ML020640463

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Revision 27 to EP-101, Classification of Emergencies.
ML020640463
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 02/13/2002
From: Laubenstein S
Detroit Edison
To:
Document Control Desk, Office of Nuclear Security and Incident Response
References
EP-101 Revision 27
Download: ML020640463 (60)


Text

February 13, 2002 Enclosed per your request is the current "Controlled" copy of EP-1O1 from Fermi 2. Please note that the coloredpages were copied in black & white also per your request. If you have any questions,please feel free to contact me @ 734.586.4338 or laubensteins@dteenergy.com. Thank you!

Sharon Laubenstein

Fermi 2 EP-101 RERP Plan Implementing Procedure Revision 27 Page 1 CLASSIFICATION OF EMERGENCIES Revision Summary

1) Deleted commitments throughout Section 4.0.
2) Added "using nuclide analysis method" to EAL #1 of AA1 in Enclosure A, Tab A.
3) Added 15 minute duration qualifier to EAL #1 of HA2 in Enclosure A, Tab H.
4) Added EAL #4 for a confirmed credible site-specific security threat notification to HU4 in Enclosure A, Tab H.
5) Revised HGl to reflect intent of EALs as being loss of physical control of facility in Enclosure A, Tab H, and Enclosure B, Tab H.
6) Changed Nuclear Shift Supervisor (NSS) to Shift Manager (SM) in Enclosure A, Tabs H and S.

Implementation Plan

1) This revision goes into effect upon issuance and upon completion of all implementation requirements for LCR 01-014-REP.

Attachments - None Enclosures A Emergency Action Levels 121101 Tab A Recognition Category A - Abnormal Rad Levels/Radiological Effluent 120100 Tab F Recognition Category F - Fission Product Barrier Degradation 121101 Tab H Recognition Category H - Hazards and Other Conditions Affecting Plant Safety 121101 Tab S Recognition Category S - System Malfunctions B Initiating Condition Matrix CONTROLLED 121101 Tab A Abnormal Rad Levels/Radiological Effluent 121101 Tab F Fission Product Barrier Degradation 121101 Tab H Hazards and other Conditions Affecting Plant Safety 121101 Tab S System Malfunction

EP-101 Revision 27 Page 2 1.0 PURPOSE To provide a guide for identifying initiating conditions for proper classification of emergencies.

2.0 USE REFERENCES 2.1 29.100.01, Sheet 1, RPV Control 29.100.01, Sheet 1A, RPV Control - ATWS 2.2 29.100.01, Sheet 2, Primary Containment Control 2.3 29.100.01, Sheet 3, Emergency Depressurization. Steam Cooling, RPV and PC Flooding 29.100.01, Sheet 3A, Emergency Depressurization, Steam Cooling, RPV and PC Flooding ATWS 2.4 29.100.01, Sheet 4, Primary Containment H2/0 2 Control 2.5 29.100.01, Sheet 5, Secondary Containment and Rad Release 2.6 29.100.01, Sheet 6, Curves, Cautions. and Tables 3.0 ENTRY CONDITIONS 3.1 Conditions exist that require use of Abnormal Operating Procedures, Emergency Operating Procedures, or entry into a Technical Specification Limiting Condition for Operation.

and 3.2 Conditions exist that may require classification in accordance with the emergency action levels in Enclosure A.

4.0 GENERAL INFORMATION 4.1 Detailed emergency action levels are listed for each initiating condition under each category of events in Enclosure A. Categories and conditions are summarized in a matrix format in Enclosure B.

EP-101 Revision 27 Page 3 4.2 The following is a list of event categories by tab in Enclosure A ZI_

1 4.2.1 Tab A Abnormal Rad Levels/Radiological Effluent 4.2.2 Tab F Fission Product Barrier Degradation 4.2.3 Tab H Hazards and Other Conditions Affecting Plant Safety 4.2.4 Tab S System Malfunctions 4.3 Control Room Chain of Command 4.3.1 The Shift Manager shall:

1. Perform initial evaluation of any abnormal or emergency situation.
2. Ensure the appropriate actions of applicable Abnormal and Emergency Operating Procedures are performed.
3. Ensure a determination is made of:
a. Magnitude of the emergency conditions
b. Whether or not a potential hazard exists to the health and safety of site personnel or the general public
4. Classify the emergency condition using the initiating conditions and emergency action levels of Enclosure A.
5. Assume the position of Emergency Director until properly relieved or until the emergency is terminated.
6. Continue to evaluate the emergency condition and make classification recommendations to the Emergency Director in the Technical Support Center (TSC) when the TSC is functional.

4.3.2 The Control Room Supervisor shall assume the responsibilities of the Shift Manager if the he/she is absent or incapacitated.

4.4 The Emergency Director (Plant Manager/alternate) shall:

4.4.1 Evaluate and assess the emergency condition.

EP-101 Revision 27 Page 4 4.4.2 Perform the following actions:

1. Classify/reclassify the emergency.
2. Authorize emergency response personnel to exceed radiation exposure limits delineated in 10 CFR 20, if required.
3. Augment the Emergency Response Organization as appropriate for the severity of the emergency
4. Recommend protective actions to offsite authorities when appropriate 4.5 Emergency Class Definitions 4.5.1 Unusual Event - Events are in process or have occurred that indicate a potential degradation of the level of safety of the plant. No release of radioactive material requiring offsite response or monitoring is expected.

4.5.2 Alert - Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the Environmental Protection Agency (EPA) Protection Action Guidelines exposure levels.

4.5.3 Site Area Emergency - Events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public. Any releases are not expected to exceed Environmental Protection Agency (EPA) Protection Action Guidelines exposure levels except at or near the site boundary.

4.5.4 General Emergency - Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed Environmental Protection Agency (EPA) Protection Action Guidelines exposure levels offsite for more than the immediate site area.

5.0 IMMEDIATE ACTIONS - None

EP-101 Revision 27 Page 5 6.0 PROCEDURE 6.1 The Emergency Director shall:

6.1.1 Verify initial emergency indications (such as an alarm or surveillance report) by such means as:

1. Comparison with redundant instrument channels
2. Comparison with other related plant parameters
3. Physical observations
4. Field measurements 6.1.2 Determine appropriate emergency classification by comparing verified plant conditions with the initiating conditions identified in Enclosure A or B, and the emergency action levels in Enclosure A.

6.1.3 Take actions in accordance with:

1. EP-102, "Unusual Event"
2. EP-103, "Alert"
3. EP-104, "Site Are Emergency"
4. EP-105, "General Emergency" 7.0 FOLLOW-UP ACTIONS 7.1 Continually assess the emergency situation. As necessary, upgrade, de-escalate, or terminate the emergency classification as more definitive information becomes available, and/or if plant conditions change.

7.1.1 Eliminating one or more of the conditions constituting an event classification does not necessarily ensure the event can be de-escalated or terminated.

7.1.2 Use EP- 102, EP- 103, EP- 104, and EP- 105 for criteria on de-escalation and termination of the emergency.

7.2 Continue to perform this procedure until event is terminated.

EP-101 Revision 27 Page 6 8.0 RECORDS There are no required records generated through the performance of this procedure.

END OF TEXT

EP-101 Enclosure A, Tab A Page A-1 121101 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT UNUSUAL EVENT AU1 Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds Two Times the Values of ODCM Control 3.11.2.1 or 3.11.1.1 for 60 Minutes or Longer OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Note: If a valid monitor reading indicates a release of radioactivity that may be in excess of 2 times the ODCM Control value for greater than 60 minutes, and it is not confirmed by sample analysis within that time. then the declaration must be based on the valid monitor reading. Confirmatory sample and analysis in response to reaching AU1 monitor EAL value is done for the purpose of both confirming the existence of the uncontrolled condition (AU1/AA1) and also to verify that there is no radiological hazard (AS 1/AG1).

A valid monitor reading from the table below which exceeds the corresponding value may indicate a release in excess of 2 times the ODCM Control 3.11.2.1 or 3.11.1.1 value, and warrants immediate confirmation by sampling and analysis in accordance with ODCM methodology or by performing dose assessment using nuclide analysis method.

EMuent Monilor Channel Reading RB SPING 5 4.6E-3 uCi/cc SGTS I SPING 7 5.3E-2 puCi/cc SGTS II SPING 7 4.6E-2 pCi/cc RW SPING 5 4.9E-3 pCi/cc TB SPING 5 3.3E-4 pCi/cc CW Decant N/A 2600 cpm

2. Valid projection of Actual Dose indicates a dose rate in excess of 0.1 mRem/hr TEDE at the site boundary using computerized dose assessment by nuclide analysis method, with the condition sustained for a duration of 60 minutes or greater
3. Valid sample analysis of gaseous or liquid effluent release using ODCM methodology indicates a release rate or concentration in excess of 2 times the ODCM Control 3.11.2.1 or 3.11.1.1 value, with the condition sustained for a duration of 60 minutes or greater

EP-101 Enclosure A, Tab A Page A-2 121101 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT ALERT AA1 Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times the Values of ODCM Control 3.11.2.1 or 3.11.1.1 for 15 Minutes or Longer OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Note: If a valid monitor reading indicates a release of radioactivity that may be in excess of 200 times the ODCM Control value for greater than 15 minutes, and it is not confirmed by sample analysis within that time. then the declaration must be based on the valid monitor reading. Confirmatory sample and analysis in response to reaching AA1 monitor EAL value is done for the purpose of both confirming the existence of the uncontrolled condition (AU1/AAI) and also to verify that there is no radiological hazard (AS 1/AGI).

A valid monitor reading from the table below which exceeds the corresponding value may indicate a release in excess of 200 times the ODCM Control 3.11.2.1 or 3.11.1.1 value, and warrants immediate confirmation by sampling and analysis in accordance with ODCM methodology or by performing dose assessment using nuclide analysis method.

Effluent Channel Reading Monitor Div I AXM 4 5.3 uCi/cc Div 11AXM 4 4.6 ,Ci/cc CW Decant N/A 2.6E5 cpm

2. Valid projection of Actual Dose indicates a dose rate in excess of 10 mRem/hr TEDE at the site boundary using computerized dose assessment by nuclide analysis method, with the condition sustained for a duration of 15 minutes or greater
3. Valid sample analysis of gaseous or liquid effluent release using ODCM methodology indicates a release rate or concentration in excess of 200 times the ODCM Control 3.11.2.1 or 3.11.1.1 value, with the condition sustained for a duration of 15 minutes or greater

EP-101 Enclosure A, Tab A Page A-3 121101 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT SITE AREA EMERGENCY AS1 Site Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mrem TEDE or 500 mrem Adult Thyroid for the Actual or Projected Duration of the Release OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Note: If a valid monitor reading indicates a release of radioactivity that may result in a Site Boundary Doses in excess of 100 mrem TEDE or 500 mrem Adult Thyroid for greater than 15 minutes, and it is not confirmed by sample analysis or dose projection within that time, then the declaration must be based on the valid monitor reading.

A valid monitor reading of greater than 80 yCi/cc on SGTS DIV 1/1I AXM, Channel 3, may indicate a release resulting in Site Boundary Dose Rates in excess of 100 mrem/hr TEDE or 500 mrem/hr Adult Thyroid. and warrants immediate confirmation by sampling and analysis in accordance with ODCM methodology or by performing dose assessment.

2. Valid projection of Actual or Potential Dose indicates a dose in excess of 100 mrem TEDE or 500 mrem Adult Thyroid at the Site Boundary for the projected duration of the release
3. Site Boundary Dose Rate measurements in excess of 100 mrem/hr expected to continue for more than one hour, or a sample analysis indicating a combined radioiodine concentration in excess of 20 DAC expected to continue for more than one hour

EP-101 Enclosure A, Tab A Page A-4 121101 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT GENERAL EMERGENCY AGI Site Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 1000 mrem TEDE or 5000 mrem Adult Thyroid for the Actual or Projected Duration of the Release Using Actual Meteorology OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Note: If a valid monitor reading indicates a release of radioactivity that may result in Site Boundary Doses in excess of 1000 mrem TEDE or 5000 mrem Adult Thyroid for greater than 15 minutes, and it is not confirmed by dose projection within that time, then the declaration must be based on the valid monitor reading.

A valid monitor reading of greater than 800,uCi/cc on SGTS DIV 1I/I AXM, Channel 3, may indicate a release resulting in Site Boundary Dose Rates in excess of 1000 mRemlhr TEDE or 5000 mRem/hr Adult Thyroid. and warrants immediate confirmation by sampling and analysis in accordance with ODCM methodology or by performing dose assessment.

2. Valid projection of Actual or Potential Dose indicates a dose in excess of 1000 mrem TEDE or 5000 mrem Adult Thyroid for the projected duration of the release
3. Site Boundary Dose Rate measurements in excess of 1000 mrem/hr expected to continue for more than one hour; or a sample analysis indicating a combined radioiodine concentration in excess of 200 DAC expected to continue for more than one hour

EP-101 Enclosure A. Tab A Page A-5 121101 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT UNUSUAL EVENT AU2 Unexpected Increase of Plant Radiation Levels OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Uncontrolled water level decrease in the reactor refueling cavity with level at 619 inches and lowering by Floodup Level Indicator or 20 feet and lowering by visual indication, with all irradiated fuel assemblies remaining covered by water
2. Uncontrolled water level decrease in the spent fuel storage pool with level at 21.5 feet and lowering by visual indication, with all irradiated fuel assemblies remaining covered by water
3. Valid direct Area Radiation Monitor readings which exceed the Maximum Normal Operating Level of 29.100.01. Sheet 5. Table 14, inside secondary containment, or which have increased by a factor of 1000 over normal* levels in other areas of the plant
  • Normal levels can be considered as the highest reading in the past twenty-four hours excluding the current peak value

EP-101 Enclosure A, Tab A Page A-6 121101 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT ALERT AA2 Major Damage to Irradiated Fuel or Loss of Water Level That Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. An unplanned valid alarm of ARM Channel 18. Refuel Area High Radiation Monitor, reading >1000 mR/hr
2. An unplanned valid alarm of ARM Channels 15 and 17, Fuel Storage Pool and Refuel Area Low Range Radiation Monitors, and a valid trip of the Fuel Pool Area Ventilation Exhaust Radiation Monitor indicated by Annunciator 3D35, DIV I/II FP VENT EXH RADN MONITOR UPSCALE TRIP
3. Report of visual indication of irradiated fuel uncovered
4. Spent Fuel Pool Water Level below the bottom of the Spent Fuel Pool Gates and lowering indicating a loss of inventory which will result in uncovering irradiated fuel

EP-101 Enclosure A. Tab A Page A-7 121101 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT ALERT AA3 Releases of Radioactive Material or Increases in Radiation Levels Within the Facility That Impede Operation of Systems Required to Maintain Safe Operations or to Establish or Maintain Cold Shutdown OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Valid reading on ARM Channel 6, Control Room Direct Area Radiation Monitor, GREATER THAN 15 mR/hr
2. Valid, unplanned, direct Area Radiation Monitor readings which exceed the Maximum Safe Operating Level of 29.100.01, Sheet 5, Table 14

EP-101 Enclosure A, Tab F Page F-i 120100 FISSION PRODUCT BARRIER DEGRADATION OPERATING MODE APPLICABILITY: 1, 2,3 UNUSUAL EVENT FU1 Any Loss or Any Potential Loss of Primary Containment ALERT FA1 Any Loss or Any Potential Loss of Either Fuel Clad or Reactor Coolant System SITE AREA EMERGENCY FS1 Loss or Potential Loss of Any Two Barriers GENERAL EMERGENCY FG 1 Loss of Any Two Barriers and Potential Loss of Third Barrier

EP-101 Enclosure A, Tab F Page F-2 120100 FUEL CLAD BARRIER EALS LOSS POTENTIAL LOSS RPV Water Level 1. RPV Water Level RPV Water Level less RPV Water Level less than 0 inches than -40 inches

2. Containment Radiation CHRRM reading greater than 2.500 R/hr
3. Primary Coolant Activity Level Primary coolant activity level greater than 300 pCi/gm DE 1-131 (see SU4 also)
4. Determination of release of at Least 5%

of the Gap Activity from the Fuel

5. Emergency Director Judgment 5. Emergency Director Judgment Any condition in the judgment of the Any condition in the judgment of the Emergency Director that indicates Loss of Emergency Director that indicates a the Fuel Clad Barrier Potential Loss of the Fuel Clad Barrier

EP-101 Enclosure A, Tab F Page F-3 120100 REACTOR COOLANT BARRIER EALS LOSS POTENTIAL LOSS RPV Water Level RPV Water Level less than 0 inches

2. Reactor Coolant Leak Rate*

Reactor Coolant unidentified leakage greater than 50 gpm inside the Drywell, or Unisolable Primary System leakage outside Drywell as indicated by isolation mimic, or exceeding a maximum safe operating Secondary Containment temperature or radiation level of 29.100.01, Sheet 5, Table 12 or 14 (see SU5 and SA6 also)

3. Drywell Pressure Drywell pressure greater than 1.68 psig
4. Containment Radiation CHRRM reading greater than 5 R/hr two minutes after reactor shutdown or beyond
5. Emergency Director Judgment 5. Emergency Director Judgment Any condition in the judgment of the Any condition in the judgment of the Emergency Director that indicates Loss of the Emergency Director that indicates a Reactor Coolant Barrier Potential Loss of the Reactor Coolant Barrier Stuck open SRV is not a Reactor Coolant Barrier loss or potential loss unless there is a concurrent loss of the Fuel Clad Barrier, in which case the stuck open SRV constitutes a potential loss of the Reactor Coolant Barrier (FS I applies).

EP-101 Enclosure A, Tab F Page F-4 120100 PRIMARY CONTAINMENT BARRIER EALS LOSS POTENTIAL LOSS**

1. RPV Water Level*

RPV Water Level less than -40 inches or unknown AND Maximum Core Uncovery Time Limit (MCUTL) of 29.100.01, Sheet 6, is exceeded

2. Containment Isolation Valve Status After Containment Isolation Failure of both valves in any one line to close and downstream pathway to the environment exists, or Containment venting requiring trip defeat per EOPs, or Unisolable Primary System leakage outside Drywell as indicated by isolation mirmc. or exceeding a Secondary Containment maximum safe operating temperature or radiation level of 29.100.01, Sheet 5. Table 12 or 14 (see SA6 also)
3. Drywell Pressure 3. Containment Pressure or Gas Mix Rapid unexplained decrease following Torus Pressure cannot be maintained below the initial increase, or Primary Containment Pressure Limit, or Drywell Pressure response not consistent Drywell or Torus Hydrogen concentration > 6% and with LOCA conditions Drywell or Torus Oxygen concentration

> 57

4. Containment Radiation CHRRM reading greater than I0,OOOR/hr 5 Determination of release of at least 20% Gap activity from the fuel
6. Emergency Director Judgment 6ý Emergency Director Judgment Any condition in the judgment of the Emergency Any condition in the judgment of the Emergency Director that indicates Loss of the Containment Barrier Director that indicates a Potential Loss of the Containment Barrier
  • It is not a prerequisite to be in the section of the EOPs where MCUTL is tracked (RPV Flooding) to apply this EAL. The intent is based on the assurance of adequate core cooling and therefore MCUTL must be calculated for the EAL, possibly independent of EOP use. For the EAL, MCUTL starts when RPV level is less than -40 inches or unknown. Also, the MCUTL curve can be extrapolated to a value of 2.35 minutes at 10 minutes after shutdown.
    • Primary Containment Barrier Potential Loss EALs I - 5 are indicative of conditions warranting a General Emergency declaration.

EP-101 Enclosure A, Tab H Page H- I 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY UNUSUAL EVENT HU1 Natural and Destructive Phenomena Affecting the Protected Area OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Seismic monitor indicates earthquake greater than 0.01g
2. Report by plant personnel of tornado striking within protected area boundary
3. Vehicle crash into plant structures or systems within protected area boundary
4. Report by plant personnel of an unanticipated explosion within protected area boundary resulting in visible damage to permanent structure or equipment
5. Report of turbine failure resulting in casing penetration or damage to turbine or generator seals
6. Sustained winds greater than 75 mph as measured at the 10 m or 60 m elevations on the meteorological tower
7. External flooding indicated by wave crests exceeding the top of the shore barrier
8. Internal flooding in the Auxiliary Building. Reactor Building, or RHR Complex that has the potential to affect the operation of safe shutdown equipment
9. Assessment by the Control Room that a destructive event affecting the protected area has occurred

EP-101 Enclosure A, Tab H Page H-2 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA1 Natural and Destructive Phenomena Affecting the Plant Vital Area OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Seismic monitor indicates seismic event greater than 0.08 g
2. Report by plant personnel of tornado striking Reactor Building, Auxiliary Building, or RHR Complex
3. Any occurrence that results in visible damage to the Reactor Building, Auxiliary Building, or RHR Complex
4. Control Room indications which in the judgment of Control Room personnel reflect damage to the Reactor Building. Auxiliary Building, or RHR Complex
5. Vehicle crash affecting the Reactor Building. Auxiliary Building, or RHR Complex
6. Turbine failure generated missiles result in any visible structural damage to or penetration of the Reactor Building, Auxiliary Building. or RHR Complex
7. Sustained winds greater than 90 mph as measured at the 10 m or 60 m elevations on the meteorological tower
8. Flooding from internal or external sources that has affected the operation of safe shutdown equipment in the Reactor Building, Auxiliary Building, or RHR Complex

EP-101 Enclosure A. Tab H Page H-3 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY UNUSUAL EVENT HU2 Fire Within Protected Area Boundary Not Extinguished Within 15 Minutes of Detection OPERATING MODE APPLICABILITY: All Emergency Action Level:

1. Fire in the Auxiliary Building, Reactor Building, Control Center, Turbine Building, Radwaste Building, or RHR Complex not extinguished within 15 minutes of Control Room notification or verification of a control room alarm NOTE: If a Control Room Fire Alarm is verified, the 15 minute period starts at the time that the Control Room Fire Alarm was received.

EP-101 Enclosure A, Tab H Page H-4 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA2 Fire or Explosion Affecting the Operability of Plant Safety Systems Required to Establish or Maintain Safe Shutdown OPERATING MODE APPLICABILITY: All Emergency Action Level:

1. Fire not extinguished within 15 minutes of Control Room notification or verification of a Control Room alarm or explosion in any of the following areas: I
  • Reactor Building
  • Auxiliary Building
  • Control Center

° RHR Complex and Affected system parameter indications show degraded performance or plant personnel report visible damage to permanent structures or equipment within the specified area

EP-101 Enclosure A. Tab H Page H-5 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY UNUSUAL EVENT HU3 Release of Toxic or Flammable Gases Deemed Detrimental to Safe Operation of the Plant OPERATING MODE APPLICABILITY: All NOTE (1): Potential sources of offsite toxic releases include, but are not limited to:

1. Berlin Water Treatment Plant 1.5 miles North Northwest (Sector R, 330')

600 pounds of chlorine gas

2. Meijer Distribution Center 3.8 miles Northwest (Sector Q. 3150) 22.000 pounds of anhydrous ammonia NOTE (2): Fire suppression gases are not considered toxic for the purpose.of this EAL.

NOTE (3): The HAZWOPER Plan may be used for additional reference.

Emergency Action Levels:

1. Report or detection of toxic or flammable gases that could enter within the site area boundary in amounts that can affect normal operation of the plant
2. Report by Local. County or State Officials for potential evacuation of site personnel based on offsite event

EP-101 Enclosure A, Tab H Page H-6 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA3 Release of Toxic or Flammable Gases Within a Facility Structure Which Jeopardizes Operation of Systems Required to Maintain Safe Operations or to Establish or Maintain Cold Shutdown OPERATING MODE APPLICABILITY: All NOTE (1): Fire suppression gases are not considered toxic for the purpose of this EAL.

NOTE (2): The HAZWOPER Plan may be used for additional reference.

Emergency Action Levels:

1. Report or detection of toxic gases within a facility structure in concentrations that will be life threatening to plant personnel
2. Report or detection of flammable gases within a facility structure in concentrations that will affect the safe operation of the plant

EP-101 Enclosure A. Tab H Page H-7 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY UNUSUAL EVENT HU4 Confirmed Security Event Which Indicates a Potential Degradation in the Level of Safety of the Plant OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Attempted unauthorized entry into the protected area
2. Attempted sabotage within the protected area
3. Internal disturbance within the protected area not brought under immediate control or presenting an unknown threat
4. A confirmed credible site-specific security threat notification

EP-101 Enclosure A, Tab H Page H-8 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA4 Security Event in a Plant Protected Area OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Explosive device discovered within the plant protected area but outside the plant vital areas
2. Intrusion into plant protected area by a hostile force
3. Confirmed act of sabotage within the plant protected area

EP-101 Enclosure A. Tab H Page H-9 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY SITE AREA EMERGENCY HS1 Security Event in a Plant Vital Area OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Explosive device discovered in a plant vital area
2. Intrusion into a plant vital area by a hostile force
3. Confirmed act of sabotage within a plant vital area

EP-101 Enclosure A, Tab H Page H-10 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY GENERAL EMERGENCY HG1 Security Event Resulting in Loss of Physical Control of Facility OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Loss of physical control of the Control Room due to security event
2. Loss of physical control of remote shutdown capability due to security event

EP-101 Enclosure A. Tab H Page H- 11 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA5 Control Room Evacuation has been Initiated OPERATING MODE APPLICABILITY: All Emergency Action Level:

1. Evacuation of the Control Room ordered by the Shift Manager (SM).

i

EP-101 Enclosure A, Tab H Page H- 12 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY SITE AREA EMERGENCY HS2 Control Room Evacuation has been Initiated and Plant Control Cannot be Established OPERATING MODE APPLICABILITY: All Emergency Action Level:

1. Control Room evacuation has been initiated and Control of RPV level and pressure cannot be established per 20.000.18 or 20.000.19 within 15 minutes

EP-101 Enclosure A, Tab H Page H- 13 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY UNUSUAL EVENT HU5 Other Conditions Existing Which in the Judgment of the Emergency Director Warrant Declaration of an Unusual Event OPERATING MODE APPLICABILITY: All Example Emergency Action Level:

1. Other conditions exist which in the judgment of the Emergency Director indicate a potential degradation of the level of safety of the plant. No release of radioactive material requiring offsite response or monitoring is expected.

EP-101 Enclosure A, Tab H Page H-14 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA6 Other Conditions Existing Which in the Judgment of the Emergency Director Warrant Declaration of an Alert OPERATING MODE APPLICABILITY: All Emergency Action Level:

1. Other conditions exist which in the judgment of the Emergency Director indicate that 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 Guidelines (PAG) exposure levels.

EP-101 Enclosure A. Tab H Page H-15 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY SITE AREA EMERGENCY HS3 Other Conditions Existing Which in the Judgment of the Emergency Director Warrant Declaration of a Site Area Emergency OPERATING MODE APPLICABILITY: All Emergency Action Level:

1. Other conditions exist which in the judgment of the Emergency Director indicate actual or likely major failures of plant functions needed for protection of the public.

Any releases are not expected to exceed EPA Protective Action Guidelines (PAG) exposure levels except near the site boundary.

EP-101 Enclosure A, Tab H Page H-16 121101 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY GENERAL EMERGENCY HG2 Other Conditions Existing Which in the Judgment of the Emergency Director Warrant Declaration of General Emergency OPERATING MODE APPLICABILITY: All Emergency Action Level:

1. Other conditions exist which in the judgment of the Emergency Director indicate:

actual or imminent substantial core degradation or melting with potential for loss of containment, or potential for uncontrolled radionuclide releases which can reasonably be expected to exceed EPA PAG plume exposure levels outside the site boundary

EP-101 Enclosure A. Tab S Page S-i 121101 SYSTEM MALFUNCTIONS UNUSUAL EVENT SUI Loss of All Offsite Power to Essential Busses for Greater Than 15 Minutes OPERATING MODE APPLICABILITY: All Emergency Action Level:

1. Loss of power to System Service Transformers 64 and 65 for greater than 15 minutes and Emergency Diesel Generators are supplying power to all Div. 1 and Div. 2 emergency busses

EP-101 Enclosure A, Tab S Page S-2 121101 SYSTEM MALFUNCTIONS ALERT SA1 Loss of all Offsite Power and Loss of all Onsite AC Power to Essential Busses During Cold Shutdown or Refueling Mode OPERATING MODE APPLICABILITY: 4, 5, defueled Emergency Action Level:

1. The following conditions exist for the required AC Power Distribution Source:
a. Loss of power to System Service Transformers 64 or 65 and
b. Failure of Emergency Diesel Generators to supply power to the required division of emergency busses and
c. Failure to restore power to at least one required division of busses within 15 minutes from the time of loss of both offsite and onsite AC power sources

EP-101 Enclosure A, Tab S Page S-3 121101 SYSTEM MALFUNCTIONS ALERT SA5 AC Power Capability to Essential Busses Reduced to a Single Power Source for Greater Than 15 Minutes Such That Any Additional Single Failure Would Result in Station Blackout OPERATING MODE APPLICABILITY: 1,2,3 Emergency Action Levels:

1. Loss of Power to System Service 64 and 65 transformers for greater than 15 minutes and Onsite ESF power capability has been degraded to one full division of emergency busses
2. Loss of ability to power Div. I and Div. 2 emergency busses from Emergency Diesel Generators for greater than 15 minutes and Loss of power to System Service Transformer 64 or 65

EP-101 Enclosure A, Tab S Page S-4 121101 SYSTEM MALFUNCTIONS SITE AREA EMERGENCY SS1 Loss of all Offsite Power and Loss of all Onsite AC Power to Essential Busses OPERATING MODE APPLICABILITY: 1,2,3 Emergency Action Levels:

1. Loss of power to System Service Transformers 64 and 65 and Failure of Emergency Diesel Generators to supply power to one full division of emergency busses and Failure to restore power to at least one division of emergency busses within 15 minutes from the time of loss of both offsite and onsite AC power

EP-101 Enclosure A, Tab S Page S-5 121101 SYSTEM MALFUNCTIONS GENERAL EMERGENCY SG1 Prolonged Loss of all Offsite Power and Prolonged Loss of all Onsite AC Power OPERATING MODE APPLICABILITY: 1.2,3 Emergency Action Level:

1. Loss of power to System Service Transformers 64 and 65 and Failure of Emergency Diesel Generators to supply power to one full division of emergency busses and Restoration of at least one full division of emergency busses within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is NOT likely, or RPV water level less than 0 inches

EP-101 Enclosure A, Tab S Page S-6 121101 SYSTEM MALFUNCTIONS ALERT SA2 Failure of Reactor Protection System Instrumentation to Complete or Initiate an Automatic Reactor Scram Once a Reactor Protection System Setpoint Has Been Exceeded and Manual Scram Was Successful OPERATING MODE APPLICABILITY: 1,2 Emergency Action Level:

1. A valid initiating scram signal received. but no automatic scram occurred and Manual actions taken at COP H 11-P603 were successful in scram of control rods to achieve reactor power < 3%

EP-101 Enclosure A, Tab S Page S-7 121101 SYSTEM MALFUNCTIONS SITE AREA EMERGENCY SS2 Failure of Reactor Protection System Instrumentation to Complete or Initiate an Automatic Reactor Scram Once a Reactor Protection System Setpoint Has Been Exceeded and Manual Scram Was NOT Successful OPERATING MODE APPLICABILITY: 1,2 Emergency Action Level:

1. A valid initiating scram signal received, but no automatic scram occurred and Manual actions taken at COP HI 1-P603 were not successful in scram of control rods to achieve reactor power < 3%

EP-101 Enclosure A, Tab S Page S-8 121101 SYSTEM MALFUNCTIONS GENERAL EMERGENCY SG2 Failure of the Reactor Protection System to Complete an Automatic Scram and Manual Scram was NOT Successful and there is Indication of an Extreme Challenge to the Ability to Cool the Core OPERATING MODE APPLICABILITY: 1,2 Emergency Action Level:

1. A valid initiating scram signal received, but no automatic scram occurred and Manual actions taken at COP H I1-P603 were not successful in scram of control rods to achieve reactor power < 3%

and Emergency depressurization is required by any Emergency Operating Procedure

EP-101 Enclosure A, Tab S Page S-9 121101 SYSTEM MALFUNCTIONS UNUSUAL EVENT SU2 Inability to Reach Required Shutdown within Technical Specification Limits OPERATING MODE APPLICABILITY: 1,2,3 Emergency Action Level:

1. Plant is not brought to required operating mode within Technical Specifications LCO Action Statement Time

EP-101 Enclosure A, Tab S Page S-10 121101 SYSTEM MALFUNCTIONS UNUSUAL EVENT SU3 Unplanned Loss of most or all Safety System Annunciation in the Control Room for Greater than 15 Minutes OPERATING MODE APPLICABILITY: 1,2,3 Emergency Action Level:

1. Loss of most or all (greater than approximately 75%) annunciators on H1 1-P601, P602, and P603 for greater than 15 minutes and Compensatory. non-alarming indications are available and In the opinion of the Shift Manager (SM). the loss of the annunciators requires increased surveillance to safely operate the plant I and Annunciator loss does not result from planned action

EP-101 Enclosure A, Tab S Page S-11 121101 SYSTEM MALFUNCTIONS ALERT SA4 Unplanned Loss of most or all Safety System Annunciation in Control Room with Either (1) a Significant Transient in Progress, or (2) Compensatory Non-Alarming Indicators Unavailable OPERATING MODE APPLICABILITY: 1,2,3 Emergency Action Level:

1. Loss of most or all (greater than approximately 75%) annunciators on HI l-P601, P602, and P603 for greater than 15 minutes and In the opinion of the Shift Manager (SM). the loss of the annunciators requires increased surveillance to safely operate the plant I and Annunciator loss does not result from planned action and A significant plant transient is in progress. or Compensatory non-alarming indications are unavailable NOTE: Significant transients include:
1. Manual or automatic scrams
2. Runbacks involving greater t han 25% thermal power change
3. ECCS injections
4. Thermal power oscillations o f 10% or greater

EP-101 Enclosure A, Tab S Page S- 12 121101 SYSTEM MALFUNCTIONS SITE AREA EMERGENCY SS6 Inability to Monitor a Significant Transient in Progress OPERATING MODE APPLICABILITY: 1,2,3 Emergency Action Level:

1. Loss of most or all (greater than approximately 75%) annunciators associated with Hi l-P601, P602, and P603 and Compensatory non-alarming indications unavailable and Indications needed to monitor safety functions associated with lost annunciators unavailable and Significant transient in progress NOTE: Significant transients include:
1. Manual or automatic scrams
2. Runbacks involving greater than 25% thermal power change
3. ECCS injections
4. Thermal power oscillations of 10% or greater

EP-101 Enclosure A. Tab S Page S-13 121101 SYSTEM MALFUNCTIONS UNUSUAL EVENT SU4 Fuel Clad Degradation OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Gross radioactivity rate of noble gases measured at the discharge of the 2.2 minute delay piping greater than 340 millicuries/sec after 30 minute delay
2. Reactor scram due to main steam line radiation greater than three times full power value as may be indicated by Annunciator 3D82
3. Dose Equivalent 1-131 greater than 0.2 /Ci/gm for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />
4. Dose equivalent 1-131 greater than 4.0 UCi/gm

,.- t

EP-101 Enclosure A, Tab S Page S-14 121101 SYSTEM MALFUNCTIONS UNUSUAL EVENT SU5 RCS Leakage OPERATING MODE APPLICABILITY: 1,2,3 Emergency Action Levels:

1. Unidentified or pressure boundary leakage greater than 10 gpm
2. Identified leakage greater than 25 gpm

EP-101 Enclosure A, Tab S Page S-15 121101 SYSTEM MALFUNCTIONS ALERT SA6 Main Steam Line Break OPERATING MODE APPLICABILITY: 1,2,3 Emergency Action Level:

1. Indication of Main Steam Line Break on Isolation Mimic

EP-101 Enclosure A, Tab S Page S-16 121101 SYSTEM MALFUNCTIONS UNUSUAL EVENT SU6 Unplanned Loss of All Onsite or Offsite Communications Capabilities OPERATING MODE APPLICABILITY: All Emergency Action Levels:

1. Loss of all the following onsite communications capabilities affecting the ability to perform routine operations:

Administrative Telephones Hi-Com Plant radios

2. Loss of all the following offsite communications capabilities:

Administrative Telephones Emergency Telephones

EP-101 Enclosure A, Tab S Page S-17 121101 SYSTEM MALFUNCTIONS UNUSUAL EVENT SU7 Unplanned Loss of Required DC Power During Cold Shutdown or Refueling Mode for Greater than 15 Minutes OPERATING MODE APPLICABILITY: 4,5 Emergency Action Level:

I. Loss of both Div. I and Div. 2 130V DC Systems as indicated by DC bus voltage less than:

Div 1: 112.2VDC Div 2: 107.4V DC and Inability to restore voltage on either Div. 1 or Div. 2 130V DC bus within 15 minutes from discovery of loss

EP-101 Enclosure A, Tab S Page S-18 121101 SYSTEM MALFUNCTIONS SITE AREA EMERGENCY SS3 Loss of All Vital DC Power OPERATING MODE APPLICABILITY: 1.2,3 Emergency Action Level:

1. Loss of both Div. 1 and Div. 2 130V DC Systems as indicated by DC bus voltage less than:

Div 1: 112.2V DC Div 2: 107.4V DC and Inability to restore voltage on either Div. I or Div. 2 130V DC bus within 15 minutes from discovery of loss

EP-101 Enclosure A, Tab S Page S-19 121101 SYSTEM MALFUNCTIONS ALERT SA3 Inability to Maintain Plant in Cold Shutdown OPERATING MODE APPLICABILITY: 4,5 Emergency Action Level:

1. Div. 1 and Div. 2 of the RHR System are not effective in Decay Heat Removal and Reactor coolant temperature exceeds 200°F, or Results in uncontrolled temperature rise approaching 200'F

EP-101 Enclosure A, Tab S Page S-20 121101 SYSTEM MALFUNCTIONS SITE AREA EMERGENCY SS5 Loss of Water Level in the Reactor Vessel that has or will Uncover Fuel in the Reactor Vessel OPERATING MODE APPLICABILITY: 4,5 Emergency Action Level:

1. RPV water level cannot be kept above 0 inches

EP-101 Enclosure A, Tab S Page S-21 121101 SYSTEM MALFUNCTIONS SITE AREA EMERGENCY SS4 Complete Loss of Function Needed to Achieve or Maintain Hot Shutdown OPERATING MODE APPLICABILITY: 1.2,3 Emergency Action Level:

1. Any combination of events which would require the plant to be shutdown from normal operating pressure and temperature and Torus water temperature and RPV pressure cannot be kept below the Heat Capacity Limit (HCL)

EP-101 Enclosure B, Page 1 of 4 121101 INITIATING CONDITION MATRIX TAB A TAB A Abnormal Rad LeveWsRadiological Effluent or immnen relas of gaeu r ei tat 1 - -

- *IZ::..N A*llOl actualSm*troo

  • j5-[oo-. Pg' A-4il*

n

ý

-[5 0* - -. - it

- *.l -. - S.

rim iene

  • l*'=-]lSilte*boudar dose resltng frmuu] an.acua AA1 7QU tiJAJ Any unplanned release of gaseous or liquid Major damage to Releases of radioactive radioactivity to the environment that irradiated fuel or loss of material or increases in ALERT exceeds 200 times the values of O0CM water level that has or will radiation levels within the control 3.11.2.1 or 3.11.1.1 for 15 minutes result in the uncovering of facility that impede or longer irradiated fuel outside the operation of systems reactor vessel required to maintain safe operations or to establish or maintain cold shutdown All Pa A-2 IAll Po A-6 lAll Pq A-7 AU1 AU

--An unlne relas of eos or liui Unexpected increaseof "raioctiit to t-he eniom n that -plant r-adi,,-

o- levels *t-'

1':1- 10 1 I :ICIOS'LIC 13, IPagc 2 ot'4 121101 INITIATING CONDITION MATRIX T AB F~

.4 I. .1 NOTE 1: Stuck open SRV is not a reactor coolant barrier loss or potential loss unless there is a concurrent loss of the fuel clad barrier, in which case the stuck open SRV constitutes a potential loss of the reactor coolant barrier (FS.1 applies).

NOTE 2: It is not a prerequisite to be in the section of the EOPs where MCUTL is tracked (RPV flooding) to apply this EAL. The intent is based on the assurance of adequate core cooling and

- lI therefore MCUTL must be calculated for the Any loss or any EAL, possibly potential loss of either independent of EOP use. For the EAL, ALERT fuel clad or reactor MCUTL starts when coolant system RPV level is less than 40" or unknown Also

()l the MCUTL curve can be extrapoluted to a value of 2.35 minutes at 10 minutes after shutdown NOTE 3: Primary Containment Barrier Potential I oss AIts 1 5 are indicative of conditions warranting a General Emergency declaration

EP-101 Enclosure B, Page 3 of 4 121101 INITIATING CONDITION MATRIX TAB H "A1$4 MADO Natural and Fire or Release of toxic Security event Control Room Other conditions destructive explosion or flammable in a Plant evacuation has existing which in phenomena affecting the gases within a Protected Area been initiated the judgement of affecting the operability of facility structure the Emergency ALERT Plant Vital Area Plant safety which Director warrant systems jeopardizes declaration of an required to operation of Alert establish or systems maintain safe required to shutdown maintain safe operations or to establish or maintain cold shutdown All All All P -B A All destructive A o f e s ri 1 e eitng w h1 in UNUUA ona b.ound a* y gases dich

-n-ot iniat t 1 ju igm nt of EVN afetn th -aiguse de- - alt ~a- poeta th -mrg-c Prtete Are wihi 15 saf oprto dgadaio in Dieco warrn miue of of th Pln h ee dcaaino an

EP-101 Enclosure B, Page 4 of 4 121101 INITIATING CONDITION MATRIX TAB S 9999.9 * . -T.AB-S

  • -S.stem Malfunctio9 999G1 t 0S9 2 ** .

Proongd- ossof9 llFaiureofthereato offste owe an prtecionsysem o W GENRAL os prloned ofallcoplee9a atomti 1,2,- g S 9 -,2 -

SS1Sl SAR 5A9 SSd S

Loss of all offsite power AC power capability to Failure of reactor protection Unplanned loss of Main steam line Inability to maintain and loss of all onsite AC essential busses system instrumentation to most or all safety break plant in cold power to essential busses reduced to a single complete or initiate an system' annunciation shutdown during cold shutdown or power source for greater automatic reactor scram in Control Room with ALERT refueling mode than 15 minutes such once a reactor protection either (9)a significant that any additional system setpoint has been transielt in progress, single failure would exceeded and manual or (2) compensatory result in station blackout scram was successful non-alarming indicators unavailable END

Detroit Edison 1Info. Mgmt. 140 EF-2 NOC 6400 N. Dixie Hwy.

Newport, MI 48166 U S NRC DOCUMENT CONTROL DESK WASHINGTON DC 20555 1/4