10 CFR 50.47(b)(4) requires in part, a standard scheme of emergency classification and action levels the basis of which include facility system and effluent parameters. PLP- 007, Robinson
Emergency Plan, and the associated Emergency Action Level (
EAL) Matrices provide guidance for emergency classification. Contrary to the above, on December 6, 2011, the licensee identified that the Unusual Event (UE) (RU1.1) and Alert (RA1.1)
EAL criteria for the Liquid Waste Disposal Effluent could not be achieved due to the monitor range capability. Specifically, the R-18 effluent monitor instrument range has a maximum range of 1.0E+06 with the alarm set at 1.0E+06. The UE and Alert criteria, which are 2 times the alarm for at least 60 minutes and 200 times the alarm for at least 15 minutes respectively, both exceed the instrument range. Additionally, on December 8, 2011, the licensee identified that the same
EAL classification criteria for the
Steam Generator Blowdown radiation monitors and the Condensate Polisher
Sump discharge radiation monitor could not be achieved due to the monitors range capability. Specifically, the R-19 A, B, C and the R-37 monitors instrument range have a maximum range of 1.6E+06 which is less than the classification criteria. This finding was evaluated using
IMC 0609 Appendix B and was determined to be Green, because the specified radiation monitors created a condition such that an existing
EAL would not be declared for one Alert or Notification of Unusual Event. Immediate corrective actions by the licensee were to establish guidance to declare an Alert if the alarm was reached on any of these radiation monitors if flow could not be stopped within 15 minutes. Planned long term corrective actions include adjusting the radiation monitor alarms and revising the
EAL criteria. This issue is in the licensees
CAP as NCR 499498.
