFLUENT (continued)
SITE AREA EMERGENCY EAL# 15.3 Radiological effluent corresponds to greater than 50 mrem W.B.(1 ) or 250 mrem thyroid(2) for a half-hour or 500 mrem W.B.(1) or 2500 mrem thyroid(2) for 2 minutes at the emergency plan boundary as indicated by:
OR Emergency plan boundary dose is projected to exceed 500 mrem W.B. (1)within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> as indicated by:
(A or B)
A. Dose projections based on:
(1 or2)
- 1. Building vent stack monitoring system indications on Panel 0C630 or 0C677.
or
- 2. Field monitoring data onsite or offsite.
or B. Dose projections based on:
(1 or2)
- 1. Building vent stack monitoring system indications on Panel 0C630 or 0C677.
or
- 2. Field monitoring data onsite or offsite (CONTINUED ON NEXT PAGE)
(1) The sum of the Effective Dose Equivalent resulting from the exposure to external sources and the Committed Effective Dose Equivalent incurred from all significant inhalation pathways during the early phase.
(2) Committed Dose Equivalent to the thyroid from radioiodine.
EP-AD-000-200, Revision 16, Page 28 of 39
TAB 7 EP-PS-126-7 15- RADIOLOGICAL EFFLUENT (continued)
GENERAL EMERGENCY EAL# 15.4 Radiological effluent release corresponds to 1 rem whole body(1 ) or 5 rem( 2 ) thyroid at the emergency plan boundary as indicated by:
OR Offsite doses are projected to exceed 1 rem whole body0i) or 5 rem thyroid(2 ) due to the event as indicated by:
(A or B)
A. Dose projections based on:
(1 or2 or3)
- 1. Building Vent Stack Monitoring System indication on Panel 0C630 or 0C677.
or
- 2. Field monitoring data onsite or offsite.
or
- 3. In-plant conditions.
or B. Dose projections based on:
(1 or2 or3)
- 1. Building Vent Stack Monitoring System indication on Panel 0C630 or 0C677.
or
- 2. Field monitoring data onsite or offsite.
or
- 3. In-plant conditions.
(1) The sum of the Effective Dose Equivalent resulting from the exposure to external sources and the Committed Effective Dose Equivalent incurred from all significant inhalation pathways during the early phase.
(2) Committed Dose Equivalent to the thyroid from radioiodine.
EP-AD-000-200, Revision 16, Page 29 of 39
TAB 7 EP-PS-126-7 16 - SECURITY EVENT UNUSUAL EVENT EAL# 16.1 Security threat or attempted entry or attempted sabotage as indicated by:
(AorBorC)
A. A report from Security of a security threat, attempted entry, or attempted sabotage of the owner controlled area adjacent to the site.
or B. Any attempted act of sabotage which is deemed legitimate in the judgment of the SHIFT SUPERVISOR/EMERGENCY DIRECTOR, and affects plant operation.
or C. A site specific credible security threat notification.
ALERT EAL# 16.2 Ongoing Security Compromise as indicated by:
(A or B)
A. A report from Security that a security compromise is at the site but no penetration of protected areas has occurred.
or B. Any act of sabotage which results in an actual or potential substantial degradation of the level of safety of the plant as judged by the SHIFT SUPERVISOR/EMERGENCY DIRECTOR.
SITE AREA EMERGENCY EAL# 16.3 An ongoing adversary event threatens imminent loss of physical control of plant as indicated by:
(A or B)
A. Report from Security that the security of the plant vital area is threatened by unauthorized (forcible) entry into the protected area.
or B. Any act of sabotage which results in actual or likely major failures of plant functions needed for protection of the public as judged by the SHIFT SUPERVISOR/EMERGENCY DIRECTOR.
(CONTINUED ON NEXT PAGE)
EP-AD-000-200, Revision 16, Page 30 of 39
TAB 7 EP-PS-126-7 16 - SECURITY EVENT (continued)
GENERAL EMERGENCY EAL# 16.4 Loss of physical control of facilities as indicated by:
(A or B)
A. Report from Security that a loss of physical control of plant vital areas has occurred.
or B. Any act of sabotage which results in imminent significant cladding failure or fuel melting with a potential for loss of containment integrity or the potential for release of significant amounts of radioactivity in a short time as judged by the SHIFT SUPERVISOR/EMERGENCY DIRECTOR.
EP-AD-000-200, Revision 16, Page 31 of 39
TAB 7 EP-PS-126-7 17 - SPENT FUEL RELATED INCIDENT UNUSUAL EVENT EAL# 17.1 Unanticipated or unplanned concentrations of airborne activity exist in normally accessible areas, which is not due to planned maintenance activities, as indicated by:
Concentrations exceed 500 times the DAC values of 10CFR20 Appendix B, Table I values for a single isotope, or full multiple isotopes where CA -+ CB +/- Cc CN >500 0
DACA DACB DACc DACN ALERT EAL# 17.2 Unexpected in-plant high radiation levels or airborne contamination which indicates a severe fuel handling accident as indicated by:
Refuel floor area radiation monitor reading 1000 times normal annunciation on Panel 1C601 (2C601) or indication on Panel 1C600 (2C600).
(CONTINUED ON NEXT PAGE)
EP-AD-000-200, Revision 16, Page 32 of 39
TAB 7 EP-PS-126-7 17 - SPENT FUEL RELATED INCIDENT (continued)
SITE AREA EMERGENCY EAL# 17.3.a Major damage to irradiated fuel with actual or clear potential for significant release of radioactive material to the environment as indicated by:
(A and B)
A. Dropping, bumping, or otherwise rough handling of a new OR irradiated fuel bundle with irradiated fuel in the pool.
and B. (1 or2)
- 1. Refueling floor area radiation monitor reading 1000 times normal annunciation on Panel 1C601 (2C601) or indication on Panel 1C600 (2C600).
or
- 2. Reactor Building vent stack monitoring system high radiation annunciation or indication on Panel 0C630 or 0C677.
OR EAL# 17.3.b Damage to irradiated fuel due to uncontrolled decrease in the fuel pool level to below the level of the fuel as indicated by:
(A and B)
A. (1 or2)
- 1. Uncovering of irradiated fuel confirmation by verification of significant leakage from spent fuel pool.
or
- 2. Visual observation of water level below irradiated fuel in the pool.
and B. (1 or 2)
- 1. Refueling floor area radiation monitor annunciation on Panel 1C651 (2C651) or indication on Panel 1C600 (2C600).
or
- 2. Reactor Building vent stack monitoring system high radiation annunciation or indication on Panel 0C630 or 0C677.
GENERAL EMERGENCY EAL# 17.4 None.
EP-AD-000-200, Revision 16, Page 33 of 39
TAB 7 EP-PS-126-7 18 - STEAM LINE BREAK UNUSUAL EVENT EAL# 18.1 None.
ALERT EAL# 18.2 MSIV malfunction causing leakage as indicated by:
(A and B)
A. Valid MSIV closure signal or indication on Panel 1C601 (2C601).
and B. (1 or2)
- 1. Valid Main Steam Line flow indication on Panel 1C652 (2C652).
or
- 2. Valid Main Steam Line radiation indication on Panel 1C600 (2C600).
(CONTINUED ON NEXT PAGE)
EP-AD-000-200, Revision 16, Page 34 of 39
TAB 7 EP-PS-126-7 18 - STEAM LINE BREAK (continued)
SITE AREA EMERGENCY EAL# 18.3 Steam line break occurs outside of containment without isolation as indicated by:
(A or B or C or D)
A. (1 and 2)
- 1. Failure of both MSIVs in the line with the leak to close as indicated by position indication on Panel 1C601 (2C601).
and
- 2. (a orb)
- a. High MSL flow annunciation on Panel 1C601 (2C601) or indication on Panel 1C652 (2C652).
or
- b. Other indication of main steam leakage outside containment.
or B. (1 and 2)
- 1. Failure of RCIC steam isolation valves HV-F008 and HV-F007 to close as indicated on Panel 1C601 (2C601).
and
- 2. (aorborcordoreorf)
- a. RCIC steamline pipe routing area high temperature annunciation on Panel 1C601 (2C601), or indication on Panel 1C614 (2C614).
or
- b. - RCIC equipment area high temperature annunciation on Panel 1C601 (2C601) or indication on Panel 1C614 (2C614).
or
- c. RCIC steamline high flow annunciation on Panel 1C601 (2C601).
or
- d. RCIC steamline tunnel ventilation high delta temperature annunciation on Panel 1C601 (2C601).
or
or
- f. Other indication of steam leakage from the RCIC system.
(CONTINUED ON NEXT PAGE)
EP-AD-000-200, Revision 16, Page 35 of 39
TAB 7 EP-PS-126-7 18 - STEAM LINE BREAK (continued)
SITE AREA EMERGENCY (continued) or C. (1 and 2)
- 1. Failure of HPCI steam isolation valves HV-F002 and HV-F003 to close as indicated by position indicator on Panel 1C601 (2C601).
and
- 2. (aorborcordoreorf)
- a. HPCI steamline pipe routing area high temperature annunciation on Panel 1C601 (2C601), or indication on Panel 1C614 (2C614).
or
- b. HPCI equipment area high temperature annunciation on Panel 1C601 (2C601) or indication on Panel 1C614 (2C614).
or
- c. HPCI steamline high flow annunciation on Panel 1C601 (2C601).
or
- d. HPCI steamline tunnel ventilation high delta temperature annunciation on Panel 1C601 (2C601).
or
or
- f. Other indication of steam leakage from the HPCI system.
or_.
D. Any other un-isolatable steam line breaks.
GENERAL EMERGENCY EAL# 18.4 None.
EP-AD-000-200, Revision 16, Page 36 of 39
TAB 7 EP-PS-126-7 19 - TOXIC/FLAMMABLE GASES UNUSUAL EVENT EAL# 19.1 Nearby or onsite release of potentially harmful quantifies of toxic or flammable material as indicated by:
Visual observation or notification received by the control room operator.
ALERT EAL# 19.2 Entry of toxic or flammable gases into the facility, with subsequent habitability problem as indicated by:
Visual observation, direct measurement, or notification received by the control room operator.
SITE AREA EMERGENCY EAL# 19.3 Toxic or flammable gases enter vital areas, restricting access and restricted access constitutes a safety problem, as determined by:
(A and B)
A. Shift Supervisor's evaluation.
and B. Visual observation, direct measurement, or notification- received by control room operator.
GENERAL EMERGENCY EAL# 19.4 None.
EP-AD-000-200, Revision 16, Page 37 of 39
TAB 7 EP-PS-126-7 20 - TECHNICAL SPECIFICATION SAFETY LIMIT UNUSUAL EVENT EAL# 20.1 Abnormal occurrences which result in operator complying with any of the Technical Specification SAFETY LIMIT ACTION statements indicated by:
(A or B or C or D)
A. Exceeding THERMAL POWER, low pressure or low flow safety limit 2.1 .1 .1.
or B. Exceeding THERMAL POWER, high pressure and high flow safety limit 2.1.1.2.
or C. Exceeding REACTOR VESSEL WATER LEVEL safety limit 2.1.1.3.
or D. Exceeding REACTOR COOLANT SYSTEM PRESSURE safety limit 2.1.2.
ALERT EAL# 20.2 None.
SITE AREA EMERGENCY EAL# 20.3 None.
GENERAL EMERGENCY EAL# 20.4 None.
EP-AD-000-200, Revision 16, Page 38 of 39
TAB 7 EP-PS-126-7 21 - DRY FUEL STORAGE UNUSUAL EVENT EAL# 21.1.a. Situations are occurring or have occurred during the transport of the irradiated spent fuel to the onsite storage facility, which jeopardize the integrity of the spent fuel or its container as indicated by:
(A or B)
A. Radiological readings exceed 2 R/hour at the external surface of any transfer cask or horizontal storage module.
or B. Radiological readings exceed 1 R/hour one foot away from the external surface of any transfer cask or horizontal storage module.
OR EAL# 21.1.b. Situations are occurring or have occurred at the irradiated spent fuel storage facility, which jeopardize the integrity of the dry cask storage system as indicated by:
(A or B)
A. Radiological readings exceed 2 R/hour at the external surface of any transfer cask or horizontal storage module.
or B. Radiological readings exceed 1 R/hour one foot away from the external surface of any transfer cask or horizontal storage module.
ALERT EAL# 21.2 None.
SITE AREA EMERGENCY EAL# 21.3 None.
GENERAL EMERGENCY EAL# 21.4 None.
EP-AD-000-200, Revision 16, Page 39 of 39