ONS-2015-048, Emergency Plan Implementing Procedures Manual Volume 1, Revision 2015-003

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Emergency Plan Implementing Procedures Manual Volume 1, Revision 2015-003
ML15142A506
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 05/20/2015
From: Batson S
Duke Energy Corp
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
ONS-2015-048, FOIA/PA-2016-0071 RP/O/A/1000/001, Rev 003
Download: ML15142A506 (41)
v • d • e


Text

j ENERGY, DUKE ONS-2015-048 10 CFR 50.54(q)

May 20, 2015 Attn: Document Control Desk U. S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852-2746

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Emergency Plan Implementing Procedures Manual Volume 1, Revision 2015-003 Please find attached for your use and review a copy of the revision to the Oconee Nuclear Station Emergency Plan Implementing Procedures.

This revision is being submitted in accordance with 10 CFR 50.54(q) and does not reduce the effectiveness of the Emergency Plan or the Emergency Plan Implementing Procedures. Ifthere are any questions or concerns pertaining to this revision please call Pat Street, Emergency Preparedness Manager, at 864-873-3124.

By copy of this letter, two copies of this revision are being provided to the NRC, Region II, Atlanta, Georgia.

Sincerely, Scott L. Batson Vice President Oconee Nuclear Station Attachments:

Revision Instructions EPIP Volume 1 - Revision 2015-003 50.54(q) Evaluation

  • i-(

ONS-2015-048 U. S. Nuclear Regulatory Commission May 20, 2015 Page 2 xc: w/2 copies of attachments Mr. Victor McCree, Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 w/copy of attachments Mr. James R. Hall, Project Manager U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation 11555 Rockville Pike Mailstop: O-8G9Q Rockville, MD 20852 2738 (send via E-mail)

Mr. Jeffrey A. Whited, Project Manager U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation 11555 Rockville Pike Mailstop: O-8B1A Rockville, MD 20852 (send via E-mail) w/o attachments Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station ELL EC2ZF

April 20, 2015 OCONEE NUCLEAR STATION

SUBJECT:

Emergency Plan Implementing Procedures Volume 1, Revision 2015-003 Please make the following changes to the Emergency Plan Implementing Procedures Volume 1.

REMOVE INSERT Cover Sheet Rev. 2015-002 Cover Sheet Rev. 2015-003 RP/O/A/1000/001 Rev 002 RP/O/A/1000/001 Rev 003 Pat Street ONS Emergency Preparedness Mgr.

,-,*DUKE ENERGY.

OCONEE NUCLEAR STATION EMERGENCY PLAN IMPLEMENTING PROCEDURES Volume 1 APPROVED:

Terry L. Patterson Director, Nuclear Organizational Effectiveness Date Approved Volume 1 REVISION 2015-003 April 2015

Duke Energy Procedure No.

Oconee Nuclear Station RP/0/I1000/001 Emergency Classification Revision No.

003 Electronic Reference No.

OP009A63 Reference Use PERFORMANCE I This Procedure was printed on 04/27/15 at 09:36:16 from the electronic library as:

(ISSUED) - PDF Format Compare with Control Copy every 14 calendar days while work is being performed.

Compared with Control Copy* Date Compared with Control Copy* Date Compared with Control Copy* Date Date(s) Performed Work Order/Task Number (WO#)

COMPLETION I o] Yes 0 NA Checklists and/or blanks initialed, signed, dated, or filled in NA, as appropriate?

o Yes C NA Required enclosures attached?

[o Yes [I NA Charts, graphs, data sheets, etc. attached, dated, identified, and marked?

o Yes 0 NA Calibrated Test Equipment, if used, checked out/in and referenced to this procedure?

[] Yes [] NA Procedure requirements met?

Verified By* Date Procedure Completion Approved* Date

  • PrintedName and Signature Remarks (attachadditionalpages, if necessary)

IMPORTANT: Do NOT mark on barcodes. Printed Date: *04/27/20150 Enclosure No.: FULL 11111111111i III I II11111 I11111111111111111 11111 IIIII i iI I1111MIIIIMililI111Revision No.: "'

Il~l l111 1111flll li Procedure No.: *RP/*/A/1000/001*

IIIllI1111111111II III IN 111III III II11111111111111 I II1111111111IIIIIIIII

RP/O/A/ 1000/001 Page 2 of 6 Emergency Classification TE: This procedure is an implementing procedure to the Oconee Nuclear Site Emergency Plan and must be:

" Reviewed in accordance with IOCFR50.54(q) by Emergency Preparedness prior to approval.

  • Cross Disciplinary Reviewed by Operations
1. Symptoms 1.1 This procedure describes the immediate actions to be taken to recognize and classify an emergency condition.

1.2 This procedure identifies the four emergency classifications and their corresponding Emergency Action Levels (EALs).

1.3 This procedure provides reporting requirements for non-emergency abnormal events.

1.4 The following guidance is to be used by the Emergency Coordinator/EOF Director in assessing emergency conditions:

1.4.1 Definitions and Acronyms are italicized throughout procedure for easy recognition. The definitions are in Enclosure 4.10 (Definitions/Acronyms).

1.4.2 The Emergency Coordinator/EOF Director shall review all applicable initiating events to ensure proper classification.

1.4.3 The BASIS Document (Volume A, Section D of the Emergency Plan) is available for review if any questions arise over proper classification.

1.4.4 IF An event occurs on more than one unit concurrently, THEN The event with the higher classification will be classified on the Emergency Notification Form.

A. Information relating to the problem(s) on the other unit(s) will be captured on the Emergency Notification Form as shown in RP/0/A/ 1000/01 5A, (Offsite Communications From The Control Room),

RP/0/A/1000/015B, (Offsite Communications From The Technical Support Center) or SR/O/A/2000/004, (Notification to States and Counties from the Emergency Operations Facility).

2

RP/O/A/ 1000/001 Page 3 of 6 1.4.5 IF An event occurs, AND A lower or higher plant operating mode is reached before the classification can be made, THEN The classification shall be based on the mode that existed at the time the event occurred.

1.4.6 The Fission Product Barrier Matrix is applicable only to those events that occur at Mode 4 (Hot Shutdown) or higher.

A. An event that is recognized at Mode 5 (Cold Shutdown) or lower shall not be classified using the Fission Product Barrier Matrix.

1. Reference should be made to the additional enclosures that provide Emergency Action Levels for specific events (e.g., Severe Weather, Fire, Security).

1.5 IF A transient event should occur, THEN Review the following guidance:

1.5.1 IF An Emergency Action Level (EAL) identifies a specific duration AND The Emergency Coordinator/EOF Director assessment concludes that the specified duration is exceeded or will be exceeded, (i.e.;

condition cannot be reasonably corrected before the duration elapses),

THEN Classify the event.

1.5.2 IF A plant condition exceeding EAL criteria is corrected before the specified duration time is exceeded, THEN The event is NOT classified by that EAL.

A. Review lower severity EALs for possible applicability in these cases.

3

RP/O/A/ 1000/001 Page 4 of 6

. NOTE: Reporting under 10CFR50.72 may be required for the following step. Such a condition could occur, for example, if a follow up evaluation of an abnormal condition uncovers evidence that the condition was more severe than earlier believed.

i 1.5.3 IF A plant condition exceeding EAL criteria is not recognized at the time of occurrence, but is identified well after the condition has occurred (e.g.; as a result of routine log or record review)

AND The condition no longer exists, THEN An emergency shall NOT be declared.

  • Refer to AD-LS-ALL-0006 (Notification/Reportability Evaluation) for reportability 1.5.4 IF An emergency classification was warranted, but the plant condition has been corrected prior to declaration and notification THEN The Emergency Coordinator must consider the potential that the initiating condition (e.g.; Failure of Reactor Protection System) may have caused plant damage that warrants augmenting the on shift personnel through activation of the Emergency Response Organization.

A. IF An Unusual Event condition exists, THEN Make the classification as required.

1. The event may be terminated in the same notification or as a separate termination notification.

B. IF An Aler4 Site Area Emergency, or GeneralEmergency condition exists, THEN Make the classification as required, AND Activate the Emergency Response Organization.

1.6 Emergency conditions shall be classified as soon as the Emergency Coordinator/EOF Director assessment determines that the Emergency Action Levels for the Initiating Condition have been exceeded.

4

RP/O/A/1000/001 Page 5 of 6

2. Immediate Actions 2.1 Assessment, classification and declaration of any applicable emergency condition should be completed within 15 minutes after the availability of indications or information to cognizant facility staff that an EAL threshold has been exceeded.

2.2 Determine the operating mode that existed at the time the event occurred prior to any protection system or operator action initiated in response to the event.

2.3 IF The unit is at Mode 4 (Hot Shutdown) or higher AND The condition/event affects fission product barriers, THEN GO TO Enclosure 4.1, (Fission Product Barrier Matrix).

2.3.1 Review the criteria listed in Enclosure 4.1, (Fission Product Barrier Matrix) and make the determination if the event should be classified).

2.4 Review the listing of enclosures to determine if the event is applicable to one of the categories shown.

2.4.1 IF One or more categories are applicable to the event, THEN Refer to the associated enclosures.

2.4.2 Review the EALs and determine if the event should be classified.

A. IF An EAL is applicable to the event, THEN Classify the event as required.

2.5 IF The condition requires an emergency classification, THEN Initiate the following:

  • for Control Room - RP/O/A/1000/002, (Control Room Emergency Coordinator Procedure) o for TSC - RP/O/A/1000/0 19, (Technical Support Center Emergency Coordinator Procedure)

" for EOF - SR/O/A/2000/003, (Activation of the Emergency Operations Facility) 2.6 Continue to review the emergency conditions to assure the current classification continues to be applicable.

5

RP/O/A/ 1000/001 Page 6 of 6

3. Subsequent Actions 3.1 Continue to review the emergency conditions to assure the current classification continues to be applicable.
4. Enclosures Enclosures Page Number 4.1 Fission Product Barrier Matrix 7 4.2 System Malfunctions 8 4.3 Abnormal Rad Levels/Radiological Effluents 10 4.4 Loss Of Shutdown Functions 12 4.5 Loss of Power 14 4.6 Fires/Explosions And Security Actions 15

.4.7 Natural Disasters, Hazards, And Other Conditions Affecting Plant Safety 17 4.8 Radiation Monitor Readings For Emergency Classification 20 4.9 Unexpected/Unplanned Increase In Area Monitor Readings 21 4.10 Definitions 22 4.11 Operating Modes Defined In Improved Technical Specifications 27 4.12 Instructions For Using Enclosure 4.1 28 4.13 References 30 6

0 Enclosure 4.1 0

RP/O/A/ 1000/001 Fission Product Barrier Matrix Page 1 of I nETERMINE THE APPROPRIATE CLANNIFICATION USING THE TABLE BELOW: ADD POINTS TO CLASSIFY. SEE NOTE BELOW RCS BARRIERS (BD 5-7) . . FUEL CLAD BARRIERS (BD 8.9) '-CONTAINMENT BARRIERS (BD 10-13)

Potential Loss (4 Points) Loss (5 Points) Potential Loss (4 Points) Loss 15 Points) Potential Loss (I Point) Loss (3 Points)

RCS Leakrat >_160 gpm RCS Leak rate that results in a loss Average of the 5 highest Average of the 5 highest CETC CETC _ 1200' F 2t 15 minutes Rapid unexplained containment of subcooling. CETC > 700' F 2! 1200' F OR pressure decrease after increase CETC 700' F > 15 minutes with a OR valid RVLS reading 0" containment pressure or sump level not consistent with LOCA SGTR ? 160 gpm Valid RVLS reading of 0" Coolant activity 2! 300 liCi/ml DEI RB pressure Ž_59 psig Failure of secondary side of SG OR results in a direct opening to the RB pressure a 10 psig and no environment with SG Tube Leak NOTE: RVLS is NOT RBCU or RBS > 10 gpm in the SANME SG valid if either of the following exists:

Entry into the PTS (Pressurized IRIA 57 or 58 reading ! 1.0 R/hr *f e or more RCPs a Hours RIA 57 OR RIA 58 Hours RIA 57 OR RIA 58 SG Tube Leak > 10 gpm exists in Therml Shock) Operation running Since SD R/hr R/hr Since SD R/hr R/hr one SG.

2 RIA 57 reading > 1.6 R/hr OR AND NOTE: PTS is entaezW unde If LPI pump(s) are 0 - <0.5 >300 >150 0 - <0.5 > 1800 _860 the other SG has secondary side the following:

cither Aofcooldown 2 RIA 58 reading > 1.0 R/hr below 400F @-r

  • A cooldon ng AND taig belowng0tFo failure that thrweigvirotakin results in a direct suction from the LPI 0.5 -<2.0 _80 >40 0.5 -<2.0 >_400 >195 opening to the environment

> l00"Fflr. has occurred. 3RIA 57 or 58 reading;> 1.0 RPhr drop line. ANI) is being fed Irom the 2.0-8.0 >-280 >130 affected unit.

  • HPi has operated in the 2.0-8.0 _ 32 _ 16 injection mode while NO RCPs were operating.

HPI Forced Cooling RCS pressure spike Ž 2750 psig Hydrogen concentration 2!9% Containment isolation is incomplete and a release path to the environment exists Emergency Coordbator/EOF Emergency Coordinator/EOF Emergency CoordinatorfEOF Emergency Coordinator/EOF Director Emergency Coordinator/EOF Emergency Coordinator/EOF Director judgment Director judgment Director judgment judgment Director judgment Director judgment UNUSUAL EVENT (1-3 TotaW Points) ALERT (4-6 Total Points) . SITE AREA EMERGENCY (7-10 Total Points) GENERAL EMERGENCY (11-13 'fotal Points)

OPERATING MODE: 1, 2,3.4 OPERATING MODE: 1,2,3,4 OPERATING MODE: 1, 2,3.4 OPERATING MOI)E: I, 2, 3,4 4.1 .U. i Any potential loss of Containment 4. i.A. I Any potential loss or loss of the RCS 4.1.S.1 Loss of any two barriers 4.1.G.1 Loss of any two barriers and potential loss of the third barrier 4.1 .A.2 Any potential loss or loss of the Fuel 4.l.S.2 Loss of one barrier and potential loss of either 4.1 .U.2 Any loss of containment Clad RCS or Fuel Clad Barriers 4.1 .G.2 Loss of all three barriers 4.1.S.3 Potential loss of both the RCS and Fuel Clad Barriers NOT: culdoccr e Anven wihwichwoud mltile vens rsul intheconluson hatexcedig te ossor otetia los tresoldis MNINEN (ie..witin -3 our). n tis MMIENTLOS siuaton NOTE: e An event with multiple events could occur which would result in the conclusion that exceeding the loss or potential loss threshold is IMMINENT (i.e., within 1-3 hours). In this IMMINENT LOSS situation, use judgment and classify as if the thresholds are exceeded.

9 Reftmmcing this matrix frequently will aid in determining a ftssion barrier failure or other upgrade criteria.

7

0 Encio System Malfunctions 4.2 RP/O/A/I/001 Page 1 of 2 UNUSUAL EVENT . ALERT"; SITE-AREA EMERGENCY GENERAL EMERGENCY

1. RCS LEAKAGE (BD 15)

OPERATING MODE: 1. 2.3.4 A. Unidentified leakage ý 10 gpm B. Pressure boundary leakage > 10 gpm C. Identified leakage L 25 gpm

  • Includes SG tube leakage
2. UNPLANNED LOSS OF MOST OR ALL UNPLANNED LOSS OF MOST OR ALL SAFETY SYSTEM ANNUNCIATION/ SAFETY SYSTEM ANNUNCIATION/ 1. INABILITY TO MONITOR A INDICATION IN CONTROL ROOM INDICATION IN CONTROL ROOM SIGNIFICANT TRANSIENT IN FOR > 15 MINUTES (BD 16) (BD 20) PROGRESS (BD 22)

OPERATING MODE: 1, 2,3,4 OPERATING MODE: 1, 2,3,4 OPERATING MODE: 1, 2, 3,4 A. Unplanned loss of > 50% of the following A. Unplanned loss of> 50% of the following A. Unplanned loss of > 50% of the following annunciators on one unit for > 15 minutes: annunciators on one unit for > 15 minutes: annunciators on one unit for > 15 minutes:

Units I & 3 Units I & 3 Units I & 3 I SAI, 2,3.4,5,6,7,8,9, 14,15, 16,& IS 1 SAi, 2, 3,4, 5,6, 7, 8, 9, 14, 15, 16,& 18 I SAI, 2,3,4,5,6,7,8,9, 14, 15, 16, & 18 3 SAI, 2,3,4,5,6.7.8,9, 14.15, 16,& 18 3 SAI, 2,3,4,5,6.7,8,9, 14,15, 16,& 18 3 SAI, 2,3,4,5,6,7,8,9, 14, 15, 16, & 18 Unit 2 Unit 2 Unit 2 2 SAI, 2,3,4.5.6,7.8,9,14,15, & 16 2 SAI, 2,3,4,5,6,7,8,9,14,15, & 16 2 SAI, 2,3,4,5,6,7,8,9, 14, 15, & 16 AND AND AND Loss of annunciators or indicators requires A significanttransientis in progress additional personnel (beyond normal shift Loss of annunciators or indicators requires additional personnel (beyond normal shift complement) to safely operate the unit AND complement) to safely operate the unit AND Loss of the OAC and ALL PAM indications (CONTINUED)

Significantplant transient in progress AND OR Inability to directly monitor any one of the following functions:

Loss of the OAC and ALL PAM indications I. Subcriticality (END) 2. Core Cooling

3. Heat Sink
4. RCS Integrity
5. Containment Integrity
6. RCS Inventory (END)
  • .. _________________________ I 8

Enclo 4.2 RP/O/A//001 System Malfunctions Page 2 of 2 UNUSUAL EVENT, . ALERT S-E AREA EMERGENCY j GENERAL EMERGENCY

3. INABILITY TO REACH REQUIRED SHUTDOWN WITHIN LIMITS (BD 17)

OPERATING MODE: 1, 2,3,4 A. Required operating mode not reached within TIS LCO action statement time

4. UNPLANNED LOSS OF ALL ONSITE OR OFFSITE COMMUNICATIONS (BD 18)

OPERATING.ODE: All A. Loss of all onsite communications capability (Plant phone system, PA system.

Pager system, Onsite Radio system) affecting ability to perform Routine operations B. Loss of all onsite communications capability (Selective Signaling. NRC ETS lines, Offsitc Radio System, AT&T line) affecting ability to communicate with offsite authorities.

5. FUEL CLAD DEGRADATION (BD 19)

= OPERATING MODE: AU:

A. DEI - >5+/-Ci/ml (END) 9

Enclo 4.3 RP/O/A///001 Abnormal Rad Levels/Radiological Effluent Page 1 of 2 UNUSUAL EVENT ' ALERT . SITE AREA EMERGENCY f GENERAL EMERGENCY ANY UNPLANNED RELEASE OF 1. ANY UNPLANNED RELEASE OF 1. BOUNDARY DOSE RESULTING FROM I. BOUNDARY DOSE RESULTING FROM GASEOUS OR LIQUID RADIOACTIVITY GASEOUS OR LIQUID RADIOACTIVITY ACTUALMMINENT RELEASE OF ACTUAL/ IMMINENT RELEASE OF TO THE ENVIRONMENT THAT TO THE ENVIRONMENT THAT GASEOUS ACTIVITY (BD 35) GASEOUS ACTIVITY (BD 39)

EXCEEDS TWO TIMES THE SLC EXCEEDS 200 TIMES RADIOLOGICAL LIMITS FOR 60 MINUTES OR LONGER TECHNICAL SPECIFICATIONS FOR 15 OPERATING MODE: All OPERATING MODE: All (BD 25) MINUTES OR LONGER (BD 30)

A. Valid reading on RIA 46 of > 2.09E+05 cpm or A. Valid reading on RIA 46 of > 2.09E+06 cpm or OPERATING MODE: All OPERATING MODE: All RIA 56 reading of > 175 R/hr or RP sample RIA 56 reading of> 17.5 R/hr or RP sample reading of 6.62E+01 uCi/mI Xe 133 eq for reading of 6.62E+O2uCi/nil Xe 133 eq for A. Valid indication on radiation monitor RIA 33 A. Valid indication of RIA-46 of > 2.09 E+ 04 > IS minutes (See Note 2) >_ 15 minutes (Sec Note 3) of Ž 4.06E+06 cpm for > 60 minutes cpm or RP sample reading of> 6.62 uCi/mI (See Note I) Xe 133 eq for> 15 minutes. (See Note 1) B. Valid reading on RIA 57 or 58 as shown on B. Valid reading on RIA 57 or 58 as shown on Enclosure 4.8 (See Note 2) Enclosure 4.8 (See Note 3)

B. Valid indication on radiation monitor RIA-45 B RIA 33 HIGH Alarm of> 9.35E+05 cpm or RP sample reading of C. Dose calculations result in a dose projection at C. Dose calculations result in a dose projection at

> 6.62E-2uCi/ml Xe 133 eq for > 60 minutes the site boundary of: the site boundary of:

(See Note i)

Liquid effluent being released exceeds 200 > 100 mRem TEDE _ 1000 mRem TEDE C. Liquid effluent being released exceeds two times the level of SLC 16.11.1 for > 15 minutes times SLC 16.11.1 for > 60 minutes as as determined by Chemistry Procedure OR OR determined by Chemistry Procedure C. Gaseous effluent being released exceeds 200 500 mRem CDE adult thyroid 2 5000 mnRem CDE adult thyroid D. Gaseous effluent being released exceeds two times the level of SLC 16.11.2 for >15 minutes times SLC 16.11.2 for > 60 minutes as as determined by RP Procedure D. Field survey results indicate site boundary dose D. Field survey results indicate site boundary dose determined by RP Procedure rates exceeding Ž>100 mRad/hr expected to rates exceeding _>1000 mRad/hr expected to continue for more than one hour continue for more than one hour OR OR (CONTINUED)

Analyses of field survey samples indicate adult Analyses of field survey samples indicate adult thyroid dose commitment of ->500 mRem thyroid dose commitment of _>5000 miRem CDE (3.84 E7 lgCi/nl) for one hour of CDE for one hour of inhalation NOTE 1: If monitor reading is sustained inhalation for the time period indicated in the EAL AND the required assessments (procedure calculations) cannot be completed within NOTE 3: If actual Dose Assessment cannot this period, declaration must be made on the NOTE 2: If actual Dose Assessment cannot be completed within 15 minutes, then the valid Radiation Monitor reading. be completed within 15 minutes. then the valid radiation monitor reading should be valid radiation monitor reading should be used for emergency classification.

used for emergency classification.

(CONTINUED)

(CONTINUED) tEIND*l i __ ____

____ ____ ____ _(END) 10

Encio 4.3 RP/O/AIS/O001 Abnormal Rad Levels/Radiological Effluent Page 2 of 2 a UNUSUAL EVENT

- j

  • :Ti.

ALERT SITE AREA EMERGENCY

'  ! " :* : " .  :..  : i GENERAL EMERGENCY 2 UNEXPECTED INCREASE IN PLANT 2. RELEASE OF RADIOACTIVE 2. LOSS OF WATER LEVEL IN THE RADIATION OR AIRBORNE MATERIAL OR INCREASES IN REACTOR VESSEL THAT HAS OR CONCENTRATION (BD 27) RADIATION LEVELS THAT IMPEDES WILL UNCOVER FUEL IN THE OPERATION OF SYSTEMS REQUIRED REACTOR VESSEL (BD 38)

OPERATING MODE: All TO MAINTAIN SAFE OPERATION OR TO ESTABLISH OR MAINTAIN COLD OPERATING MODE: 5,6 SHUTDOWN (BD 32)

A. LT 5 reading 14" and decreasing with makeup not keeping up with leakage 35M fuel in the OPERATING MODE: All A. Loss of all decay heat removal as indicated by core the inability to maintain RCS temperature A. Valid radiation reading ? 15 mRad/hr in CR, below 200' F CAS. or Radwaste CR B. Valid indication of uncontrolled water decrease in the SFP or fuel transfer canal with all fuel B. Unplannedlunexpected valid area monitor AND assemblies remaining covered by water readings exceed limits stated in Enclosure 4.9 LT 5 indicates 0 inches after initiation of RCS NOTE: These readings may also be indicative of makeup AND Fission Product Barrier concerns which makes a review of the Fission Product Barrier Matrix Unplanned Valid RIA 3, 6 or Portable Area necessary. B. Loss of all decay heat removal as indicated by Monitor readings increase. the inability to maintain RCS temperature

3. MAJOR DAMAGE TO IRRADIATED below 2000 F C. I R/hr radiation reading at one foot away from FUEL OR LOSS OF WATER LEVEL THAT HAS OR WILL RESULT IN THE AND a damaged storage cask located at the ISFSI UNCOVERING OF IRRADIATED FUEL Either train ultrasonic level indication less than D. Valid area monitor readings exceeds limits OUTSIDE THE REACTOR VESSEL 0 inches and decreasing after initiation of RCS stated in Enclosure 4.9. (BD 33) makeup OPERATING MODE: All NOTE: This Initiating Condition is also located NOTE: This Initiating Condition is also in Enclosure 4.4., (Loss of Shutdown Functions). A. Valid RIA 3", 6,41, OR 49* HIGH Alarm located in Enclosure 4.4.. (Loss of Shutdown High radiation levels will also be seen with this * - Applies to Mode 6 and No Mode Only Functions). High radiation levels will also be condition. seen with this condition.

B. HIGH Alarm for portable area monitors on the main bridge or SFP bridge C. Report of visual observation of irradiated fuel uncovered (END))

D. Operators determine water level drop in either (END) the SFP or fuel transfer canal will exceed makeup capacity such that irradiated fuel will be uncovered NOTE: This Initiating Condition is also located in Enclosure 4.4., (Loss of Shutdown Functions).

High radiation levels will also be seen with this condition.

(END)

II

Enclo 4.4 RP/0IAI@//001 Loss of Shutdown Functions Page 1 of 2 UNUSUAL EVENTA AREA EMERGENCY GENERAL EMRGENCY

1. FAILURE OF RPS TO COMPLETE OR 1. FAILURE OF RPS TO COMPLETE OR 1. FAILURE OF RPS TO COMPLETE INITIATE A Rx SCRAM (BD 44) INITIATE A Rx SCRAM (BD 50)

OPERATING MODE: 1, 2 OPERATING MODE 1, 2,3 OPERATING MODE: 1, 2 (CONTINUE TO NEXT PAGE) A. Valid Rx trip signal received or required A. Valid reactor trip signal received or required A. Valid reactor trip signal received or required WITHOUT automatic scram WITHOUT automatic scram WITHOUT automatic scram AND AND AND DSS has inserted Control Rods Manual trip from the Control Room was OR DSS has NOT inserted Control Rods NOT successful in reducing reactor power to < 5% and decreasing Manual trip from the Control Room is successful and reactor power is less AND AND than 5% and decreasing Manual trip from the Control Room was NOT Average of the 5 highest CETCs >1200' F successful in reducing reactor power to less on ICCM than 5% and decreasing (END)

2. INABILITY TO MAINTAIN PLANT IN 2. COMPLETE LOSS OF FUNCTION MODE 5 (COLD SHUTDOWN) (BD 46) NEEDED TO ACHIEVE OR MAINTAIN MODE 4 (HOT SHUTDOWN) (BD 51)

OPERATING MODE: 5,6 OPERATING MODE: 1, 2,3,4 A. Loss of LPI and/or LPSW AND A. Average of the 5 highest CETCs > 1200* F shown on ICCM Inability to maintain RCS temperature B. Unable to maintain reactor subcritical below 2000 F as indicated by either of the following:

C. Inability to feed SGs prior to RCS pressure reaching 2300 psig RCS temperature at the LPI Pump Suction AND OR HPI Forced Cooling degraded by any of the Average of the 5 highest CETCs as indicated following:

by ICCM display " Unacceptable HPI flow/pressure in either header per EOP Rule 4 OR

  • Only I HPI Pump available

" Either PORV (*RC-66) and/or PORV Visual observation Block (*RC-4) closed (CONTINUED) (CONTINUED)

Encloe 4.4 RP/0/A* /001 Loss of Shutdown Functions Page 2 of 2 12 UNUSUAL EVENT 1IALERT SITE AREA EMERGENCY.' GENERAL EMERGENCY

1. UNEXPECTED INCREASE IN PLANT 3. MAJOR DAMAGE TO IRRADIATED 3. LOSS OF WATER LEVEL IN THE RADIATION OR AIRBORNE FUEL OR LOSS OF WATER LEVEL REACTOR VESSEL THAT HAS OR CONCENTRATION (BD 42) THAT HAS OR WILL RESULT IN THE WILL UNCOVER FUEL IN THE UNCOVERING OF IRRADIATED FUEL REACTOR VESSEL (BD 52)

OPERATING MODE: All OUTSIDE THE REACTOR VESSEL (BD 48) OPERATING NIODE: 5,6 A. LT 5 reading 14' and decreasing with makeup not keeping up with leakage WITH fuel in the OPERATING MODE. All A. Loss of all decay heat removal as indicated by core the inability to maintain RCS temperature A. Valid RIA 3*, 6,41, OR 49* HIGH Alarm below 2000 F B. Valid indication of uncontrolledwater decrease in the S-P or fuel transfer canal with all fuel *Applies to Mode 6 and No Mode Only AND assemblies remaining covered by water B. HIGH Alarm for portable area monitors on the LT-5 indicates 0 inches after initiation of RCS main bridge or SFP bridge Makeup AID~

B. Loss of all decay heat removal as indicated by Unplanned Valid RIA 3, 6 or Portable Area C Report of visual observation of irradiated fuel the inability to maintain RCS temperature Monitor readings increase. uncovered below 2000 F AND C. I R/hr radiation reading at one foot away from D. Operators determine water level drop in either a damaged storage cask located at the ISFSI the SFP or fuel transfer canal will exceed makeup capacity such that irradiated fuel will Either train ultrasonic level indication less than D. Valid area monitor readings exceeds limits be uncovered 0 inches and decreasing after initiation of RCS stated in Enclosure 4.9. makeup NOTE: This Initiating Condition is also located in Enclosure 4.3, (Abnormal Rad NOTE: This initiating Condition is also located Levels/Radiological Effluent). High radiation NOTE: This Initiating Condition is also located in Enclosure 4.3., (Abnormal Rad levels will also be seen with this condition. in Enclosure 4.3, (Abnormal Rad Levels/Radiological Effluent). High radiation Levels/Radiological Effluent). High radiation levels will also be seen with this condition. levels will also be seen with this condition.

(END)

(END)

(END) 13

0 Enclosure 4.5 0

RP/O/A/1000/001 Loss of Power (4) Page 1 of I UNSA UNUSAL EVN EENT ALET LR J SITE AREA EMERGENCY GEERAL EMERGENCY E

1. LOSS OF ALL OFFSITE POWER TO 1. LOSS OF ALL OFFSITE AC POWER AND 1. LOSS OF ALL OFFSITE AC POWER AND 1. PROLONGED LOSS OF ALL OFFSITE ESSENTIAL BUSSES FOR GREATER LOSS OF ALL ONSITE AC POWER TO LOSS OF ALL ONSITE AC POWER TO POWER AND ONSITE AC POWER THAN 15 MINUTES (BD 55) ESSENTIAL BUSSES (BD 57) ESSENTIAL BUSSES (BD 59) (BD 62)

OPERATING MODE: All OPERATING MODE; 5,6 OPERATING MODE: 1, 2,3,4 OPERATING MOI)E: I, 2, 3,4 Defueled A. Unit auxiliaries are being supplied from A. MFB I and 2 de-energized A. MFB I and 2 de-energized Keowee or CTS A. MFB I and 2 de-energized AND AND AND AND Failure to restore power to at least one MFB SSF fails to maintain Mode 3 Failure to restore power to at least one MFB within 15 minutes from the time of loss of (Hot Standby) {l)

Inability to energize gileb MFB from an offsite within 15 minutes from the time of loss of both both offsite and onsite AC power source (either switchyard) within 15 minutes. offsite and onsite AC power AND At least one of the following conditions exist:

2. AC POWER CAPABILITY TO 2. LOSS OF ALL VITAL DC POWER
2. UNPLANNED LOSS OF REQUIRED DC (BD 60) Restoration of power to at least one ESSENTIAL BUSSES REDUCED TO A POWER FOR GREATER THAN 15 MFB within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is NOT likely SINGLE SOURCE FOR GREATER THAN MINUTES (RD 56) 15 MINUTES (BD 58) OPERATING MODE: 1, 2,3,4 I OR OPERATING MODE: 5.6 OPERATING MODE: 1, 2,3,4 A. Unplanned loss of vital DC power to required Indications of continuing DC busses as indicated by bus voltage less than degradation of core cooling based A. Unplanned loss of vital DC power to required A. AC power capability has been degraded to a 110 VDC on Fission Product Barrier DC busses as indicated by bus voltage less single power source for > 15 minutes due to the monitoring than 110 VDC loss of all but one of the following: AND AND (END)

Unit Normal Transformer (backcharged) Failure to restore power to at least one required Unit SU Transformer DC bus within 15 minutes from the time of loss Failure to restore power to at least one required Another Unit SU Transformer (aligned)

DC bus within I5 minutes from the time of loss CT4 (END)

CT5 (END)

(END)

Loss of Power - Emergency Action Levels (EALs) apply to the ability of electrical energy to perform its intended function, reach its intended equipment. ex. - If both MFBs, are energized but all 4160V switchgear is not available, the electrical energy can not reach the motors intended. The result to the plant is the same as if both MFBs were de-energized. 141 14

EnclI 4.6 RP/O/A/IO/001 Fire/Explosions and Security Actions (2) 43) Page 1 of 2 UNUSUAL EVENT ALERT SITE AREA EMERGENCY GENERAL EMERGENCY I. FIRES/EXPLOSIONS WITHIN THE 1. FIRE/EXPLOSION AFFECTING PLANT (BD 65) OPERABILITY OF PLANT SAFETY (CONTINUE TO NEXT PAGE) (CONTINUE TO NEXT PAGE)

SYSTEMS REQUIRED TO OPERATING MODE: All ESTABLISHIMAINTAIN SAFE SHUTDOWN (BD 70)

NOTE: Within the plant means:

Turbine Building OPERATING MODE: All Auxiliary Building Reactor Building NOTE: Only one train of a system needs to Keowee Hydro be affected or damaged in order to satisfy this Translormer Yard condition.

B3T B4T Service Air Diesel Compressors A. Fire/explosions Keowee Hydro & associated AND Transformers SSF Affected safety-related system parameter indications show degraded performance A- Fire within the plant not extinguished within OR 15 minutes of Control Room notification or Plant personnel report visible danmage to verification of a Control Room alarm permanent structures or equipment required for safe shutdown B. Unanticipated explosion within the plant resulting in visible damage to permanent (Continued) structures/equipment

  • includes steam line break and FDW line breAk (Continued) 15

Encl&e 4.6 RP/0/A* /001 Fire/Explosions and Security Actions 12) 13) Page 2 of 2 UNUSUAL EVENT ALERT '.. I -SITE AREA EMERGENCY GENERAL EMERGENCY

2. CONFIRMED SECURITY CONDITION 2 HOSTILE ACTION WITHIN THE 1. HOSTILE ACTION within the PROTECTED 1. A HOSTILE ACTION RESULTING IN OR THREAT WHICH INDICATES A OWNER CONTROLLED AREA OR AREA (BD 76) LOSS OF PHYSICAL CONTROL OF POTENTIAL DEGRADATION IN THE AIRBORNE ATTACK THREAT. (BD 72) THE FACILITY (BD 79)

LEVEL OF SAFETY OF THE PLANT OPERATING MODE: All (HD 67) OPERATING MODE: All OPERATING NIODE: All A. A HOSTILE ACTION is occurring or has A. A HOSTILE ACTION is occurring or has OPERATING MODE: All A. A HOSTILE ACTION has occurred such that occurred within the OWNER CONTROLLED occurred within the PROTECTED AREA as AREA as reported by the Security Shift reported by the Security Shift Supervision. plant personnel are unable to operate A. Security condition that does not involve a equipment required to maintain safety HOSTILE ACTION as reported by the Supervision.

functions Security Shift Supervision. 2. OTHER CONDITIONS EXIST WHICH IN B. A validated notification from NRC of an THE JUDGEMENT OF THE EMERGENCY B. A HOSTILE ACTION has caused failure of B. A credible site-specific security threat AIRLINER attack threat within 30 minutes of DIRECTOR WARRANT DECLARATION Spent Fuel Cooling Systems and notification the site. OF A SITE AREA EMERGENCY. (BD 78) IMMINENT fuel damage is likely for a freshly off-loaded reactor core in pool.

C. A validated notification from NRC providing OPERATING MODE: All information of an aircraft threat 3. OTHER CONDITIONS EXIST WHICH IN THE JUDGEMENT OF THE A. Other conditions exist which in the judgment of 2. OTHER CONDITIONS EXIST WHICH EMERGENCY DIRECTOR WARRANT the Emergency Director indicate that events are in IN THE JUDGMENT OF THE

3. OTHER CONDITIONS EXIST WHICH DECLARATION OF AN ALERT (BD 75) EMERGENCY DIRECTOR WARRANT progress or have occurred which involve actual or IN THE JUDGEMENT OF THE likely major failures of plant functions needed for DECLARATION OF A GENERAL EMERGENCY DIRECTOR WARRANT OPERATING MODE: All protection of the public or HOSTILE ACTION EMERGENCY. (BD 81)

DECLARATION OF A NOUE. (BD 69) that results in intentional damage or malicious A. Other conditions exist which in the judgment acts; (I) toward site personnel or equipment that OPERATING MODE: All of the Emergency Director indicate that events OPERATING MODE: All could lead to the likely failure of or, (2) that are in progress or have occurred which involve prevent effective access to equipment needed for A. Other conditions exist which in the judgment A. Other conditions exist which in the judgment an actual or potential substantial degradation of the protection of the public. Any releases are not of the Emergency Director indicate that the level of safety of the plant or a security of the Emergency Director indicate that expected to result in exposure levels which events are in progress or have occurred event that involves probable life threatening events are in progress or have occurred which exceed EPA Protective Action Guideline which involve actual or IMMINENT risk to site personnel or damage to site indicate a potential degradation of the level of exposure levels beyond the site boundary. substantial core degradation or melting with equipment because of HOSTILE ACTION.

salety of the plant or indicate a security threat potential for loss of containment integrity or Any releases are expected to be limited to small to facility protection has been initiated. No HOSTILE ACTION that results in an actual fractions of the EPA Protective Action releases of radioactive material requiring off- loss of physical control of the facility.

Guideline exposure levels.

site response or monitoring are expected (END) Releases can be reasonably expected to unless further degradation of safety systems exceed EPA Protective Action Guideline occurs. (END) exposure levels off-site for more than the immediate site area.

(END)

(END)

I I 16

Encle 4.7 RPaOgAe ofo3 Natural Disasters, Hazards and Other Conditions Affecting Plant Safety Page I of 3 UNUSUAL EVENT 'ALERT SITE AREA EMERGENCY GENERAL EMERGENCY NATURAL AND DESTRUCTIVE 1. NATURAL AND DESTRUCTIVE PHENOMENA AFFECTING THE PHENOMENA AFFECTING THE PLANT (CONTINUE TO NEXT PAGE) (CONTINUE TO NEXT PAGE)

PROTECTED AREA (BD 83) VITAL AREA (BD 89)

OPERATING MODE: All OPERATING MODE: All A. Tremor felt and valid alarm on the strong A. Tremor felt and seismic trigger actuates (0.05g) motion accelerograph NOTE: Only one train of a safety-related B Tornado striking within ProtectedArea Boundary system needs to be affected or damaged in order to satisfy these conditions.

C. Vehicle crash into plant structures/systems within the ProtectedArea Boundary B. Tornado, high winds, missiles resulting from turbine failure, vehicle crashes, or other D. Turbine failure eulting in casing penetration catastrophic event.

or damage to turbine or generator seals AND (CONTINUED) Visible damage to permanent structures or equipment required for safe shutdown of the unit.

OR Affected safety system parameter indications show degraded performance.

(CONTINUED) 17

Encle 4.7 RP/O/AJ/o001 Natural Disasters, Hazards and Other Conditions Affecting Plant Safety Page 2 of 3 UNUSUAL EVENT A LERT SITE AREA EMERGENCY.., GENERAL EMERGENCY

2. NATURAL AND DESTRUCTIVE 2. RELEASE OF TOXICIFLAMMABLE 1. CONTROL ROOM EVACUATION AND PHENOMENA AFFECTING KEOWEE GASES JEOPARDIZING SYSTEMS PLANT CONTROL CANNOT BE HYDRO CONDITION B (BD 85) REQUIRED TO MAINTAIN SAFE ESTABLISHED (BD 96) (CONTINUE TO NEXT PAGE)

OPERATION OR ESTABLISH/

OPERATING NIODE: All MAINTAIN MODE 5 (COLD OPERATING MODE: All SHUTDOWN) (BD 91)

A. Reservoir elevation Zt805.0 feet with all A. Control Room evacuation has been initiated spillway gates open and the lake elevation OPERATING MODE: All continues to rise A. Report/detection of toxic gases in AND concentrations that will be life-threatening to B. Seepage readings increase or decrease greatly plant personnel Control of the plant cannot be established from or seepage water is carrying a significant the Aux Shutdown Panel or the SSF within 15 amount of soil particles B. Report/detection of flammable gases in minutes concentrations that will affect the safe C New area of seepage or wetness, with large operation of the plant:

amounts of seepage water observed on dam,

  • Reactor Building 2. KEOWEE HYDRO DAM FAILURE dam toe, or the abutments
  • Auxiliary Building (BD 97)
  • Turbine Building D. Slide or other movement of the dam or
  • Control Room OPERATING MODE: All abutments which could develop into a failure
3. TURBINE BUILDING FLOOD (BD 93) A. Imminent/actual dam failure exists involving E. Developing failure involving the powerhouse or appurtenant structures and the operator believes any of the following:

the safety of the structure is questionable

  • Keowee Hydro Dam OPERATING MODE: All Little River Dam U
  • Dikes A, B, C, orD A. Turbine Building flood requiring use of
  • Intake Canal Dike
3. NATURAL AND DESTRUCTIVE AP/l .2,3/A/1700/10, (Turbine Building Rood)

PHENOMENA AFFECTING JOCASSEE

  • Jocassee Dam - Condition A HYDRO CONDITION B (BD 86)

(CONTINUED)

4. CONTROL ROOM EVACUATION HAS OPERATING MODE; All BEEN INITIATED (BD 94)

A. Condition B has been declared for the Jocassee OPERATING MODE: All Dam A. Evacuation of Control Room (CONTINUED)

AND ONE OF THE FOLLOWING:

Plant control IS established from the Aux shutdown Panel or the SSF OR Plant control IS BEING established from the Aux Shutdown Panel or SSF (CONTINUED) 18

Encl1 4.7 RP/O/AO/001 Natural Disasters, Hazards and Other Conditions Affecting Plant Safety Page 3 of 3 UNUSUAL EVENT. ALERT SITE AREA EMERGENCY GENERAL EMERGENCY

4. RELEASE OF TOXIC OR FLAMMABLE 5. OTHER CONDITIONS WARRANT 3. OTHER CONDITIONS WARRANT 1. OTHER CONDITIONS WARRANT GASES DEEMED DETRIMENTAL TO SAFE CLASSIFICATION OF AN ALERT DECLARATION OF SITE AREA DECLARATION OF GENERAL OPERATION OF THE PLANT (BD 87) (BD 95) EMERGENCY (BD 98) EMERGENCY (BD 99)

OPERATING MODE: All OPERATING MODE; All OPERATING MOI)E: All OPERATING NOI)E; All A. Rcport/detection of toxic or flammable gases A. Emergency Coordinator judgment indicates A. Emergency Coordinator/EOF Director A. Emergency Coordinator/EOF Director that could enter within the site area boundary in that: judgment judgment indicates:

amounts that can affect normal operation of the plant Plant safety may be degraded Actual/imminent substantial core D(END) degradation with potential for loss of B. Report by local, county, state officials for AND containment potential evacuation of site personnel based on offsite event Increased monitoring of plant functions OR is warranted Potential for uncontrolled

5. OTHER CONDITIONS EXIST WHICH (END) radionuclide releases that would WARRANT DECLARATION OF AN result in a dose projection at the UNUSUAL EVENT (BD 88) site boundary greater than 1000 mRem TEDE or 5000 mRem CDE Adult Thyroid OPERATING MODE: All A. Emergency Coordinator determines potential (END) degradation of level of safety has occurred (END) 19

Enclosure 4.8 0

RP/O/A/1000/001 Radiation Monitor Readings for Emergency Classification Page I of 1 All RIA values are considered GREATER THAN or EQUAL TO HOURS SINCE RIA 57 R/hr. RIA 58 R/hr*

REACTOR TRIPPED Site Area Emergency General Emergency Site Area Emergency General Emergency 0.0 - < 0.5 5.9E+003 5.9E+004 2.6E+003 2.6E+004 0.5 - < 1.0 2.6E+003 2.6E+004 1.1E+003 1.1EE+004 1.0 - < 1.5 1.9E+003 1.9E+004 8.6E+002 8.6E+003 1.5 - < 2.0 1.9E+003 1.9E+004 8.5E+002 8.5E+003 2.0 - < 2.5 1.4E+003 1.4E+004 6.3E+002 6.3E+003 2.5 - < 3.0 1.2E+003 1.2E+004 5.7E+002 5.7E+003 3.0 - < 3.5 1.1E+003 1.1E+004 5.2E+002 5.2E+003 3.5 - < 4.0 1.0E+003 1.OE+004 4.8E+002 4.8E+003 4.0 - < 8.0 1.0E+003 1.0E+004 4.4E+002 4.4E+003

  • RIA 58 is partially shielded 20

O Enclosure 4.9 O

RP/O/A/ 1000/001 Unexpected/Unplanned Increase In Area Monitor Readings Page 1 of 1 NOTE: This Initiating Condition is not intended to apply to anticipated temporary increases due to planned events (e.g.; incore detector movement, radwaste container movement, depleted resin transfers, etc.).

UNITS 1, 2,3 MONITOR NUMBER UNUSUAL EVENT 1000x ALERT NORMAL LEVELS mRAD/HR mRAD/HR RIA 7, Hot Machine Shop Elevation 796 150 Ž5000 RIA 8, Hot Chemistry Lab Elevation 796 4200 > 5000 RIA 10, Primary Sample Hood Elevation 796 830 > 5000 RIA 11, Change Room Elevation 796 210 Ž 5000 RIA 12, Chem Mix Tank Elevation 783 800 > 5000 RIA 13, Waste Disposal Sink Elevation 771 650 > 5000 RIA 15, HPI Room Elevation 758 NOTE* > 5000 NOTE: RIA 15 normal readings are approximately 9 mRad/hr on a daily basis. Applying 1000x normal readings would put this monitor greater than 5000 mRad/hr just for an Unusual Event. For this reason, an Unusual Event will NOT be declared for a reading less than 5000 mRad/hr.

21

Enclosure 4.10 RP/O/A/1000/001 Definitions/Acronyms Page 1 of 5

  • 1. List of Definitions and Acronyms NOTE: Definitions are italicized throughout procedure for easy recognition.

1.1 ALERT - Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

1.2 BOMB - Refers to an explosive device suspected of having sufficient force to damage plant systems or structures.

1.3 COGNIZANT FACILITY STAFF - any member of facility staff, who by virtue of training and experience, is qualified to assess the indications or reports for validity and to compare the same to the EALs in the licensee's emergency classification scheme. (Does not include staff whose positions require they report, rather than assess, abnormal conditions to the facility.)

1.4 CONDITION A - Failure is Imminent or Has Occurred - A failure at the dam has occurred or is about to occur and minutes to days may be allowed to respond dependent upon the proximity to the dam.

@ 1.5 CONDITION B - Potentially Hazardous Situation is Developing - A situation where failure may develop, but preplanned actions taken during certain events (such as major floods, earthquakes, evidence of piping) may prevent or mitigate failure.

1.6 CIVIL DISTURBANCE - A group of persons violently protesting station operations or activities at the site.

1.7 EXPLOSION - A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components.

1.7 EXTORTION - An attempt to cause an action at the station by threat of force.

1.8 FIRE - Combustion characterized by heat and light. Sources of smoke, such as slipping drive belts or overheated electrical equipment, do NOT constitute fires. Observation of flames is preferred but is NOT required if large quantities of smoke and heat are observed.

1.9 FRESHLY OFF-LOADED CORE - The complete removal and relocation of all fuel assemblies from the reactor core and placed in the spent fuel pool. (Typical of a "No Mode" operation during a refuel outage that allows safety system maintenance to occur and results in maximum decay heat load in the spent fuel pool system).

22

Enclosure 4.10 RP/O/A/1000/001 Definitions/Acronyms Page 2 of 5 1.10 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 or HOSTILE ACTION that results in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guidelines exposure levels offsite for more than the immediate area.

1.11 HOSTAGE - A person(s) held as leverage against the station to ensure demands will be met by the station.

1.12 HOSTILE ACTION - An act toward an NPP or its personnel that includes the use of violent force to destroy equipment, takes HOSTAGES, and/or intimidates the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the owner controlled area.)

1.13 HOSTILE FORCE - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

1.14 IMMINENT - Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur. Where IMMINENT timeframes are specified, they shall apply.

1.15 INTRUSION - A person(s) present in a specified area without authorization. Discovery of a BOMB in a specified area is indication of INTRUSION into that area by a HOSTILE FORCE.

1.16 INABILITY TO DIRECTLY MONITOR - Operational Aid Computer data points are unavailable or gauges/panel indications are NOT readily available to the operator.

1.17 LOSS OF POWER - Emergency Action Levels (EALs) apply to the ability of electrical energy to perform its intended function, reach its intended equipment. Ex. - If both MFBs, are energized but all 4160v switchgear is not available, the electrical energy can not reach the motors intended. The result to the plant is the same as if both MFBs were de-energized.

1.18 PROJECTILE - An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

1.19 PROTECTED AREA - Typically the site specific area which normally encompasses all controlled areas within the security PROTECTED AREA fence.

23

Enclosure 4.10 RP/O/A/1000/001 Definitions/Acronyms Page 3 of 5 1.20 REACTOR COOLANT SYSTEM (RCS) LEAKAGE - RCS Operational Leakage as defined in the Technical Specification Basis B 3.4.13:

RCS leakage includes leakage from connected systems up to and including the second normally closed valve for systems which do not penetrate containment and the outermost isolation valve for systems which penetrate containment.

A. Identified LEAKAGE LEAKAGE to the containment from specifically known and located sources, but does not include pressure boundary LEAKAGE or controlled reactor coolant pump (RCP) seal leakoff (a normal function not considered LEAKAGE).

LEAKAGE, such as that from pump seals, gaskets, or valve packing (except RCP seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank; LEAKAGE through a steam generator (SG) to the Secondary System (primary to secondary LEAKAGE): Primary to secondary LEAKAGE must be included in the total calculated for identified LEAKAGE.

B. Unidentified LEAKAGE All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE.

C. Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a nonisolable fault in an RCS component body, pipe wall or vessel wall.

1.21 RUPTURED (As relates to Steam Generator) - Existence of Primary to Secondary leakage of a magnitude sufficient to require or cause a reactor trip and safety injection.

1.22 SABOTAGE - Deliberate damage, mis-alignment, or mis-operation of plant equipment with the intent to render the equipment inoperable. Equipment found tampered with or damaged due to malicious mischief may not meet the definition of SABOTAGE until this determination is made by security supervision.

1.23 SECURITY CONDITION - Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.

1.24 SAFETY-RELATED SYSTEMS AREA - Any area within the Protectedarea which contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation.

24

Enclosure 4.10 RP/O/A/1000/001 Definitions/Acronyms Page 4 of 5 1.25 SELECTED LICENSEE COMMITMENT (SLC) -Chapter 16 of the FSAR 1.26 SIGNIFICANT PLANT TRANSIENT - An unplannedevent involving one or more of the following:

(1) Automatic turbine runback>25% thermal reactor power (2) Electrical load rejection >25% full electrical load (3) Reactor Trip (4) Safety Injection System Activation 1.27 SITE AREA EMERGENCY - Events are in process or have occurred which involve actual or likely major failures of plant functions needed for the protection of the public, or HOSTILE ACTION that results in intentional damage or malicious act; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevents effective access to equipment needed for the protection of the public. Any releases are NOT expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the Site Boundary.

1.28 SITE BOUNDARY - That area, including the ProtectedArea, in which DPC has the authority to control all activities including exclusion or removal of personnel and property (1 mile radius from the center of Unit 2).\

1.29 TOXIC GAS - A gas that is dangerous to life or health by reason of inhalation or skin contact (e.g.; Chlorine).

1.30 UNCONTROLLED - Event is not the result of planned actions by the plant staff.

1.31 UNPLANNED - An event or action is UNPLANNED if it is not the expected result of normal operations, testing, or maintenance. Events that result in corrective or mitigative actions being taken in accordance with abnormal or emergency procedures are UNPLANNED.

1.32 UNUSUAL EVENT - Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

1.33 VALID - An indication or report or condition is considered to be VALID when it is conclusively verified by: (1) an instrument channel check; or, (2) indications on related or redundant instrumentation; or, (3) by direct observation by plant personnel such that doubt related to the instrument's operability, the condition's existence, or the report's accuracy is removed. Implicit with this definition is the need for timely assessment.

25

Enclosure 4.10 RP/O/A/1000/001 Definitions/Acronyms Page 5 of 5 1.34 VIOLENT - Force has been used in an attempt to injure site personnel or damage plant property.

1.35 VISIBLE DAMAGE - Damage to equipment or structure that is readily observable without measurements, testing, or analyses. Damage is sufficient to cause concern regarding the continued operability or reliability of affected safety structure, system, or component.

Example damage: deformation due to heat or impact, denting, penetration, rupture.

1.36 VITAL AREA - An area within the protected area where an individual is required to badge in to gain access to the area and that houses equipment important for nuclear safety. The failure or destruction of this equipment could directly or indirectly endanger the public health and safety by exposure to radiation.

26

Enclosure 4.11 RP/O/AI 1000/001 Operating Modes Defined In Improved Page 1 of 1 Technical Specifications MODES REACTIVITY  % RATED AVERAGE CONDITION THERMAL REACTOR COOLANT MODE TITLE POWER (a) TEMPERATURE (Keff) (OF)

I Power Operation >0.99 >5 NA 2 Startup >0.99 <5 NA 3 Hot Standby <0.99 NA >250 4 Hot Shutdown (b) < 0.99 NA 250 > T > 200 5 Cold Shutdown (b) < 0.99 NA < 200 6 Refueling (c) NA NA NA (a) Excluding decay heat.

(b) All reactor vessel head closure bolts fully tensioned.

(c) One or more reactor vessel head closure bolts less than fully tensioned 27

Enclosure 4.12 RP/O/A/1000/001 Instructions For Using Enclosure 4.1 Page 1 of 2

1. Instructions For Using Enclosure 4.1 - Fission Product Barrier Matrix 1.1 If the unit was at Hot S/D or above, (Modes 1, 2, 3, or 4) and one or more fission product barriers have been affected, refer to Enclosure 4.1, (Fission Product Barrier Matrix) and review the criteria listed to determine if the event should be classified.

1.1.1 For each Fission Product Barrier, review the associated EALs to determine if there is a Loss or Potential Loss of that barrier.

NOTE: An event with multiple events could occur which would result in the conclusion that exceeding the loss or potential loss thresholds is imminent (i.e. within 1-3 hours). In this situation, use judgement and classify as if the thresholds are exceeded.

1.2 Three possible outcomes exist for each barrier. No challenge, potential loss, or loss.

Use the worst case for each barrier and the classification table at the bottom of the page to determine appropriate classification.

1.3 The numbers in parentheses out beside the label for each column can be used to assist in determining the classification. If no EAL is met for a given barrier, that barrier will have 0 points. The points for the columns are as follows:

BFmkr Ualm PoQin RCS Potential Loss 4 Loss 5 Fuel Clad Potential Loss 4 Loss 5 Containment Potential Loss 1 Loss 3 1.3.1 To determine the classification, add the highest point value for each barrier to determine a total for all barriers. Compare this total point value with the numbers in parentheses beside each classification to see which one applies.

1.3.2 Finally as a verification of your decision, look below the Emergency Classification you selected. The loss and/or potential loss EALs selected for each barrier should be described by one of the bullet statements.

28

Enclosure 4.12 RP/O/A/1000/001 Instructions For Using Enclosure 4.1 Page 2 of 2 EXAMPLE: Failure to properly isolate a 'B' MS Line Rupture outside containment, results in extremely severe overcooling.

PTS entry conditions were satisfied.

Stresses on the 'B' S/G resulted in failure of multiple S/G tubes.

RCS leakage through the S/G exceeds available makeup capacity as indicated by loss of subcooling margin.

Barrier EAL Failure Points RCS SGTR > Makeup capacity of one HPI pump in Potential Loss 4 normal makeup mode with letdown isolated Entry into PTS operating range Potential Loss 4 RCS leak rate > available makeup capacity as Loss 5 indicated by a loss of subcooling Fuel Clad No EALs met and no justification for No 0 classification on judgment I I_ Challenge Containment Failure of secondary side of SG results in a Loss 3 direct opening to the environment RCS 5 + Fuel 0 + Containment 3 = Total 8 A. Even though two Potential Loss EALs and one Loss EAL are met for the RCS barrier, credit is only taken for the worst case (highest point value) EAL, so the points from this barrier equal 5.

B. No EAL is satisfied for the Fuel Clad Barrier so the points for this barrier equal 0.

C. One Loss EAL is met for the Containment Barrier so the points for this barrier equal 3.

D. When the total points are calculated the result is 8, therefore the classification would be a Site Area Emergency.

E. Look in the box below "Site Area Emergency". You have identified a loss of two barriers. This agrees with one of the bullet statements.

The classification is correct.

29

Enclosure 4.13 RP/O/A/1000/001 References Page 1 of 1 I

References:

1. PIP 0-05-02980
2. PIP 0-05-4697
3. PIP 0-06-0404
4. PIP 0-06-03347
5. PIP 0-09-00234
6. PIP 0-10-1055
7. PIP 0-10-01750
8. PIP 0-11-02811
9. PIP 0-12-1590
10. PIP 0-10-7809
11. PIP 0-12-9201
12. PIP 0-12-9198
13. PIP 0-12-11227
14. PIP 0-14-10064 and PIP 0-14-11470
15. PIP 0-13-6662
16. PIP 0-14-13933

3.10 10CFR 50.54(q) Evaluations Emergency Planning Functional Area Manual Attachment 3.10.7.2 4W §50.54(q) Screening Evaluation Form Activity Description and

References:

RP/O/A/1000/001, Emergency Classification, Revision 003 Revision 003 of RP/0/A/1000/001 consists of the following change.

Protected Service Water replaces the Station Auxiliary Service Pump as a result of a system modification. Change made to clarify sub-step of EAL 4.4.S.2.C (ComoIete Loss of Shutdown Function Needed to Achieve or Maintain Mode 4 (Hot Shutdown)

See attached sheet for all changes pertaining to this procedure.

Activity Scope: B -

[ The activity is a change to the emergency plan El The activity is not a change to the emergency plan Change Type: BL Change Type:

El The change is editorial or typographical E] The change does conform to an activity that has Z The change is not editorial or typographical prior approval The change does not conform to an activity that has prior approval Planning Standard Impact Determination:

El §50.47(b)(1) - Assignment of Responsibility (Organization Control)

§ 50.47(b)(2) - Onsite Emergency Organization

§50.47(b)(3) - Emergency Response Support and Resources

§50.47(b)(4) - Emergency Classification System*

El §50.47(b)(5) - Notification Methods and Procedures*

El §50.47(b)(6) - Emergency Communications El §50.47(b)(7) - Public Education and Information El §50.47(b)(8) - Emergency Facility and Equipment El §50.47(b)(9) - Accident Assessment*

El §50.47(b)(10) - Protective Response*

El §50.47(b)(1 1) - Radiological Exposure Control El §50.47(b)(12) - Medical and Public Health Support

[E §50.47(b)( 13) - Recovery Planning and Post-accident Operations El §50.47(b)(14) - Drills and Exercises El §50.47(b)(I 5) - Emergency Responder Training El §50.47(b)(16) - Emergency Plan Maintenance

  • Risk Significant Planning Standards El The proposed activity does not impact a Planning Standard Commitment Impact Determination: BLOCK 6.

El The activity does involve a site specific EP commitment Record the commitment or commitment reference:

[ The activity does not involve a site specific EP commitment

I. .,"

Results: Li.BLOCK 7,:

[I The activity can be implemented without performing a §50.54(q) effectiveness evaluation m

LI The activity cannot be implemented without performing a §50.54(q) effectiveness evaluation IP arer Name: Dat Mike Stephens Reviewer Name: Date:

Don Growl '/-T- -/.<

Revision 12

3.10 10CFR 50.54(q) Evaluations Emergency Planning Functional Area Manual Attachment 3.10.7.3

§50.54(q) Effectiveness Evaluation Form a

%ctivity Description and

References:

Revision 003 of RP/O/A/1000/001 consists of the following change.

Protected Service Water replaces the Station Auxiliary Service Pump as a result of a system modification. Change made to clarify sub-step of EAL 4.4.S.2.C (Complete Loss of Shutdown Function Needed to Achieve or Maintain Mode 4 (Hot Shutdown). Clarification added to address a total loss of main and emergency feedwater with SSF and PSW unavailable coincident with degraded High Pressure Injection.

See attached change matrix:

Activity Type: IBLO I Z The activity is a change to the emergency plan EJ The activity affects implementation of the emergency plan, but is not a change to the emergency plan Impact and Licensing Basis Determination:

Licensing Basis:

10CFR50.47b (4) A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

NUREG 0654II.D.1 An emergency classification and emergency action level scheme as set forth in Appendix I must be established by the licensee. The specific instruments, parameters or equipment status shall be shown for establishing each emergency class, in the in-plant emergency procedures. The plan shall identify the parameter values and equipment status for each emergency class.

PiS E-Plan Section D, EMERGENCY CLASSIFICATION SYSTEM States;

  • eg Guide 1.101, Rev. 3, August, 1992, approved the guidance provided by NUMARC/NESP-007, Revision 2, as an Alternative Methodology for the Development of Emergency Action Levels. Oconee Nuclear Site used the NUMARC guidance for the development of initiating conditions and emergency action levels. The emergency action levels provided in this section have been modified to implement the guidance provided in NRC Bulletin 2005-02, NEI guidance as endorsed in Regulatory Issue Summary 2006-12 and to support the implementation of NEI 03-12.

Changes to ONS E-Plan Section D, EMERGENCY CLASSIFICATION SYSTEM documented under separate 50.54q evaluation.

Reg. Guide 1.219 lists the emergency planning function associated with 10 CFR 50.47(b)(4).

A standard scheme of emergency classification and action level is in use.

Compliance Evaluation and

Conclusion:

~BLO9~4A

1. Evaluation:

Basis Information for Fission Product Barrier Reference Table Enc. 4.1 (4) Reactor Coolant System Integrity.

HPI Forced cooling represents the failure of the steam generators to remove heat from the core. To use this mode of cooling indicates that all feedwater (both main and emergency) are not available for use and the pressure of the reactor coolant system is greater than or equal to 2300 psig. The power-operated relief valve must be opened to initiate the cooling through the high pressure injection system. In effect, a self-imposed loss of coolant is established. This condition is classified as a potential loss of the reactor coolant system. HPI Forced Cooling is classified as an Alert from RP/0/A/1000/001 Enc. 4.1 Fission Product Barrier Matrix.

,Conclusion:

The proposed activity 0 does / [] does not continue to comply with the requirements.

Reduction in Effectiveness (RIE) Evaluation and

Conclusion:

BL0C- 5!.

Evaluation:

Current wording in Enc. 4.4.S.2.C states: "EOP directs feeding SG from SSF ASWP or PSW Pump. The installation of the PSW Pump enabled the Station to not require a blow-down of the SG's in order to commence feeding to achieve shutdown cooling, as the PSW pump is a high discharge head pump. The installation and use of the PSW pump provides a better margin of safety for the plant. The use of the PSW pump remains consistent with the technical bases of the EAL (NUMARC - NESP-007, IC - SS4 -Complete Loss of Heat Removal Capability EAL 1 Loss of core cooling and heat sink (PWR). Core exit thermocouple readings are considered to be the average of the five (5) highest thermocouple reading shown on the Inadequate Core Cooling Monitor. The SSF can provide the following: (1) makeup to the Reactor Coolant Pump seals, (2) low pressure service water to the steam generators, (3) capability to keep the unit in hot shutdown for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following an Appendix R fire. This change is then in keeping true to the basis as currently written.

The basis provides, "This EAL addresses complete loss of functions core cooling and heat sink required for hot shut down with the reactor at pressure and temperature. Under these conditions, there is an actual major failure of a system intended for protection of the public. Thus, declaration of a Site Area Emergency is warranted with the total loss of main and emergency feedwater with SSF and PSW unavailable coincident with degraded High Pressure Injection. Escalation to General Emergency would be via Abnormal Rad Levels/Radiological Effluent, Emergency Coordinator Judgment or Fission Product Barrier Degradation ICs".

Conclusion:

The proposed activity F] does / does not constitute a RIE.

ffectiveness Evaluation Results LOCK6 The activity does continue to comply with the requirements of §50.47(b) and §50 Appendix E and the activity does not constitute a reduction in effectiveness. Therefore, the activity can be implemented without prior approval.

F1 The activity does not continue to comply with the requirements of §50.47(b) and §50 Appendix E or the activity does constitute a reduction in effectiveness. Therefore, the activity cannot be implemented without prior approval.

Preparer Name: Pre ?Antu a

..... re Na m

........e....................

.......e..gn..r.

."P .. . .....

..... . D ' e -.. . .* . ... . .......

Mike Stephens _

Reviewer Name: Review Sign re Date-Don Crowl .... r-/ -

Approver Name: p ignatlr4 9 Date:

Pat Street R N I q 1*J ]T Revision 12

3.10 IOCFR 50.54(q) Evaluations Emergency Planning Functional Area Manual Attachment 3.10.7.2 EAL Change Review Form J

Rhange Description and

References:

/ - i/l//4-B///b,6/L

'BLOCK",

Revision 003 of E-Plan Section D consists of the following change. e,,t ý3

,.* C -a. , *_4ý Protected Service Water replaces the Station Auxiliary Service Pump as a result ot a system qjý,_j.5 modification. Change made to clarify sub-step of EAL 4.4.S.2.C (Complete Loss of Shutdown Function Needed to Achieve or Maintain Mode 4 (Hot Shutdown).

Change Type: E ýB

ý

[ The change is considered a difference from the approved wording.

El The change is considered a deviation from the approved wording.

Change Verification:

Item Yes No N/A Resolution/Comments Initiating CondItIoni "__.-*

IC identification number is correct 0 El fE .________- . _______,

Click here to enter text.

Wording is consistent with the NRC approved IC j 0 [ Click here to enter text.

EAL/FPB identification number is correct 0 El El Click here to enter text.

Wording is consistent with the NRC approved EAL / FPB 0l 0 Cl PSW modieinstalled antd associated procedure changes tnade.

Threshold values or conditions remain specific to ensure generic Z I] El Click here to enter text.

teria are not substituted reducing clarity and accuracy of the Sequencing/nesting 1L.

logic format is correct 0 El El Click here to enter text.

Source document inputs used for calculations and in thresholds are 0 El El Click here to enter text.

correct Site specific content wording/tables/values are correct and specific: 0 El El ('lick here to enter text.

  • Operations procedures are consistent with the change
  • Instrument/display number and noun name are provided
  • Alarm sctpoints are equal to or below EAL/FPB values
  • Radiation monitor values account for background

" Procedure references are correct The EAI/FPB Matrix is legible and intuitively organized 0 El El Click here to enter text.

Miode Applicability "

Operational mode alignment is consistent with the EAL licensing 1 [, l (Click here to enter text.

basis jj ___

Technical Bases - ..

Site specific bases is consistent with the EAL threshold 0 El El Click here to enter text.

Bases for calculations and threshold values are consistent with the 0 El1 E Click here to enter text.

technical bases approved by the NRC Source document inputs used for calculations and in thresholds are 0 El3 E Click here to enter text.

correct Site specific bases remains accurate and consistent with the EAL 0] El E Click here to enter text.

technical bases approved by the NRC pecific bases has appropriate level of detail and is o El E (

Click hcre to enter text.

biguous I __

The change does not cause a change to the logic of the EAL scheme 0 El El Click here to enter text.

(i.e. gaps in classification thresholds)

Contlicts with the EAI.FPB wording have not been introduced 0 El El Click here to enter text.

  • evision 12

.10 10CFR 50.54(q) Evaluations Emergency Planning Functional Area Manual Attachment 3.10.7.2 References Source document references are correct 0 El E I Click here to enter text.

Source document references are current 0 E] 11 Click here to enter text.

Definition&-:

Wording is consistent with the license basis definitions approved l l Ccick here to enter text.

by the NRC for the EALs and EAL technical bases I I I Other Manual Content.,

Wording isconsistent with the license basis definitions approved by the NRC for the EALs and EAL technical bases I 0 I l l lick here to enter text.

Change Validation:

Me-hod i..,.-

0 In-Plant Walk down El Simulator [ Other (Specify)

EOP Changes o Training El Tabletop E- N/A Item Yes No N/A Resolution/Comments

/ "FPB. ':I.

rmation and/or values are available in all facilities where 0 El E[ Click here to enter text.

classifications are required to be made Instrumentation and computer points are compatible: Q 0 Click Cl here to enter text.

  • Instrument/display designation matches
  • Instrument/display units are correct
  • Proper significant digits are indicated and within the accuracy capabilities of the instrument/display
  • The instrument/display range is on scale for the threshold value
  • Instrument/display provides separation for escalating values Conditions are easily recognizable and able to support declaration 0 El El Click here to enter text.

within 15 minutes.

Information and/or values are easily obtained and able to support 0 E El Click here to enter text.

declaration within 15 minutes The change does not introduce a time delay to classification 11 [] Click here to enter text.

Change Justification: HPI Forced cooling represents the failure of the steamr generators to remove heat from the core. To use this mode of cooling indicates that all feedwater (both main and emergency) are not available for use and the vis pressure of the reactor coolant system is greater than or equal to 2300 psig. The power-operated relief valve must be opened to initiate the cooling through the high pressure injection system. In effect, a self-imposed loss of coolant is established. Declaration of a Site Area Emergency is warranted with the total loss I of main and emergency feed water with SSF and PSW unavailable coincident

  • degraded High Pressure Injection.

EAL Change Review Results: ... B.LOCK 6.-.,

Z The EAL change can be implemented without prior NRC approval.

El The EAL change cannot be implemented without prior NRC approval.

parer Name: !P7 rS-l ike Stephens Date Reviewer Name: Review r Signature Don Crowl _ _

Date:

Approver Name: Aeto a-e Pat Street A-Revision 12

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