RA-20-0050, Emergency Action Levels CSD-EP-RNP-0101-02, Revision 0

From kanterella
Jump to navigation Jump to search
Emergency Action Levels CSD-EP-RNP-0101-02, Revision 0
ML20044C811
Person / Time
Site: Robinson Duke energy icon.png
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


Text

M. CHRISTOPHER NOLAN

£DUKE Vice President ENERGY Nuclear Regulatory Affairs, Policy &

Emergency Preparedness 526 South Church Street, EC-07C Charlotte, NC 28202 980-382-7426 Chris.Nolan@duke-energy.com Serial: RA-20-0050 10 CFR 50.54(q)

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:

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 BNP EREG #: 2305303 CNS CR3 HNP MNS 5AD #: 2305232 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.

  1. E-Plan or Current (Existing) Text Proposed (Change) Text Procedure Section Reference 1 EALs New Reference (Figure C-RVLIS) added to refer to a CS1.1, figure in the wallchart, previously not CS1.1, referenced CS1.2, CG1.1 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 10 CFR 50.54(q) Continue to Alert and Notification System Design Report? Effectiveness Attachment 4, Evaluation is not 10 CFR If yes, identify bounding source document number or approval reference and required. Enter 50.54(q) ensure the basis for concluding the source document fully bounds the proposed justification Screening change is documented below: below and Evaluation complete Form, Part III Attachment 4, Justification: Part V.

Bounding document attached (optional)

Part III. Editorial Change No or Yes Is this activity an editorial or typographical change only, such as formatting, Partially paragraph numbering, spelling, or punctuation that does not change intent? 10 CFR 50.54(q) Continue to Effectiveness Attachment 4, Evaluation is not Part IV and Justification:

required. Enter address non justification and editorial complete changes Attachment 4, Part V.

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

GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Release of gaseous radioactivity resulting in offsite dose greater Release of gaseous radioactivity resulting in offsite dose greater Release of gaseous or liquid radioactivity resulting in offsite dose Release of gaseous or liquid radioactivity greater than 2 times the than 1,000 mrem TEDE or 5,000 mrem thyroid CDE than 100 mrem TEDE or 500 mrem thyroid CDE greater than 10 mrem TEDE or 50 mrem thyroid CDE ODCM limits for 60 minutes or longer Loss of RCS inventory affecting fuel clad integrity with containment Loss of RCS inventory affecting core decay heat removal Loss of RCS inventory UNPLANNED loss of RCS inventory for 15 minutes or longer challenged capability 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 5 6 5 6 5 6 5 6 RG1.1 RS1.1 RA1.1 RU1.1 CG1.1 CS1.1 CA1.1 CU1.1 Reading on any Table R-1 effluent radiation monitor > column Reading on any Table R-1 effluent radiation monitor > column Reading on any Table R-1 effluent radiation monitor Reading on any Table R-1 effluent radiation monitor GE for 15 min. (Notes 1, 2, 3, 4) SAE for 15 min. (Notes 1, 2, 3, 4) > column ALERT for 15 min. (Notes 1, 2, 3, 4) > column UE for 60 min. (Notes 1, 2, 3) RCS level < 59.8% RVLIS Full Range for 30 min. (Note 1) With CONTAINMENT CLOSURE not established, RCS level Loss of RCS inventory as indicated by RCS water level UNPLANNED loss of reactor coolant results in RCS water (Figure C-RVLIS) < 64.5% RVLIS Full Range (Figure C-RVLIS) < -72 in. (69% RVLIS Full Range) (Figure C-RVLIS) level less than a required lower limit for 15 min. (Note 1)

RG1.2 RS1.2 RA1.2 RU1.2 AND 1

Dose assessment using actual meteorology indicates doses Dose assessment using actual meteorology indicates doses Dose assessment using actual meteorology indicates doses Sample analysis for a gaseous or liquid release indicates a CS1.2 CA1.2 CU1.2 Any Containment Challenge indication, Table C-2

> 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or > 100 mrem TEDE or 500 mrem thyroid CDE at or beyond > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the concentration or release rate > 2 x ODCM limits for 60 min. With CONTAINMENT CLOSURE established, RCS level RCS water level cannot be monitored for 15 min. (Note 1) RCS water level cannot be monitored beyond the SITE BOUNDARY (Notes 3, 4) the SITE BOUNDARY (Notes 3, 4) SITE BOUNDARY (Notes 3, 4) 1 (Notes 1, 2) < 59.8% RVLIS Full Range (Figure C-RVLIS)

CG1.2 AND EITHER AND EITHER RG1.3 RS1.3 RA1.3 RCS RCS water level cannot be monitored for 30 min. (Note 1) CS1.3 UNPLANNED increase in any Table C-1 sump or tank UNPLANNED increase in any Table C-1 sump or Field survey results indicate EITHER of the following at or Field survey results indicate EITHER of the following at or Analysis of a liquid effluent sample indicates a concentration Level due to a loss of RCS inventory tank due to a loss of RCS inventory beyond the SITE BOUNDARY: beyond the SITE BOUNDARY: or release rate that would result in doses > 10 mrem TEDE or AND RCS water level cannot be monitored for 30 min. (Note 1)

Rad OR OR Closed window dose rates > 1,000 mR/hr expected to Closed window dose rates > 100 mR/hr expected to 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for Core uncovery is indicated by any of the following: AND Effluent Visual observation of UNISOLABLE RCS leakage Visual observation of UNISOLABLE RCS leakage 60 min. of exposure (Notes 1, 2) - UNPLANNED increase in any Table C-1 sump or tank of Core uncovery is indicated by any of the following:

continue for 60 min. continue for 60 min.

sufficient magnitude to indicate core uncovery - UNPLANNED increase in any Table C-1 sump or tank of OR OR RA1.4 - Containment High Range Radiation Monitor R-32A or R- sufficient magnitude to indicate core uncovery Analyses of field survey samples indicate thyroid CDE Analyses of field survey samples indicate thyroid CDE Field survey results indicate EITHER of the following at or 32B > 5 R/hr - Containment High Range Radiation Monitor R-32A or

> 5,000 mrem for 60 min. of inhalation. > 500 mrem for 60 min. of inhalation.

beyond the SITE BOUNDARY: - Erratic source range monitor indication R-32B > 5 R/hr (Notes 1, 2) (Notes 1, 2)

Closed window dose rates > 10 mR/hr expected to AND - Erratic source range monitor indication continue for 60 min. Any Containment Challenge indication, Table C-2 OR R

Analyses of field survey samples indicate thyroid CDE Loss of all but one AC power source to emergency buses for 15 Loss of all offsite and all onsite AC power to emergency buses for 15

> 50 mrem for 60 min. of inhalation. (Notes 1, 2) minutes or longer minutes or longer Table C-1 Sumps / Tanks Table C-6 AC Power Sources Spent fuel pool level cannot be restored to at least the top of the Spent fuel pool level at the top of the fuel racks Significant lowering of water level above, or damage to, irradiated Unplanned loss of water level above irradiated fuel 5 6 DEF 5 6 DEF Abnorm.

fuel racks for 60 minutes or longer 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF fuel 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 2

  • Containment (CV) sump
  • PRT Offsite CA2.1 Loss of all offsite and all onsite AC power capability to 480V CU2.1 AC power capability, Table C-6, to 480V emergency buses Rad RG2.1 RS2.1 RA2.1 RU2.1 - 115KV SUT E-1 and E-2 reduced to a single power source for 15 min.

Loss of emergency buses E-1 and E-2 for 15 min. (Note 1)

Levels Spent fuel pool level cannot be restored to at least 14.75 ft. Lowering of spent fuel pool level to < 14.75 ft. Uncovery of irradiated fuel in the REFUELING PATHWAY UNPLANNED water level drop in the REFUELING PATHWAY

Emergency - 230KV SUT

/ Rad for > 60 min. (Note 1) as indicated by low water level alarm or indication: AND 2

RA2.2 - SFP level LI-11442A/LI-11443A AC

  • CCW surge tank Effluent Power - UAT backfed via Main Transformer Any additional single power source failure will result in loss of Damage to irradiated fuel resulting in a release of radioactivity - SFP low level alarm (LA-651) APP-036-B6 all AC power to SAFETY SYSTEMS from the fuel as indicated by a high alarm on any of the - Local SFP level indication (only if already aligned)

Table R-1 Effluent Monitor Classification Thresholds following: - Local Refueling Cavity level indication (Refueling mode)

Irradiated Onsite Inability to maintain plant in cold shutdown UNPLANNED increase in RCS temperature

- R-2 CV Area C

Fuel Event Release Point Monitor GE SAE Alert UE AND

- R-5 Spent Fuel Pit Area UNPLANNED rise in corresponding area radiation levels as Table C-2 Containment Challenge Indications - EDG A 5 6 5 6 R-14C ---- ---- ---- 2.16E+5 cpm - R-11 CV Air Particulate indicated by any of the following:

- R-12 CV Air Gas - R-2 CV Area - EDG B CA3.1 CU3.1 3

Plant Vent R-14D 6.38E+5 cpm 6.38E+4 cpm 6.38E+3 cpm ---- - R-14 Plant Vent

  • Containment Closure not established (Note 6)

- R-5 Spent Fuel Pit Area UNPLANNED increase in RCS temperature to > 200°F for UNPLANNED increase in RCS temperature to > 200°F Gaseous

- R-21 Fuel Handling Building Upper Level - Local area survey R-14E 3.31E+3 cpm 3.40E+2 cpm 4.30E+1 cpm ----

  • Containment hydrogen concentration 4% > Table C-3 duration (Note 1)

RA2.3 Cold SD/ None OR Lowering of spent fuel pool level to < 24 ft.

Refuel RCS

  • UNPLANNED rise in Containment pressure Table C-3 RCS Re-heat Duration Thresholds UNPLANNED RCS pressure increase > 10 psig (this does not CU3.2 FHB Exhaust R-20 ---- ---- ---- 3.78E+5 cpm System Temp. apply during water-solid plant conditions) Loss of all RCS temperature and RCS level indication FHB Exhaust HR R-30 ---- 2.60E+4 mR/hr 2.60E+3 mR/hr ---- Radiation levels that IMPEDE access to equipment necessary for Malfunct. RCS Status Containment Heat-up for 15 min. (Note 1) normal plant operations, cooldown or shutdown Closure Status Duration 1 2 3 4 5 6 DEF Liquid Waste Disposal R-18 ---- ---- ---- 4.08E+6 cpm Intact (but not REDUCED N/A 60 min.*

3 INVENTORY)

Liquid RA3.1 .

SGBD Effluent R-19 A/B/C ---- ---- ---- 6.94E+5 cpm Dose rates > 15 mR/hr in EITHER of the following areas:

4 Not intact 20 min.* Loss of Vital DC power for 15 minutes or longer established Condensate Polisher Control Room (R-1) OR R-37 ---- ---- ---- 4.23E+5 cpm None 5 6 OR At REDUCED INVENTORY Area Rad not established 0 min. CU4.1 Central Alarm Station (by survey) None None Levels None Loss of < 109.5 VDC (Bus A) / < 106.2 (Bus B) bus voltage indications RA3.2 Vital DC

  • If an RCS heat removal system is in operation within this time frame and None None RCS temperature is being reduced, the EAL is not applicable on Technical Specification required 125 VDC buses for An UNPLANNED event results in radiation levels that prohibit Power 15 min. (Note 1) or IMPEDE access to any Table R-2/H-2 rooms or areas (Note 5) Loss of all onsite or offsite communications capabilities Hostile Action within the Protected Area Hostile Action within the Owner Controlled Area or airborne attack Confirmed SECURITY CONDITION or threat 5 6 DEF 5

threat within 30 minutes CU5.1 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF None None None Loss of all Table C-4 onsite communication methods HS1.1 HA1.1 HU1.1 OR A HOSTILE ACTION is occurring or has occurred within the A HOSTILE ACTION is occurring or has occurred within the A SECURITY CONDITION that does not involve a HOSTILE Loss of Loss of all Table C-4 offsite communication methods 1

PROTECTED AREA as reported by the Security Shift OWNER CONTROLLED AREA as reported by the Security ACTION as reported by the Security Shift Supervision Comm. OR Supervision Shift Supervision Loss of all Table C-4 NRC communication methods HU1.2 HA1.2 Notification of a credible security threat directed at the site Table C-5 Hazardous Events Security None Hazardous event affecting a SAFETY SYSTEM needed for the A validated notification from NRC of an aircraft attack threat current operating mode within 30 min. of the site HU1.3 6

- Seismic event (earthquake) 5 6 A validated notification from the NRC providing information Table R-2/H-2 Safe Operation & Shutdown Rooms/Areas of an aircraft threat - Internal or external FLOODING event CA6.1 Room / Area Mode(s) - High winds or tornado strike The occurrence of any Table C-5 hazardous event Hazardous AND

- Reactor Auxiliary Building, 1st level hallway 1, 2, 3, 4, 5 Event None - FIRE None

- Event damage has caused indications of degraded None Seismic event greater than OBE levels Affecting 2

- Reactor Auxiliary Building, 2nd level hallway 1, 2, 3, 4, 5 - EXPLOSION performance on one train of a SAFETY SYSTEM 1 2 3 4 5 6 DEF Safety needed for the current operating mode

- Charging Pump Room 1, 2, 3, 4, 5 HU2.1 Systems - Other events with similar hazard AND EITHER of the following:

- Component Cooling Water Pump Room None 1, 2, 3, 4, 5 None None characteristics as determined by the Seismic Recording Unit A or B indicates seismic event - Event damage has caused indications of degraded Seismic - Primary Sample Room 1, 2, 3, 4, 5 Shift Manager

> Operating Basis Earthquake performance to a second train of the SAFETY Event - Primary Demineralizer Room 1, 2, 3 [Refer to EAL CA6.1 OR SA9.1 for escalation due to seismic SYSTEM needed for the current operating mode.

event] (0.1g horizontal OR 0.067g vertical)

- Spent Fuel Pump / Heat Exchanger Room 1, 2, 3, 4, 5 - Event damage has resulted in VISIBLE DAMAGE to

- Pipe Alley 4 Hazardous event the second train of the SAFETY SYSTEM needed for

- RHR Heat Exchanger Room 4 the current operating mode 1 2 3 4 5 6 DEF (Note 10, 11)

- RHR Pump Room entry area (access to RHR Pump CCW 4 HU3.1 flow indication / control) A tornado strike within the PROTECTED AREA

- Boric Acid Batch Tank Room 1, 2, 3, 4, 5 HU3.2 3

- Emergency Bus E1/E2 Room 3, 4, 5 Internal room or area FLOODING of a magnitude sufficient Reactor Vessel Levels (Figure C-RVLIS) Table C-4 Communication Methods

- Turbine Building 1st Floor (includes Condensate Polisher, 1, 2, 3, 4 to require manual or automatic electrical isolation of a Makeup Water Treatment and Secondary Sample Room) SAFETY SYSTEM component needed for the current RVLIS Full Standpipe EAL System Onsite Offsite NRC Natural or - Turbine Building 2nd Floor 1, 2, 3, 4 operating mode None Range Tech. - Turbine Building 3rd Floor 1, 3, 4 Public Address System X HU3.3 Hazard - Containment Building 3 [Refer to EAL CA6.1 OR SA9.1 for escalation due to natural Movement of personnel within the PROTECTED AREA is Reactor Vessel Flange 0" PBX Telephone System X or technological hazard] IMPEDED due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release) Radio Transceivers for RNP and Vicinity X Min. RHR Operation 69.0% -72" CA1.1 HU3.4 Back-up Telephone System (ESSX) X A hazardous event that results in on-site conditions sufficient Bottom of Hotleg 65.8% Plant Security Radio Transceivers X to prohibit the plant staff from accessing the site via personal 6 in. < Bottom of Hotleg 64.5% CS1.1 NOTES vehicles (Note 7) Corporate Telephone Communications X X Table H-1 Fire Areas System (Voicenet)

Top of Active Fuel 59.8% CS1.1/CG1.1 FIRE potentially degrading the level of safety of the plant Note 1: The Emergency Coordinator should declare the event promptly upon BellSouth X X determining that time limit has been exceeded, or will likely be exceeded.

  • Containment 1 2 3 4 5 6 DEF Plant Security Radio Control Station X Note 2: If an ongoing release is detected and the release start time is unknown,
  • Auxiliary Building assume that the release duration has exceeded the specified time limit. HU4.1 DEMNET X
  • Control Room A FIRE is not extinguished within 15 min. of any of the Note 3: If the effluent flow past an effluent monitor is known to have stopped, NRC Emergency Telecommunication indicating that the release path is isolated, the effluent monitor reading is no longer
  • Fuel Handling Building following FIRE detection indications (Note 1): System (ETS) X VALID for classification purposes. - Report from the field (i.e., visual observation)
  • Intake - Receipt of multiple (more than 1) fire alarms or indications Satellite Phones X X Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 - Field verification of a single fire alarm and RG1.1 should be used for emergency classification assessments until the
  • AFW Room Cellular Phones X X AND H

results from a dose assessment using actual meteorology are available.

  • 4 KV Switchgear Room The FIRE is located within any Table H-1 area Palmetto 800 Transceivers X 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.
  • E-1/E-2 Switchgear Room HU4.2 4

Receipt of a single fire alarm (i.e., no other indications of a Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-

  • RWST FIRE) minute time limit, declaration of a General Emergency is not required.

Hazards

  • CST AND Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, The fire alarm is indicating a FIRE within any Table H-1 area NOTES Fire ice, or vehicle breakdowns or accidents. AND The existence of a FIRE is not verified within 30 min. of Note 8: A manual trip action is any operator action, or set of actions, which causes Note 1: The Emergency Coordinator should declare the event promptly upon alarm receipt (Note 1) determining that time limit has been exceeded, or will likely be exceeded.

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.

HU4.3 Note 2: If an ongoing release is detected and the release start time is unknown, Note 9: Mode 3 applicable only when RCS temperature is > 500°F None A FIRE within the plant PROTECTED AREA not extinguished assume that the release duration has exceeded the specified time limit.

within 60 min. of the initial report, alarm or indication (Note 1) Date & Time of Shutdown Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of Note 3: If the effluent flow past an effluent monitor is known to have stopped, service before the hazardous event occurred, then this emergency classification is indicating that the release path is isolated, the effluent monitor reading is no longer HU4.4 VALID for classification purposes.

not warranted.

[Refer to EAL CA6.1 OR SA9.1 for escalation due to FIRE] A FIRE within the plant PROTECTED AREA that requires Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no firefighting support by an offsite fire response agency to Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 Date Time and RG1.1 should be used for emergency classification assessments until the indications of degraded performance to at least one train of a SAFETY SYSTEM, extinguish results from a dose assessment using actual meteorology are available.

then this emergency classification is not warranted.

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

normal plant operations, cooldown or shutdown 5

Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-1 2 3 4 5 6 DEF minute time limit, declaration of a General Emergency is not required.

HA5.1 None None Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, None Hazardous Release of a toxic, corrosive, asphyxiant or flammable gas ice, or vehicle breakdowns or accidents.

into any Table R-2/H-2 rooms or areas Gases Note 8: A manual trip action is any operator action, or set of actions, which causes AND the control rods to be rapidly inserted into the core, and does not include manually Entry into the room or area is prohibited or IMPEDED (Note 5) driving in control rods or implementation of boron injection strategies.

Inability to control a key safety function from outside the Control Control Room evacuation resulting in transfer of plant control to Note 9: Mode 3 applicable only when RCS temperature is > 500°F RNP Room alternate locations RNP 1 2 3 4 5 6 1 2 3 4 5 6 DEF 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 HS6.1 HA6.1 6

not warranted.

An event has resulted in plant control being transferred from An event has resulted in plant control being transferred from the Control Room to the Dedicated/Alternate Shutdown Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no the Control Room to the Dedicated/Alternate Shutdown indications of degraded performance to at least one train of a SAFETY SYSTEM, None System System None then this emergency classification is not warranted.

Control AND Room Control of any of the following key safety functions is not Evacuation 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 Other conditions existing that in the judgment of the Emergency Other conditions exist that in the judgment of the Emergency Other conditions existing that in the judgment of the Emergency Coordinator warrant declaration of a General Emergency Coordinator warrant declaration of a Site Area Emergency Coordinator warrant declaration of an Alert Coordinator warrant declaration of a UE 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF HG7.1 HS7.1 HA7.1 HU7.1 Other conditions exist which in the judgment of the Other conditions exist which in the judgment of the Other conditions exist which, in the judgment of the Other conditions exist which in the judgment of the 7 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 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 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 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 EC of containment integrity or HOSTILE ACTION that results in HOSTILE ACTION that results in intentional damage or security event that involves probable life threatening risk to facility protection has been initiated. No releases of Judgment an actual loss of physical control of the facility. Releases can malicious acts, (1) toward site personnel or equipment that site personnel or damage to site equipment because of radioactive material requiring offsite response or monitoring be reasonably expected to exceed EPA Protective Action could lead to the likely failure of or, (2) that prevent effective HOSTILE ACTION. Any releases are expected to be limited are expected unless further degradation of SAFETY Guideline exposure levels offsite for more than the access to equipment needed for the protection of the public. to small fractions of the EPA Protective Action Guideline SYSTEMS occurs.

immediate site area Any releases are not expected to result in exposure levels exposure levels.

which exceed EPA Protective Action Guideline exposure levels beyond the SITE BOUNDARY.

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

Damage to a loaded cask CONFINEMENT BOUNDARY Table E-1 ISFSI Dose Limits 1 2 3 4 5 6 DEF E

7P ISFSI 24P ISFSI EU1.1

  • 400 mrem/hr outside of HSM door on
  • 2,600 mrem/hr onNone the HSM front surface Damage to a loaded canister CONFINEMENT BOUNDARY None None as indicated by an on-contact radiation reading on the centerline of DSC
  • 10 mrem/hr on the HSM-H door centerline surface of a loaded spent fuel cask > any Table E-1 dose ISFSI
  • 400 mrem/hr at center of air inlets or outlets limit
  • 20 mrem/hr on the end shield wall exterior
  • 100 mrem/hr on roof, front, back or side EAL - COLD MODES 5, 6 & Defueled Robinson Nuclear Plant Robinson Nuclear Plant Modes: 1 Power Operations Startup 2 3 Hot Standby 4

Hot Shutdown 5

Cold Shutdown 6

Refuel DEF Defueled CSD-EP-RNP-0101-02 Rev 000 CSD-EP-RNP-0101-02 Rev 000

GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Release of gaseous radioactivity resulting in offsite dose greater Release of gaseous radioactivity resulting in offsite dose greater Release of gaseous or liquid radioactivity resulting in offsite dose Release of gaseous or liquid radioactivity greater than 2 times the than 1,000 mrem TEDE or 5,000 mrem thyroid CDE than 100 mrem TEDE or 500 mrem thyroid CDE greater than 10 mrem TEDE or 50 mrem thyroid CDE ODCM limits for 60 minutes or longer Prolonged loss of all offsite and all onsite AC power to Loss of all offsite and all onsite AC power to emergency buses Loss of all but one AC power source to emergency buses Loss of all offsite AC power capability to emergency buses emergency buses for 15 minutes or longer for 15 minutes or longer for 15 minutes or longer 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF RG1.1 RS1.1 RA1.1 RU1.1 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 Reading on any Table R-1 effluent radiation monitor > column Reading on any Table R-1 effluent radiation monitor > column Reading on any Table R-1 effluent radiation monitor Reading on any Table R-1 effluent radiation monitor SG1.1 SS1.1 SA1.1 SU1.1 GE for 15 min. (Notes 1, 2, 3, 4) SAE for 15 min. (Notes 1, 2, 3, 4) > column ALERT for 15 min. (Notes 1, 2, 3, 4) > column UE for 60 min. (Notes 1, 2, 3) Loss of all offsite and all onsite AC power capability to 480V Loss of all offsite and all onsite AC power capability to 480V AC power capability, Table S-5, to 480V emergency buses Loss of all offsite AC power capability, Table S-5, to 480V RG1.2 RS1.2 RA1.2 RU1.2 emergency buses E-1 and E-2 emergency buses E-1 and E-2 for 15 min. (Note 1) E-1 and E-2 reduced to a single power source for 15 min. emergency buses E-1 and E-2 for 15 min. (Note 1)

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)

Dose assessment using actual meteorology indicates doses

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

Dose assessment using actual meteorology indicates doses

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

Sample analysis for a gaseous or liquid release indicates a concentration or release rate > 2 x ODCM limits for 60 min. 1 AND EITHER:

Restoration of at least one emergency bus in < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is not likely (Note 1)

(Note 1)

AND Any additional single power source failure will result in loss of Table S-5 AC Power Sources 1

(Notes 1, 2)

RG1.3 RS1.3 RA1.3 Loss of OR all AC power to SAFETY SYSTEMS Emergency Core Cooling RED Path entry conditions met Offsite Field survey results indicate EITHER of the following at or Field survey results indicate EITHER of the following at or Analysis of a liquid effluent sample indicates a concentration AC Power beyond the SITE BOUNDARY: beyond the SITE BOUNDARY: or release rate that would result in doses > 10 mrem TEDE or - 115KV SUT Rad Loss of all AC and vital DC power sources for 15 minutes or longer 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for - 230KV SUT Effluent Closed window dose rates > 1,000 mR/hr expected to Closed window dose rates > 100 mR/hr expected to 60 min. of exposure (Notes 1, 2) continue for 60 min. continue for 60 min. 1 2 3 4 - UAT backfed via Main Transformer RA1.4 Field survey results indicate EITHER of the following at or SG1.2 (only if already aligned)

OR OR beyond the SITE BOUNDARY: Loss of all offsite and all onsite AC power capability to 480V Onsite Closed window dose rates > 10 mR/hr expected to emergency buses E-1 and E-2 for 15 min.

Analyses of field survey samples indicate thyroid CDE Analyses of field survey samples indicate thyroid CDE - UAT via Main Generator

> 5,000 mrem for 60 min. of inhalation. > 500 mrem for 60 min. of inhalation. continue for 60 min. AND 2

(Notes 1, 2) (Notes 1, 2) OR Loss of all vital DC power based on < 109.5 VDC Bus A and Loss of all vital DC power for 15 minutes or longer - EDG A R

Analyses of field survey samples indicate thyroid CDE < 106.2 VDC Bus B voltage indications for 15 min. 1 2 3 4 - EDG B

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

SS2.1 None None Spent fuel pool level cannot be restored to at least the top of the Spent fuel pool level at the top of the fuel racks Significant lowering of water level above, or damage to, irradiated Unplanned loss of water level above irradiated fuel Loss of fuel racks for 60 minutes or longer fuel Vital DC Loss of all vital DC power based on < 109.5 VDC Bus A and Power < 106.2 VDC Bus B voltage indications for 15 min. (Note 1)

Abnorm. 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF Rad RG2.1 RS2.1 RA2.1 RU2.1 UNPLANNED loss of Control Room indications for 15 minutes or UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress longer Levels Spent fuel pool level cannot be restored to at least 14.75 ft. Lowering of spent fuel pool level to < 14.75 ft. Uncovery of irradiated fuel in the REFUELING PATHWAY UNPLANNED water level drop in the REFUELING Table S-2 Significant Transients 3

for > 60 min. (Note 1) PATHWAY as indicated by low water level alarm or 2

/ Rad RA2.2 1 2 3 4 1 2 3 4 indication:

Effluent Damage to irradiated fuel resulting in a release of radioactivity - SFP level LI-11442A/LI-11443A

- Reactor trip SA3.1 SU3.1 Table R-1 Effluent Monitor Classification Thresholds from the fuel as indicated by a high alarm on any of the - SFP low level alarm (LA-651) APP-036-B6 - Runback > 25% thermal power An UNPLANNED event results in the inability to monitor one An UNPLANNED event results in the inability to monitor one Irradiated following: - Local SFP level indication Loss of CR or more Table S-1 parameters from within the Control Room or more Table S-1 parameters from within the Control Room

- R-2 CV Area Indications - Electrical load rejection > 25% electrical load Fuel Event Release Point Monitor GE SAE Alert UE - Local Refueling Cavity level indication (Refueling mode) None for 15 min. (Note 1) for 15 min. (Note 1)

- R-5 Spent Fuel Pit Area AND - Safety injection actuation AND R-14C ---- ---- ---- 2.16E+5 cpm - R-11 CV Air Particulate UNPLANNED rise in corresponding area radiation levels as Any significant transient is in progress, Table S-2

- R-12 CV Air Gas indicated by any of the following:

Plant Vent R-14D 6.38E+5 cpm 6.38E+4 cpm 6.38E+3 cpm ----

- R-14 Plant Vent - R-2 CV Area RCS activity greater than Technical Specification allowable limits Gaseous R-14E 3.31E+3 cpm 3.40E+2 cpm 4.30E+1 cpm ---- - R-21 Fuel Handling Building Upper Level - R-5 Spent Fuel Pit Area 4

- Local area survey Table S-1 Safety System Parameters 1 2 3 RA2.3 FHB Exhaust R-20 ---- ---- ---- 3.78E+5 cpm Lowering of spent fuel pool level to < 24 ft. SU4.1 None None - Reactor power Dose Equivalent I-131 coolant activity >60 µCi/gm FHB Exhaust HR R-30 ---- 2.60E+4 mR/hr 2.60E+3 mR/hr ---- Radiation levels that IMPEDE access to equipment necessary for RCS (or >0.25 µCi/gm for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) (Note 9)

- RCS level None normal plant operations, cooldown or shutdown Activity SU4.2 Liquid Waste Disposal R-18 ---- ---- ---- 4.08E+6 cpm 1 2 3 4 5 6 DEF - RCS pressure With letdown in service, letdown line area radiation monitor 3

R-9 > 500 mR/hr (Note 9)

Liquid RA3.1 - Core exit T/C temperature SGBD Effluent R-19 A/B/C ---- ---- ---- 6.94E+5 cpm Dose rates > 15 mR/hr in EITHER of the following areas: - Level in at least one SG RCS leakage for 15 minutes or longer Condensate Polisher R-37 ---- ---- ---- 4.23E+5 cpm Control Room (R-1) 1 2 3 4 OR None - Auxiliary feed flow in at least one SG Area Rad Central Alarm Station (by survey) SU5.1 Levels None None RA3.2 An UNPLANNED event results in radiation levels that prohibit or IMPEDE access to any Table R-2/H-2 rooms or areas S 5 None None None RCS unidentified or pressure boundary leakage

> 10 gpm for 15 min.

OR (Note 5) RCS RCS identified leakage > 25 gpm for 15 min.

System Leakage OR Hostile Action within the Protected Area Hostile Action within the Owner Controlled Area or airborne attack Confirmed SECURITY CONDITION or threat Malfunct. Leakage from the RCS to a location outside containment threat within 30 minutes

> 25 gpm for 15 min.

1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF (Note 1)

HS1.1 HA1.1 HU1.1 A HOSTILE ACTION is occurring or has occurred within the A HOSTILE ACTION is occurring or has occurred within the A SECURITY CONDITION that does not involve a HOSTILE Inability to shut down the reactor causing a challenge to core cooling Automatic or manual trip fails to shut down the reactor and Automatic or manual trip fails to shut down the reactor 1

or RCS heat removal subsequent manual actions taken at the reactor control consoles are PROTECTED AREA as reported by the Security Shift OWNER CONTROLLED AREA as reported by the Security ACTION as reported by the Security Shift Supervision not successful in shutting down the reactor Supervision Shift Supervision 1 2 1 2 1 2 HU1.2 HA1.2 Notification of a credible security threat directed at the site SS6.1 SA6.1 SU6.1 Security None A validated notification from NRC of an aircraft attack threat An automatic or manual trip fails to shut down the reactor as An automatic or manual trip fails to shut down the reactor as An automatic trip did not shut down the reactor as within 30 min. of the site HU1.3 indicated by reactor power 5% indicated by reactor power 5% indicated by reactor power 5% after any RPS setpoint Table R-2/H-2 Safe Operation & Shutdown Rooms/Areas A validated notification from the NRC providing information AND AND is exceeded of an aircraft threat All actions to shut down the reactor are not successful as Manual trip actions taken at the RTGB are not successful in AND Room / Area Reactor Auxiliary Building, 1st level hallway Mode(s) 1, 2, 3, 4, 5 6 None indicated by reactor power 5%

AND EITHER:

Core Cooling RED Path entry conditions met shutting down the reactor as indicated by reactor power 5%

(Note 8)

A subsequent automatic trip or manual trip action taken at the RTGB is successful in shutting down the reactor as indicated by reactor power < 5% (Note 8)

- Reactor Auxiliary Building, 2nd level hallway 1, 2, 3, 4, 5 Seismic event greater than OBE levels RPS OR 2 -

Charging Pump Room Component Cooling Water Pump Room Primary SampleNone Room 1, 2, 3, 4, 5 1, 2, 3, 4, 5 1, 2, 3, 4, 5 None None HU2.1 1 2 3 4 5 6 DEF Failure Heat Sink RED Path entry conditions met SU6.2 A manual trip did not shut down the reactor as indicated by reactor power 5% after any manual trip action was initiated Seismic Seismic Recording Unit A or B indicates seismic event AND

- Primary Demineralizer Room 1, 2, 3 > Operating Basis Earthquake NOTES Table S-3 Communication Methods A subsequent automatic trip or manual trip action taken at the Event

- Spent Fuel Pump / Heat Exchanger Room 1, 2, 3, 4, 5 [Refer to EAL CA6.1 OR SA9.1 for escalation due to (0.1g horizontal OR 0.067g vertical) RTGB is successful in shutting down the reactor as indicated

- Pipe Alley 4 seismic event] Note 1: The Emergency Coordinator should declare the event promptly upon System Onsite Offsite NRC by reactor power < 5% (Note 8)

Hazardous event determining that time limit has been exceeded, or will likely be exceeded.

- RHR Heat Exchanger Room 4 Public Address System X

- RHR Pump Room entry area (access to RHR Pump CCW 4 1 2 3 4 5 6 DEF Note 2: If an ongoing release is detected and the release start time is unknown, flow indication / control) HU3.1 assume that the release duration has exceeded the specified time limit. PBX Telephone System X

- Boric Acid Batch Tank Room 1, 2, 3, 4, 5 A tornado strike within the PROTECTED AREA Note 3: If the effluent flow past an effluent monitor is known to have stopped, Radio Transceivers for RNP and Vicinity X Loss of all onsite or offsite communications capabilities

- Emergency Bus E1/E2 Room 3, 4, 5 indicating that the release path is isolated, the effluent monitor reading is no longer HU3.2 Back-up Telephone System (ESSX) X 3

VALID for classification purposes.

- Turbine Building 1st Floor (includes Condensate Polisher, 1, 2, 3, 4 Internal room or area FLOODING of a magnitude sufficient 1 2 3 4 7

Makeup Water Treatment and Secondary Sample Room) to require manual or automatic electrical isolation of a Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 Plant Security Radio Transceivers X SU7.1 and RG1.1 should be used for emergency classification assessments until the

- Turbine Building 2nd Floor 1, 2, 3, 4 SAFETY SYSTEM component needed for the current None results from a dose assessment using actual meteorology are available. None Corporate Telephone Communications X X Loss of all Table S-3 onsite communication methods Natural or - Turbine BuildingNone 3rd Floor 1, 3, 4 operating mode Loss of System (Voicenet) OR Tech.

None None Comm. Note 5: If the equipment in the listed room or area was already inoperable or out-of- Loss of all Table S-3 offsite communication methods

- Containment Building 3 HU3.3 service before the event occurred, then no emergency classification is warranted. BellSouth X X Hazard [Refer to EAL CA6.1 OR SA9.1 for escalation due to OR Movement of personnel within the PROTECTED AREA is Plant Security Radio Control Station X Loss of all Table S-3 NRC communication methods natural or technological hazard] IMPEDED due to an offsite event involving hazardous Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-materials (e.g., an offsite chemical spill or toxic gas release) minute time limit, declaration of a General Emergency is not required. DEMNET X Failure to isolate containment or loss of containment pressure control HU3.4 Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, NRC Emergency Telecommunication A hazardous event that results in on-site conditions sufficient ice, or vehicle breakdowns or accidents. System (ETS) X 1 2 3 4 NOTES to prohibit the plant staff from accessing the site via personal 8

Note 8: A manual trip action is any operator action, or set of actions, which causes Satellite Phones X X SU8.1 vehicles (Note 7) the control rods to be rapidly inserted into the core, and does not include manually Table H-1 Fire Areas EITHER:

Note 1: The Emergency Coordinator should declare the event promptly upon driving in control rods or implementation None of boron injection strategies. None Cellular Phones None X X determining that time limit has been exceeded, or will likely be exceeded. FIRE potentially degrading the level of safety of the plant Any penetration is not isolated within 15 min. of a VALID CNMT Palmetto 800 Transceivers X containment isolation signal Note 9: Mode 3 applicable only when RCS temperature is > 500°F Note 2: If an ongoing release is detected and the release start time is unknown,

  • Containment Failure OR assume that the release duration has exceeded the specified time limit. 1 2 3 4 5 6 DEF Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of Containment pressure 10 psig with < one full train of
  • Auxiliary Building service before the hazardous event occurred, then this emergency classification is Note 3: If the effluent flow past an effluent monitor is known to have stopped, HU4.1 depressurization equipment operating (one Containment not warranted.

indicating that the release path is isolated, the effluent monitor reading is no longer

  • Control Room A FIRE is not extinguished within 15 min. of any of the Spray System train AND one Containment Cooling System VALID for classification purposes. train) per design for 15 min. (Note 1)

RNP

  • Fuel Handling Building following FIRE detection indications (Note 1): Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no

- Report from the field (i.e., visual observation) indications of degraded performance to at least one train of a SAFETY SYSTEM, Table S-4 Hazardous Events Hazardous event affecting a SAFETY SYSTEM needed for the Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 then this emergency classification is not warranted.

and RG1.1 should be used for emergency classification assessments until the

  • Intake - Receipt of multiple (more than 1) fire alarms or indications current operating mode 9

results from a dose assessment using actual meteorology are available. - Field verification of a single fire alarm - Seismic event (earthquake) 1 2 3 4

  • AFW Room AND SA9.1 H

Note 5: If the equipment in the listed room or area was already inoperable or out-of- The FIRE is located within any Table H-1 area - Internal or external FLOODING event service before the event occurred, then no emergency classification is warranted.

  • 4 KV Switchgear Room The occurrence of any Table S-4 hazardous event

- High winds or tornado strike AND None

  • E-1/E-2 Switchgear Room HU4.2 Hazardous Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30- None 4

Receipt of a single fire alarm (i.e., no other indications of a Event - FIRE - Event damage has caused indications of degraded minute time limit, Nonedeclaration of a General Emergency is not required. None

  • RWST FIRE) Affecting performance on one train of a SAFETY SYSTEM Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, - EXPLOSION needed for the current operating mode Figure F-1 Integrity Press.- Temp. Limit Hazards
  • CST AND Safety ice, or vehicle breakdowns or accidents.

The fire alarm is indicating a FIRE within any Table H-1 area Systems AND EITHER of the following:

- Other events with similar hazard 3000 Fire characteristics as determined by the - Event damage has caused indications of degraded Note 8: A manual trip action is any operator action, or set of actions, which causes AND The existence of a FIRE is not verified within 30 min. of Shift Manager performance to a second train of the SAFETY 2560 295 325 355 the control rods to be rapidly inserted into the core, and does not include manually 2500 driving in control rods or implementation of boron injection strategies. alarm receipt (Note 1) SYSTEM needed for the current operating mode.

- Event damage has resulted in VISIBLE DAMAGE to 2000 RED GREEN Note 9: Mode 3 applicable only when RCS temperature is > 500°F None HU4.3 the second train of the SAFETY SYSTEM needed for LIMIT A PRESSURE A FIRE within the plant PROTECTED AREA not extinguished the current operating mode 1500 Note 10: If the affected SAFETY SYSTEM train was already inoperable or out of (Note 10, 11) within 60 min. of the initial report, alarm or indication (Note 1)

F O Y service before the hazardous event occurred, then this emergency classification is R E 1 2 3 4 1 2 3 4 1 2 3 4 A L not warranted. FG1.1 FS1.1 FA1.1 1000 N L HU4.4 G O Note 11: If the hazardous event only resulted in VISIBLE DAMAGE, with no [Refer to EAL CA6.1 OR SA9.1 for escalation due to E W A FIRE within the plant PROTECTED AREA that requires Loss of any two barriers Loss or potential loss of any two barriers (Table F-1) Any loss or any potential loss of either Fuel Clad or RCS 500 indications of degraded performance to at least one train of a SAFETY SYSTEM, FIRE] firefighting support by an offsite fire response agency to Fission AND barrier (Table F-1) then this emergency classification is not warranted.

extinguish Product Loss or potential loss of third barrier (Table F-1) 0 100 150 200 250 300 350 400 450 500 550 Barriers TEMPERATURE Gaseous release IMPEDING access to equipment necessary for normal plant operations, cooldown or shutdown 5 HA5.1 1 2 3 4 5 6 DEF Table F-1 Fission Product Barrier Threshold Matrix Hazardous None None Release of a toxic, corrosive, asphyxiant or flammable gas None Fuel Clad Barrier Reactor Coolant System Barrier Containment Barrier into any Table R-2/H-2 rooms or areas Gases AND Entry into the room or area is prohibited or IMPEDED (Note 5) Loss Potential Loss Loss Potential Loss Loss Potential Loss A. RCS or SG 1. An automatic or manual ECCS (SI) 1. Operation of a standby charging 1. A leaking or RUPTURED SG is Inability to control a key safety function from outside the Control Control Room evacuation resulting in transfer of plant control to Room Tube actuation required by EITHER: pump is required due to EITHER: FAULTED outside of containment alternate locations Leakage

  • UNISOLABLE RCS leakage
  • UNISOLABLE RCS leakage 1 2 3 4 5 6 1 2 3 4 5 6 DEF RNP None None None HS6.1 HA6.1
  • SG tube RUPTURE
  • SG tube leakage 6 None An event has resulted in plant control being transferred from the Control Room to the Dedicated/Alternate Shutdown System An event has resulted in plant control being transferred from the Control Room to the Dedicated/Alternate Shutdown System None
2. CSFST Integrity-RED Path entry conditions met Control AND Room 1. CSFST Core Cooling-RED Path 1. CSFST Core Cooling-ORANGE 1. CSFST Heat Sink-RED Path 1. CSFST Core Cooling-RED Path Control of any of the following key safety functions is not B. Inadequate Evacuation entry conditions met Path entry conditions met entry conditions met entry conditions met reestablished within 15 min. (Note 1): Heat AND AND

- Reactivity (Modes 1, 2, and 3 only) Removal 2. CSFST Heat Sink-RED Path Heat Sink is required None Restoration procedures not

- Core Cooling entry conditions met None effective within 15 min. (Note 1)

- RCS heat removal AND Heat Sink is required Other conditions exist which in the judgment of the Emergency Other conditions existing that in the judgment of the Emergency Other conditions exist that in the judgment of the Emergency Other conditions existing that in the judgment of the Emergency Coordinator warrant declaration of a General Emergency Coordinator warrant declaration of a Site Area Emergency Coordinator warrant declaration of an Alert Coordinator warrant declaration of a UE C. Containment 1. Containment High Range 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF 1 2 3 4 5 6 DEF Radiation / Radiation Monitor R-32A or 1. Containment High Range 1. Containment High Range Radiation RCS Activity R-32B > 100 R/hr Radiation Monitor R-32A or Monitor R-32A or R-32B > 2000 R/hr.

HG7.1 HS7.1 HA7.1 HU7.1 None None None

2. Dose equivalent I-131 coolant R-32B > 5 R/hr Other conditions exist which in the judgment of the Other conditions exist which in the judgment of the Other conditions exist which, in the judgment of the Other conditions exist which in the judgment of the 7

activity > 300 µCi/gm Emergency Coordinator indicate that events are in progress Emergency Coordinator indicate that events are in progress Emergency Coordinator, indicate that events are in progress Emergency Coordinator indicate that events are in progress or or have occurred which involve actual or IMMINENT or have occurred which involve actual or likely major failures or have occurred which involve an actual or potential have occurred which indicate a potential degradation of the 1. Containment isolation is required 1. CSFST Containment-RED Path substantial core degradation or melting with potential for loss of plant functions needed for protection of the public or substantial degradation of the level of safety of the plant or a level of safety of the plant or indicate a security threat to D. Containment Integrity or AND EITHER entry conditions met EC of containment integrity or HOSTILE ACTION that results in HOSTILE ACTION that results in intentional damage or security event that involves probable life threatening risk to facility protection has been initiated. No releases of

  • Containment integrity has been lost Judgment an actual loss of physical control of the facility. Releases can malicious acts, (1) toward site personnel or equipment that site personnel or damage to site equipment because of radioactive material requiring offsite response or monitoring Bypass 2. Containment hydrogen concentration 4%

based on Emergency Coordinator be reasonably expected to exceed EPA Protective Action could lead to the likely failure of or, (2) that prevent effective HOSTILE ACTION. Any releases are expected to be limited are expected unless further degradation of SAFETY judgment 3. Containment pressure 10 psig with Guideline exposure levels offsite for more than the access to equipment needed for the protection of the public. to small fractions of the EPA Protective Action Guideline SYSTEMS occurs. None None None None < one full train of depressurization immediate site area Any releases are not expected to result in exposure levels exposure levels.

  • UNISOLABLE pathway from equipment operating (one Containment which exceed EPA Protective Action Guideline exposure Containment to the environment exists Spray System train AND one Containment levels beyond the SITE BOUNDARY. Cooling System train) per design for
2. Indications of RCS leakage outside of Damage to a loaded cask CONFINEMENT BOUNDARY Containment 15 min.(Note 1)

Table E-1 ISFSI Dose Limits 1 2 3 4 5 6 DEF 1. Any condition in the opinion of the 1. Any condition in the opinion of 1. Any condition in the opinion of the 1. Any condition in the opinion of the 1. Any condition in the opinion of the 1. Any condition in the opinion of the E

7P ISFSI 24P ISFSI E. EC EU1.1 Judgment Emergency Coordinator that the Emergency Coordinator that Emergency Coordinator that Emergency Coordinator that Emergency Coordinator that indicates loss of Emergency Coordinator that indicates

  • 400 mrem/hr outside of HSM door on
  • 2,600 mrem/hr on None the HSM front surface Damage to a loaded canister CONFINEMENT BOUNDARY indicates loss of the Fuel Clad indicates potential loss of the indicates loss of the RCS barrier indicates potential loss of the RCS the Containment barrier potential loss of the Containment barrier None None barrier Fuel Clad barrier barrier centerline of DSC as indicated by an on-contact radiation reading on the
  • 10 mrem/hr on the HSM-H door centerline surface of a loaded spent fuel cask > any Table E-1 dose ISFSI
  • 400 mrem/hr at center of air inlets or outlets limit
  • 20 mrem/hr on the end shield wall exterior
  • 100 mrem/hr on roof, front, back or side Table F-2 CSFST Entry Conditions Table F-3 Reactor Vessel Water Level Thresholds Prepared for Duke Energy by: Operations Support Services, Inc. - www.ossi-net.com (7/5/16)

Core Cooling Core Cooling Heat Sink RCS Integrity Containment No. RCPs RVLIS Level RED Path ORANGE Path RED Path RED Path RED Path Operating Core exit T/Cs > 1,200°F EITHER of the following: All S/Gs < 9% [18%] Temperature decrease Containment Full Range None 41%

OR - Core exit T/Cs > 700°F AND in any RCS cold leg pressure > 42 psig Both of the following: - Reactor Vessel water Total FW flow to > 100ºF in last 60 min. Dynamic Head 3 53%

- Core exit T/Cs > 700°F level < Table F-3 S/Gs is less < 300 AND 2 35%

- Reactor Vessel water thresholds gpm or < 0.2E6 pph Any RCS cold leg 1 24%

level < Table F-3 temperature is to the thresholds left of Limit A, Figure F-1 Robinson Nuclear Plant EAL- HOT MODES 1, 2, 3 & 4 Robinson Nuclear Plant Modes: 1 Power Operations Startup 2 3 Hot Standby 4

Hot Shutdown 5

Cold Shutdown 6

Refuel DEF Defueled CSD-EP-RNP-0101-02 Rev 000 CSD-EP-RNP-0101-02 Rev 000

Retrieved from "https://kanterella.com/w/index.php?title=RA-20-0050,_Emergency_Action_Levels_CSD-EP-RNP-0101-02,_Revision_0&oldid=2560081"