Text

Emergency Action Levels CSD-EP-RNP-0101-02, Revision 0
	ML20044C811
Person / Time
Site:	Robinson
Issue date:	02/13/2020
From:	Nolan M; Duke Energy Progress
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RA-20-0050
	Download: ML20044C811 (10)
	v • d • e

£DUKE

ENERGY Serial: RA-20-0050 February 13, 2020 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 I RENEWED LICENSE NO. DPR-23

SUBJECT:

Emergency Action Levels CSD-EP-RNP-0101-02, Revision 0 Ladies and Gentlemen:

M. CHRISTOPHER NOLAN Vice President Nuclear Regulatory Affairs, Policy &

Emergency Preparedness 526 South Church Street, EC-07C Charlotte, NC 28202 980-382-7426 Chris.Nolan@duke-energy.com 10 CFR 50.54(q)

In accordance with 10 CFR 50.54(q), Duke Energy Progress, LLC (Duke Energy) is submitting Revision O for H.B. Robinson Steam Electric Plant (Robinson), Unit No. 2 procedure CSD-EP RNP-0101-02, which contains the Emergency Action Levels (EAL). This document is a new Robinson procedure that provides the EALs in a matrix to facilitate ease of classification.

Issuance of this document combines three separate EAL documents into one single file. No changes were made to the EALs.

In accordance with 10 CFR 50.54(q)(5), Attachment I includes a summary of analyses associated with the issuance of CSD-EP-RNP-0101-02. Attachment II is Revision O of CSD-EP RNP-0101-02.

This document contains no new Regulatory Commitments.

Should you have any questions concerning this letter, or require additional information, please contact Art Zaremba, Manager-Nuclear Fleet Licensing, at 980-373-2062.

Sincerely,

/4-

M. Christopher Nolan Vice President, Nuclear Regulatory Affairs, Policy & Emergency Preparedness Attachment I: 10 CFR 50.54(q) Screening Evaluation Form Attachment II: CSD-EP-RNP-0101-02, Revision 0 cc:

L. Dudes, NRC Regional Administrator, NRC, Region II M. Fannon, NRC Senior Resident Inspector, HBRSEP, Unit No. 2 A. Hon, NRC Project Manager, NRR

U.S. Nuclear Regulatory Commission Attachment I, Page 1 Serial: RA-20-0050 Attachment I: 10 CFR 50.54(q) Screening Evaluation Form

U.S. Nuclear Regulatory Commission Attachment I, Page 2 Serial: RA-20-0050

<< 10 CFR 50.54(q) Screening Evaluation Form >>

Screening and Evaluation Number Applicable Sites EREG #: 2305303 BNP CNS CR3 HNP 5AD #: 2305232 MNS ONS RNP GO Document and Revision CSD-EP-RNP-0101-02, EAL Wallcharts Rev 0 Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

Overall Change: CSD-EP-RNP-0101-02 (formally Emergency Action Level Matrix 1, Emergency Action Level Matrix 2, Emergency Action Level Matrix 3) is a new Robinson procedure that provides the EALs in a matrix to facilitate ease of classification.

E-Plan or Procedure Section Reference Current (Existing) Text Proposed (Change) Text 1

EALs CS1.1, CS1.1, CS1.2, CG1.1 New Reference (Figure C-RVLIS) added to refer to a figure in the wallchart, previously not referenced Part II. Activity Previously Reviewed?

Yes No

U.S. Nuclear Regulatory Commission Attachment I, Page 3 Serial: RA-20-0050 Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or Alert and Notification System Design Report?

If yes, identify bounding source document number or approval reference and ensure the basis for concluding the source document fully bounds the proposed change is documented below:

Justification:

10 CFR 50.54(q)

Effectiveness Evaluation is not required. Enter justification below and complete,

Part V.

Continue to,

10 CFR 50.54(q)

Screening Evaluation Form, Part III Bounding document attached (optional)

Part III. Editorial Change Is this activity an editorial or typographical change only, such as formatting, paragraph numbering, spelling, or punctuation that does not change intent?

Justification:

Yes No or Partially 10 CFR 50.54(q)

Effectiveness Evaluation is not required. Enter justification and complete,

Part V.

Continue to,

Part IV and address non editorial changes Part IV. Emergency Planning Element and Function Screen (Reference Attachment 1, Considerations for Addressing Screening Criteria)

Does this activity involve any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If answer is yes, then check box.

1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.

1b The response organization has the staff to respond and to augment staff on a continuing basis (24-7 staffing) in accordance with the emergency plan.

2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned 2b The process for timely augmentation of on shift staff is established and maintained.

3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.

3b State and local staff can be accommodated at the EOF in accordance with the emergency plan. (NA for CR3) 4 10 CFR 50.47(b)(4) Emergency Classification System 4a A standard scheme of emergency classification and action levels is in use. (Requires final approval of Screen and Evaluation by EP CFAM.)

5 10 CFR 50.47(b)(5) Notification Methods and Procedures 5a Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.

5b Administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway. (NA for CR3)

U.S. Nuclear Regulatory Commission Attachment I, Page 4 Serial: RA-20-0050 5c The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. (NA for CR3)

U.S. Nuclear Regulatory Commission Attachment I, Page 5 Serial: RA-20-0050 Part IV. Emergency Planning Element and Function Screen (cont.)

6 10 CFR 50.47(b)(6) Emergency Communications 6a Systems are established for prompt communication among principal emergency response organizations.

6b Systems are established for prompt communication to emergency response personnel.

7 10 CFR 50.47(b)(7) Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ). (NA for CR3) 7b Coordinated dissemination of public information during emergencies is established.

8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response.

8b Adequate equipment is maintained to support emergency response.

9 10 CFR 50.47(b)(9) Accident Assessment 9a Methods, systems, and equipment for assessment of radioactive releases are in use.

10 10 CFR 50.47(b) (10) Protective Response 10a A range of public PARs is available for implementation during emergencies. (NA for CR3) 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities. (NA for CR3) 10c A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.

10d KI is available for implementation as a protective action recommendation in those jurisdictions that chose to provide KI to the public.

11 10 CFR 50.47(b) (11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.

12 10 CFR 50.47(b) (12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.

13 10 CFR 50.47(b) (13) Recovery Planning and Post-Accident Operations 13a Plans for recovery and reentry are developed.

14 10 CFR 50.47(b) (14) Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program areas) is established.

14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.

14c Identified weaknesses are corrected.

U.S. Nuclear Regulatory Commission Attachment I, Page 6 Serial: RA-20-0050 Part IV. Emergency Planning Element and Function Screen (cont.)

15 10 CFR 50.47(b) (15) Emergency Response Training 15a Training is provided to emergency responders.

16 10 CFR 50.47(b) (16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established.

16b Planners responsible for emergency plan development and maintenance are properly trained.

PART IV. Conclusion If no Part IV criteria are checked, then provide Justification and complete Part V below.

Justification:

CSD-EP-RNP-0101-02, EAL Wallchart, superseded Emergency Action Level Matrix 1, Emergency Action Level Matrix 2, Emergency Action Level Matrix 3, in its entirety, to align with fleet procedure format. The fleet alignment changes the document number and title only.

Change 1 adds a reference to specific EALs where the figure was not previously referenced. The Figure shows the various heights of the RNP reactor vessel as a visual aid, however, does not factor into classification decision making.

Because it is a new procedure and no changes are being made to any emergency plan, there is no reduction in effectiveness. No further evaluation is required.

If any Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV criteria are checked, then complete, 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q)

Effectiveness Evaluation. Program Element 4a requires final approval of Screen and Evaluation by EP CFAM.

U.S. Nuclear Regulatory Commission Attachment II Serial: RA-20-0050 Attachment II: CSD-EP-RNP-0101-02, Revision 0

CA1.1 Loss of RCS inventory as indicated by RCS water level

< -72 in. (69% RVLIS Full Range) (Figure C-RVLIS)

CU1.1 UNPLANNED loss of reactor coolant results in RCS water level less than a required lower limit for 15 min. (Note 1)

RCS water level cannot be monitored AND EITHER UNPLANNED increase in any Table C-1 sump or tank due to a loss of RCS inventory OR Visual observation of UNISOLABLE RCS leakage CU1.2 RCS water level cannot be monitored for 30 min. (Note 1)

AND Core uncovery is indicated by any of the following:

UNPLANNED increase in any Table C-1 sump or tank of sufficient magnitude to indicate core uncovery Containment High Range Radiation Monitor R-32A or R-32B > 5 R/hr Erratic source range monitor indication RCS water level cannot be monitored for 30 min. (Note 1)

AND Core uncovery is indicated by any of the following:

UNPLANNED increase in any Table C-1 sump or tank of sufficient magnitude to indicate core uncovery Containment High Range Radiation Monitor R-32A or R-32B > 5 R/hr Erratic source range monitor indication AND Any Containment Challenge indication, Table C-2 RCS water level cannot be monitored for 15 min. (Note 1)

AND EITHER UNPLANNED increase in any Table C-1 sump or tank due to a loss of RCS inventory OR Visual observation of UNISOLABLE RCS leakage CA1.2 None Cold SD/

Refuel System Malfunct.

Loss of Emergency AC Power Loss of all but one AC power source to emergency buses for 15 minutes or longer CU2.1 AC power capability, Table C-6, to 480V emergency buses E-1 and E-2 reduced to a single power source for 15 min.

(Note 1)

AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS

< 109.5 VDC (Bus A) / < 106.2 (Bus B) bus voltage indications on Technical Specification required 125 VDC buses for 15 min. (Note 1)

CU4.1 CG1.2 Loss of RCS inventory Loss of RCS inventory affecting core decay heat removal capability Loss of RCS inventory affecting fuel clad integrity with containment challenged RCS Level Loss of Comm.

Loss of all onsite or offsite communications capabilities CU5.1 UNPLANNED loss of RCS inventory for 15 minutes or longer Loss of Vital DC power for 15 minutes or longer CA2.1 Loss of all offsite and all onsite AC power capability to 480V emergency buses E-1 and E-2 for 15 min. (Note 1)

Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer CS1.3 RCS Temp.

UNPLANNED increase in RCS temperature to > 200°F CU3.1 UNPLANNED increase in RCS temperature Loss of all RCS temperature and RCS level indication for 15 min. (Note 1)

CU3.2 CA3.1 UNPLANNED increase in RCS temperature to > 200°F for

> Table C-3 duration (Note 1)

OR UNPLANNED RCS pressure increase > 10 psig (this does not apply during water-solid plant conditions)

Inability to maintain plant in cold shutdown Hazardous Event Affecting Safety Systems C

1 3

5 6

2 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Loss of all Table C-4 onsite communication methods OR Loss of all Table C-4 offsite communication methods OR Loss of all Table C-4 NRC communication methods Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode CA6.1 EAL - COLD MODES 5, 6 & Defueled None None None None None None Loss of Vital DC Power 4

None None None 5

6 5

6 DEF 5

6 5

6 DEF 5

6 5

6 DEF 5

6 Table C-5 Hazardous Events Seismic event (earthquake)

Internal or external FLOODING event High winds or tornado strike FIRE EXPLOSION Other events with similar hazard characteristics as determined by the Shift Manager

Containment (CV) sump

PRT

RCDT

CCW surge tank Table C-1 Sumps / Tanks CS1.1 With CONTAINMENT CLOSURE not established, RCS level

< 64.5% RVLIS Full Range (Figure C-RVLIS)

CS1.2 With CONTAINMENT CLOSURE established, RCS level

< 59.8% RVLIS Full Range (Figure C-RVLIS)

CG1.1 RCS level < 59.8% RVLIS Full Range for 30 min. (Note 1)

(Figure C-RVLIS)

AND Any Containment Challenge indication, Table C-2

Containment Closure not established (Note 6)

Containment hydrogen concentration 4%

UNPLANNED rise in Containment pressure Table C-2 Containment Challenge Indications 60 min.*

20 min.*

If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable 0 min.

Table C-3 RCS Re-heat Duration Thresholds Not intact OR At REDUCED INVENTORY Intact (but not REDUCED INVENTORY)

RCS Status Containment Closure Status Heat-up Duration N/A established not established Inability to control a key safety function from outside the Control Room 5

6 1

2 3

4 Prepared for Duke Energy by: Operations Support Services, Inc. - www.ossi-net.com (7/5/16)

Modes:

1 Power Operations Defueled DEF 2

Startup 5

Cold Shutdown 3

Hot Standby 4

Hot Shutdown Robinson Nuclear Plant CSD-EP-RNP-0101-02 Rev 000 Irradiated Fuel Event RU1.1 Sample analysis for a gaseous or liquid release indicates a concentration or release rate > 2 x ODCM limits for 60 min.

(Notes 1, 2)

RU1.2 Reading on any Table R-1 effluent radiation monitor

> column UE for 60 min. (Notes 1, 2, 3)

RA1.1 Dose assessment using actual meteorology indicates doses

> 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY (Notes 3, 4)

RS1.1 Reading on any Table R-1 effluent radiation monitor > column SAE for 15 min. (Notes 1, 2, 3, 4)

RS1.2 Dose assessment using actual meteorology indicates doses

> 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the SITE BOUNDARY (Notes 3, 4)

RA1.2 Reading on any Table R-1 effluent radiation monitor

> column ALERT for 15 min. (Notes 1, 2, 3, 4)

RA1.3 Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2)

RU2.1 UNPLANNED water level drop in the REFUELING PATHWAY as indicated by low water level alarm or indication:

SFP level LI-11442A/LI-11443A SFP low level alarm (LA-651) APP-036-B6 Local SFP level indication Local Refueling Cavity level indication (Refueling mode)

AND UNPLANNED rise in corresponding area radiation levels as indicated by any of the following:

R-2 CV Area R-5 Spent Fuel Pit Area Local area survey RA2.2 Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by a high alarm on any of the following:

- R-2 CV Area

- R-5 Spent Fuel Pit Area

- R-11 CV Air Particulate

- R-12 CV Air Gas

- R-14 Plant Vent

- R-21 Fuel Handling Building Upper Level RA3.1 Dose rates > 15 mR/hr in EITHER of the following areas:

Control Room (R-1)

OR Central Alarm Station (by survey)

Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE Unplanned loss of water level above irradiated fuel Significant lowering of water level above, or damage to, irradiated fuel RA2.1 Uncovery of irradiated fuel in the REFUELING PATHWAY Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown RS1.3 Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 100 mR/hr expected to continue for 60 min.

OR Analyses of field survey samples indicate thyroid CDE

> 500 mrem for 60 min. of inhalation.

(Notes 1, 2)

Abnorm.

Rad Levels

/ Rad Effluent R

GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT 2

Rad Effluent 1

None None HS1.1 A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the Security Shift Supervision HU1.1 A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervision HU1.2 Notification of a credible security threat directed at the site HU1.3 A validated notification from the NRC providing information of an aircraft threat HA1.1 HU2.1 HU4.1 A FIRE is not extinguished within 15 min. of any of the following FIRE detection indications (Note 1):

- Report from the field (i.e., visual observation)

- Receipt of multiple (more than 1) fire alarms or indications

- Field verification of a single fire alarm AND The FIRE is located within any Table H-1 area HA5.1 Release of a toxic, corrosive, asphyxiant or flammable gas into any Table R-2/H-2 rooms or areas AND Entry into the room or area is prohibited or IMPEDED (Note 5)

Seismic event greater than OBE levels HU4.2 Receipt of a single fire alarm (i.e., no other indications of a FIRE)

AND The fire alarm is indicating a FIRE within any Table H-1 area AND The existence of a FIRE is not verified within 30 min. of alarm receipt (Note 1)

HU3.2 Internal room or area FLOODING of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode FIRE potentially degrading the level of safety of the plant Gaseous release IMPEDING access to equipment necessary for normal plant operations, cooldown or shutdown Confirmed SECURITY CONDITION or threat Hostile Action within the Owner Controlled Area or airborne attack threat within 30 minutes Hostile Action within the Protected Area HU7.1 Other conditions existing that in the judgment of the Emergency Coordinator warrant declaration of a UE Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress 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.

An event has resulted in plant control being transferred from the Control Room to the Dedicated/Alternate Shutdown System HA6.1 Control Room evacuation resulting in transfer of plant control to alternate locations HS6.1 An event has resulted in plant control being transferred from the Control Room to the Dedicated/Alternate Shutdown System AND Control of any of the following key safety functions is not reestablished within 15 min. (Note 1):

- Reactivity (Modes 1,2,3 only)

- Core Cooling

- RCS heat removal Other conditions exist which, in the judgment of the Emergency Coordinator, indicate that events are in progress 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.

HA7.1 Other conditions exist that in the judgment of the Emergency Coordinator warrant declaration of an Alert HS7.1 Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent 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.

Other conditions existing that in the judgment of the Emergency Coordinator warrant declaration of a Site Area Emergency HG7.1 Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress 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 Guideline exposure levels offsite for more than the immediate site area Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of a General Emergency None Hazards H

Seismic Event Fire Control Room Evacuation Hazardous Gases Security EC Judgment 2

4 5

1 6

7 None HU3.3 Movement of personnel within the PROTECTED AREA is IMPEDED due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release)

A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervision HA1.2 A validated notification from NRC of an aircraft attack threat within 30 min. of the site Area Rad Levels 3

RA1.4 Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 10 mR/hr expected to continue for 60 min.

OR Analyses of field survey samples indicate thyroid CDE

> 50 mrem for 60 min. of inhalation. (Notes 1, 2)

RG1.1 Reading on any Table R-1 effluent radiation monitor > column GE for 15 min. (Notes 1, 2, 3, 4)

RG1.2 Dose assessment using actual meteorology indicates doses

> 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond the SITE BOUNDARY (Notes 3, 4)

RG1.3 Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 1,000 mR/hr expected to continue for 60 min.

OR Analyses of field survey samples indicate thyroid CDE

> 5,000 mrem for 60 min. of inhalation.

(Notes 1, 2)

RA3.2 An UNPLANNED event results in radiation levels that prohibit or IMPEDE access to any Table R-2/H-2 rooms or areas (Note 5)

HU3.1 A tornado strike within the PROTECTED AREA Hazardous event HU3.4 A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7)

Natural or Tech.

Hazard 3

HU4.3 A FIRE within the plant PROTECTED AREA not extinguished within 60 min. of the initial report, alarm or indication (Note 1)

HU4.4 A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish None None None None None RA2.3 Lowering of spent fuel pool level to < 24 ft.

RS2.1 Lowering of spent fuel pool level to < 14.75 ft.

RG2.1 Spent fuel pool level at the top of the fuel racks Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer Spent fuel pool level cannot be restored to at least 14.75 ft.

for > 60 min. (Note 1) 5 6

1 2

3 4

DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 5

6 1

2 3

4 DEF 6

Refuel Seismic Recording Unit A or B indicates seismic event

> Operating Basis Earthquake (0.1g horizontal OR 0.067g vertical)

Containment

Auxiliary Building

Control Room

Fuel Handling Building

Intake

AFW Room

4 KV Switchgear Room

E-1/E-2 Switchgear Room

RWST

CST Table H-1 Fire Areas ISFSIE None None None Damage to a loaded cask CONFINEMENT BOUNDARY 5

6 1

2 3

4 DEF EU1.1 Damage to a loaded canister CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading on the surface of a loaded spent fuel cask > any Table E-1 dose limit None None None Reactor Vessel Flange Bottom of Hotleg 6 in. < Bottom of Hotleg Top of Active Fuel RVLIS Full Range Standpipe 0"

65.8%

64.5%

59.8%

Reactor Vessel Levels (Figure C-RVLIS) 69.0%

Min. RHR Operation EAL

-72" CA1.1 CS1.1 CS1.1/CG1.1 Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer VALID for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Note 5: If the equipment in the listed room or area was already inoperable or out-of-service before the event occurred, then no emergency classification is warranted.

Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.

Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

Note 8: A manual trip action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

Note 9: Mode 3 applicable only when RCS temperature is > 500°F Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then this emergency classification is not warranted.

Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

NOTES

[Refer to EAL CA6.1 OR SA9.1 for escalation due to seismic event]

[Refer to EAL CA6.1 OR SA9.1 for escalation due to natural or technological hazard]

[Refer to EAL CA6.1 OR SA9.1 for escalation due to FIRE]

6.38E+4 cpm 3.40E+2 cpm 2.60E+4 mR/hr 6.38E+3 cpm 4.30E+1 cpm 2.60E+3 mR/hr 2.16E+5 cpm 3.78E+5 cpm 4.08E+6 cpm 6.94E+5 cpm 4.23E+5 cpm R-14C R-14D R-14E R-20 R-30 R-18 R-19 A/B/C R-37 Gaseous Liquid Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent FHB Exhaust FHB Exhaust HR Liquid Waste Disposal SGBD Effluent Condensate Polisher 6.38E+5 cpm 3.31E+3 cpm None Table R-2/H-2 Safe Operation & Shutdown Rooms/Areas Room / Area Mode(s)

- Reactor Auxiliary Building, 1st level hallway

- Reactor Auxiliary Building, 2nd level hallway

- Charging Pump Room

- Component Cooling Water Pump Room

- Primary Sample Room

- Primary Demineralizer Room

- Spent Fuel Pump / Heat Exchanger Room

- Pipe Alley

- RHR Heat Exchanger Room

- RHR Pump Room entry area (access to RHR Pump CCW flow indication / control)

- Boric Acid Batch Tank Room

- Emergency Bus E1/E2 Room

- Turbine Building 1st Floor (includes Condensate Polisher, Makeup Water Treatment and Secondary Sample Room)

- Turbine Building 2nd Floor

- Turbine Building 3rd Floor

- Containment Building 1, 2, 3, 4, 5 1, 2, 3, 4, 5 1, 2, 3, 4, 5 1, 2, 3, 4, 5 1, 2, 3, 4, 5 1, 2, 3 1, 2, 3, 4, 5 4

4 4

1, 2, 3, 4, 5 3, 4, 5 1, 2, 3, 4 1, 2, 3, 4 1, 3, 4 3

Table E-1 ISFSI Dose Limits 24P ISFSI

2,600 mrem/hr on the HSM front surface

10 mrem/hr on the HSM-H door centerline

20 mrem/hr on the end shield wall exterior 7P ISFSI

400 mrem/hr outside of HSM door on centerline of DSC

400 mrem/hr at center of air inlets or outlets

100 mrem/hr on roof, front, back or side Table C-6 AC Power Sources Offsite

- 115KV SUT

- 230KV SUT

- UAT backfed via Main Transformer (only if already aligned)

Onsite

- EDG A

- EDG B Table C-4 Communication Methods Onsite Offsite System Public Address System PBX Telephone System Radio Transceivers for RNP and Vicinity Back-up Telephone System (ESSX)

Plant Security Radio Transceivers Corporate Telephone Communications System (Voicenet)

BellSouth Plant Security Radio Control Station DEMNET NRC Emergency Telecommunication System (ETS)

Satellite Phones Cellular Phones Palmetto 800 Transceivers X

X X

NRC X

X X

X Robinson Nuclear Plant CSD-EP-RNP-0101-02 Rev 000 RNP Date & Time of Shutdown Date Time Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.