Text

License Amendment Request 15-003 for Revision to Units 1 & 2 Emergency Action Levels
	ML15191A161
Person / Time
Site:	Comanche Peak
Issue date:	06/30/2015
From:	Flores R; Luminant Generation Co, Luminant Power
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15191A175	List: CP-201500668, License Amendment Request 15-003 for Revision to Units 1 & 2 Emergency Action Levels; ML15191A163; ML15191A164;
References
	CP-201500668, LAR 15-003, TXX-15101
	Download: ML15191A161 (125)
	v • d • e

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Rafael.Flores@Luminant.com Glen Rose, TX 76043 Luminant 2548975590 C 817 559 0403 F 254 897 6652 CP-201500668 Ref. # 10CFR50.90 TXX-15101 10CFR50 Appendix E June 30, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 AND 50-446 LICENSE AMENDMENT REQUEST 15-003 FOR REVISION TO UNIT 1 AND UNIT 2 EMERGENCY ACTION LEVELS

Dear Sir or Madam:

In accordance with the provisions of 10 CFR 50.90 and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section IV.B, Luminant Generation Company LLC (Luminant Power) is submitting a request for an amendment to the Emergency Plan for Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2.

The proposed amendment involves upgrading selected CPNPP Emergency Action Levels (EALs) based on NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," using the guidance of NRC Regulatory Issue Summary 2003-18, Supplement 2,"Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels." CPNPP currently uses an emergency classification scheme based on Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," February 2008, endorsed by the NRC in Letter from C. G. Miller (Nuclear Regulatory Commission) to Alan Nelson (Nuclear Energy Institute) dated February 22, 2008, "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI-99-01, Revision 5, dated February 2008." The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50. Pursuant to 10 CFR 50, Appendix E, Section IV.B, Luminant Power requests NRC approval of this proposed change to the CPNPP Emergency Plan prior to implementation.

This License Amendment Request includes the following attachments:

Attachment 1 - Evaluation of Proposed Change

Attachment 2 - CPNPP NEI 99-01, Revision 6 EAL Comparison Matrix

Attachment 3 - Emergency Action Level Technical Bases Document (Clean Version)

Attachment 4 - Emergency Action Level Technical Bases (Redline and Strikeout Version)

Attachment 5 - CPNPP Radiological Effluent EAL Values

Attachment 6 - Emergency Action Level Wallcharts for CPNPP Luminant Power requests approval of the proposed changes by June 30, 2016, with the amendment being implemented within 180 days of issuance.

U. S. Nuclear Regulatory Commission TXX-15101 Page 2 of 2 06/30/2015 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Texas State Official.

Luminant Power commits to review the new classification scheme with state and local emergency management officials following NRC approval and prior to implementation.

Should you have any questions, please contact Mr. Jack Hicks at (254) 897-6725 or jack.hicks@luminant.com.

I state under penalty of perjury that the foregoing is true and correct.

Sincerely, Luminant Generation Company LLC Rafael Flores By:__

Tom P. lVcCool Vice President, Nuclear Engineering & Support Attachments -

1. Evaluation of Proposed Change

2. CPNPP NEI 99-01, Revision 6 EAL Comparison Matrix

3. Emergency Action Level Technical Bases Document (Clean Version)

4. Emergency Action Level Technical Bases (Redline and Strikeout Version)

5. CPNPP Radiological Effluent EAL Values

6. Emergency Action Level Wallcharts for CPNPP c- William M. Dean, Office of Nuclear Reactor Regulation (cl & Attachment 1)

Marc L. Dapas, Region IV (cl & Attachment 1)

Balwant K. Singal, NRR (cl & Attachment 1)

Resident Inspectors, Comanche Peak (cl & Attachment 1)

Alice Hamilton Rogers, P.E., Texas Department of State Health Services (cl & Attachment 1) to TXX-1 5101 Page 1 of 6 EVALUATION OF PROPOSED CHANGE

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration Determination 4.3 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES

Attachment to TXX-15101 Page 2 of 6 1.0

SUMMARY

DESCRIPTION In accordance with the provisions of 10 CFR 50.90 and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section IV.B, Luminant Generation Company LLC (Luminant Power) is submitting a request for an amendment to the Emergency Plan for Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2.

The proposed amendment involves upgrading selected CPNPP Emergency Action Levels (EALs) based on NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors" (Reference 1) using the guidance of NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels" (Reference 2). CPNPP currently uses an emergency classification scheme based on Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels,"

February 2008 (Reference 3) endorsed by the NRC in Letter from C. G. Miller (Nuclear Regulatory Commission) to Alan Nelson (Nuclear Energy Institute) dated February 22, 2008, "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI-99-01, Revision 5, dated February 2008,"

(Reference 4) and approved for CPNPP in Reference 5. The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50.

2.0 DETAILED DESCRIPTION CPNPP currently uses an emergency classification scheme based on Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," February 2008 (Reference

3) endorsed by the NRC in Letter from C. G. Miller (Nuclear Regulatory Commission) to Alan Nelson (Nuclear Energy Institute) dated February 22, 2008, "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI-99-01, Revision 5, dated February 2008," (Reference 4) and approved for CPNPP in Reference 5. Luminant Power requests approval to change the CPNPP scheme basis to that described in NEI 99-01, Revision 6," Development of Emergency Action Levels for Non-Passive Reactors."

3.0 TECHNICAL EVALUATION

The Initiating Conditions (ICs) and EALs that comprise the proposed scheme are presented in . This matrix provides a cross-reference between each generic IC and EAL contained in NEI 99-01, Revision 6 and the proposed CPNPP-specific IC and EAL. Differences and Deviations are identified in accordance with the guidance discussed in RIS 2003-18 and Supplements. The basis for each Difference is included in Attachment 2. There are no Deviations from NEI 99-01, Revision 6. The matrix follows the presentation order of NEI 99-01, Revision 6 -Abnormal Rad Levels/Radiological Effluent, Cold Shutdown/Refueling System Malfunction, Events Related to Independent Spent Fuel Storage Installation (ISFSI), Fission Product Barrier Degradation, Hazards and Other Conditions Affecting Plant Safety, and System Malfunction. The Defueled Station section is not used since CPNPP is an operating plant.

Differences and Deviations As discussed in Regulatory Issue Summary (RIS) 2003-18, Supplement 1, dated July 13, 2004, differences and deviations are defined as follows:

A difference is an EAL change where the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the site-specific proposed EAL. Examples of differences include the use of site-specific terminology or administrative re-formatting of site-specific EALs.

Attachment to TXX-15101 Page 3 of 6 A deviation is an EAL change where the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the site-specific proposed EAL. Examples of deviations include the use of altered mode applicability, altering key words or time limits, or changing words of physical reference (protected area, safety- related equipment, etc.). identifies each Difference between NEI 99-01 and the final products being evaluated in this LAR. These differences do not alter the meaning or intent of the ICs or EALs. There are no Deviations between NEI 99-01 and the final products being evaluated in this LAR.

Incorporation of Action Level Frequently Asked Questions Where appropriate, information from Emergency Action Level Frequently Asked Questions (EALFAQs) has been incorporated into Attachment 2 and Attachment 3.

Related Documents includes the site-specific Technical Basis Document for each recognition category for the proposed scheme. A Redline and Strikeout version is provided as Attachment 4. These documents include appropriate information from the basis information contained in NEI 99-01, Revision 6. provides the Supporting Calculation for CPNPP EAL Table R-1, "Effluent Monitor Classification Thresholds." Attachment 6 contains the proposed CPNPP EAL Wallcharts.

Operational Modes and Applicability Mode applicability of the proposed ICs and EALs is consistent with the NEI 99-01, Revision 6 basis scheme. The Operating Modes for CPNPP, as defined in the Technical Specifications, are listed below.

MODE TITLE REACTIVITY % RATED AVERAGE REACTOR CONDITION (keff) THERMAL POWER COOLANT TEMPERATURE (F) 1 Power Operation >0.99 >5 NA 2 Startup >0.99 <5 NA 3 Hot Standby <0.99 NA >350 4 Hot Shutdown <0.99 NA 350>Tavg>200 5 Cold Shutdown <0.99 NA <200 6 Refueling NA NA NA In addition to these operating modes, NEI 99-01, Revision 6 defines the "Defueled" mode as the condition present when all reactor fuel is removed from Reactor Vessel (full core off load during refueling or an extended outage). Station procedures recognize this condition as "No Mode."

State/Local Government Review of Proposed Changes Luminant Power interacts periodically with the Texas and local emergency management agencies. The State and Local emergency management officials are advised of any EAL changes actually implemented. In the case of this EAL scheme revision, Luminant Power has committed to review the new classification scheme to State and Local emergency management officials following NRC approval and prior to implementation.

Implementation Description Luminant Power plans to implement the proposed emergency classification scheme in the third quarter of 2016. When implemented, the changes to the EALs presented in Attachment 3 will become effective.

Attachment to TXX-15101 Page 4 of 6 The EAL Technical Basis Document (Attachment 3) will be revised and maintained as a training and background reference resource. Any changes to the approved ICs and EALs will be made in accordance with 10 CFR 50.54(q).

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The regulation in 10 CFR 50.47(b)(4) states, "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and Local response plans call for reliance on information provided by facility licensees for determinations of minimunm initial offsite response measures."

10 CFR 50 Appendix E, Section IV, Content of Emergency Plans, item B, Assessment Actions states:

1. "The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of Local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC.

Thereafter, emergency action levels shall be reviewed with the State and Local governmental authorities on an annual basis."

2. A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. Licensees shall follow the change process in § 50. 5 4 (q) for all other emergency action level changes.

Regulatory Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors, Revision 4, Section C, Regulatory Position states:

"The guidance in NUMARC/NESP-007 (Revision 2, January 1992), "Methodology for Development of Emergency Action Levels," is acceptable to the NRC staff as an alternative method to that described in Appendix 1 to NUREG-0654/FEMA-REP-1 for developing EALs required in Section IV.B of Appendix E to 10 CFR Part 50 and 10 CFR50.47(b)(4). In addition, the guidance contained in NEI 99-01 (Revision 4, January 2003), "Methodology for Development of Emergency Action Levels," is acceptable to the NRC staff as an alternative method to that described in Appendix 1 to NUREG-0654/FEMA-REP-1 and NUMARC/NESP-007 for developing EALs required in Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4)."

4.2 No Significant Hazards Consideration Determination Luminant Power has evaluated whether or not a significant hazards consideration (SHC) is warranted with the proposed changes by addressing the three criteria set forth in 10 CFR50.92(c) as discussed below:

Attachment to TXX-15101 Page 5 of 6

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

These changes affect the CPNPP Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. The proposed changes do not modify any plant equipment and do not impact any failure modes that could lead to an accident. Additionally, the proposed changes do not impact the consequence of any analyzed accident since the changes do not affect any equipment related to accident mitigation. Based on this discussion, the proposed amendment does not increase the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

These changes affect the CPNPP Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. They do not modify any plant equipment and there is no impact on the capability of the existing equipment to perform their intended functions. No system setpoints are being modified and no changes are being made to the method in which plant operations are conducted. No new failure modes are introduced by the proposed changes. The proposed amendment does not introduce accident initiators or malfunctions that would cause a new or different kind of accident.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

These changes affect the CPNPP Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. The proposed changes do not affect any of the assumptions used in the accident analysis, nor do they affect any operability requirements for equipment important to plant safety. Therefore, the proposed changes will not result in a significant reduction in the margin of safety as defined in the bases for technical specifications covered in this license amendment request.

4.3 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change in the CPNPP EAL Scheme, (2) operation of CPNPP will continue to be conducted in compliance with the Commission regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

Luminant Power has determined that the proposed amendment would not change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR 20, nor

Attachment to TXX-15101 Page 6 of 6 would it change inspection or surveillance requirements. Luminant Power has evaluated the proposed change and has determined that the change does not involve:

I. A Significant Hazards Consideration, II. A significant change in the types or significant increase in the amounts of any effluent that may be released off site, or III. A significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10)(ii). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1) NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 2012, (ADAMS Accession No. ML12326A805)

2) NRC Regulatory Issue Summary 2003-18, Supplement 2, Use of Nuclear Energy Institute (NEI) 99-0 1, Methodology for Development of Emergency Action Levels, dated December 12, 2005 (ADAMS Accession No. ML051450482)

3) Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," February 2008 (ADAMS Accession No. ML080450149).

4) Letter from C. G. Miller (Nuclear Regulatory Commission) to Alan Nelson (Nuclear Energy Institute) dated February 22, 2008, "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI-99-01, Revision 5, dated February 2008," (ADAMS Accession ML080430535)

5) Letter from Eric J. Leeds (Nuclear Regulatory Commission) to Mr. Rafael Flores (Luminant Generation Company LLC) dated May 17, 2010, "Comanche Peak Nuclear Power Plant, Units 1 and 2- Change to Emergency Action Level Scheme (TAC NOS. ME1304 and ME1305)"

(ADAMS Accession No. ML100850115)

ATTACHMENT 2 TO TXX-15101 CPNPP NEI 99-01, REVISION 6 EAL COMPARISON MATRIX (116 PAGES) to TXX-15101 EAL Comparison Matrix Comanche Peak Nuclear Power Plant NEI 99-01 Revision 6 EAL Comparison Matrix Revision 0 to TXX-1 5101 EAL Comparison Matrix Table of Contents Section Page Introduction --------------------------------------------------------------------------------------------------------------------------------------------------------- I Comparison Matrix Format --------------------------------------------------------------------- 1 EAL Wording ------------------------------------------------------------------------------------------------------------------------------------------------------- I.

EAL Emphasis Techniques --------------------------------------------------------------------- 1 Global Differences --------------------------------------------------------------------------- 2 Differences and Deviations --------------------------------------------------------------------- 3 Category A - Abnormal Rad Levels / Rad Effluents --------------------------------------------------------------------------------------------------- 12 Category C - Cold Shutdown / Refueling System Malfunction -------------------------------------------------------------------------------------- 31 Category D - Permanently Defueled Station Malfunction ------------------------------------------------ 52 Category E - Events Related to Independent Spent Fuel Storage Installations --------------------------------- 54 Category F - Fission Product Barrier Degradation.................................................----------------------------------------------------- 56 Category H - Hazards and Other Conditions Affecting Plant Safety ------------------------------------------------------------------------------- 69 Category S - System Malfunction --------------------------------------------------------------------------------------------------------------------------- 88 Table 1 - CPNPP EAL Categories/Subcategories ----------------------------------------------------- 5 Table 2 - NEI / CPNPP EAL Identification Cross-Reference ----------------------------------------------- 6 Table 3 - Summary of Deviations -------------------------------------------------------------------------------------------------------------------------- 11 to TXX-1 5101 EAL Comparison Matrix Introduction criteria in cases when following the criteria would introduce undesirable This document provides a line-by-line comparison of the Initiating Conditions complications in the EAL layout.

(ICs), Mode Applicability and Emergency Action Levels (EALs) in NEI 99-01 " Upper case-bold print is used for the logic terms AND, OR and Rev. 6 Final, Development of Emergency Action Levels for Non-Passive EITHER.

Reactors, ADAMS Accession Number ML12326A805, and the Comanche " Bold font is used for certain logic terms, negative terms (not, Peak Nuclear Power Plant (CPNPP) ICs, Mode Applicability and EALs. This cannot, etc.), any, all.

document provides a means of assessing CPNPP differences and deviations from the NRC endorsed guidance given in NEI 99-01. Discussion of CPNPP " Upper case print is reserved for defined terms, acronyms, system EAL bases and lists of source document references are given in the EAL abbreviations, logic terms (and, or, etc. when not used as a Technical Bases Document. It is, therefore, advisable to reference the EAL conjunction), annunciator window engravings.

Technical Bases Document for background information while using this

Three or more items in a list are normally introduced with "Any of the document.

following..." or "All of the following..." Items of the list begin with bullets when a priority or sequence is not inferred.

Comparison Matrix Format " The use of AND/OR logic within the same EAL has been avoided The ICs and EALs discussed in this document are grouped according to NEI when possible. When such logic cannot be avoided, indentation and 99-01 Recognition Categories. Within each Recognition Category, the ICs separation of subordinate contingent phrases is employed.

and EALs are listed in tabular format according to the order in which they are given in NEI 99-01. Generally, each row of the comparison matrix provides the following information: Global Differences The differences listed below generally apply throughout the set of EALs and

" NEI EAL/IC identifier are not repeated in the Justification sections of this document. The global

" NEI EAL/IC wording differences do not decrease the effectiveness of the intent of NEI 99-01.

" CPNPP EAL/IC identifier 1. The NEI phrase "Notification of Unusual Event" has been changed to "Unusual Event" or abbreviated "UE" to reduce EAL-user reading

" CPNPP EAL/IC wording burden.

o Description of any differences or deviations 2. In some instances NEI 99-01 IC Example EALs are implemented in separate plant EALs to improve clarity and readability. For example, EAL Emphasis Techniques NEI lists all IC HU3 Example EALs under one IC. The corresponding Due to the width of the table columns and table formatting constraints in this CPNPP EALs appear as unique EALs (e.g., HU3.1 through HU3.4).

document, line breaks and indentation may differ slightly from the 3. Mode applicability identifiers (numbers/letter) modify the NEI 99-01 appearance of comparable wording in the source documents. NEI 99-01 is mode applicability names as follows: 1 - Power Operation, 2 -

the source document for the NEI EALs; the CPNPP EAL Technical Bases Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 -

Document for the CPNPP EALs. Refueling, D - Defueled. NEI 99-01defines Defueled as follows:

The print and paragraph formatting conventions summarized below guide "Reactor Vessel contains no irradiated fuel (full core off-load during presentation of the CPNPP EALs in accordance with the EAL writing criteria. refueling or extended outage)."

Space restrictions in the EAL table of this document sometimes override this 4. "rain." is the standard abbreviation for "minutes" and is used to reduce EAL user reading burden.

1 of 114 to TXX-1 5101 EAL Comparison Matrix

5. The term "Emergency Director" has been replaced by "Emergency user for a given plant condition and, thereby, speeds Coordinator" consistent with site-specific nomenclature. identification of the EAL that applies to the emergency.

6. Wherever the generic bracketed PWR term "reactor vessel/RCS" is b. Within each of the above three groups, assignment of provided, CPNPP uses the term "RCS" as the site-specific EALs to categories/subcategories - Category and nomenclature. subcategory titles are selected to represent conditions that are operationally significant to the EAL-user.

7. IC/EAL identification: Subcategories are used as necessary to further divide the

NEI Recognition Category A "Abnormal Radiation Levels/ EALs of a category into logical sets of possible Radiological Effluents" has been changed to Category R emergency classification thresholds. The CPNPP EAL "Abnormal Rad Levels / Rad Effluents." The designator "R" is categories/subcategories and their relationship to NEI more intuitively associated with radiation (rad) or radiological Recognition Categories are listed in Table 1.

events. NEI IC designators beginning with "A" have likewise c. Unique identification of each EAL - Four characters been changed to "R." comprise the EAL identifier as illustrated in Figure 1.

NEI 99-01 defines the thresholds requiring emergency classification (example EALs) and assigns them to ICs which, in Figure 1 - EAL Identifier turn, are grouped in "Recognition Categories." CPNPP endeavors to optimize the NEI EAL organization and EAL Identifier identification scheme to enhance usability of the plant-specific XXX.X EAL set. To this end, the CPNPP IC/EAL scheme includes the Category(R,H, E, S. F. C) iL Sequential number Within subcategory/classificatioo following features: Emergency classification (G.S.A. U) 1ýSubcategory number(Ilifnosubeetegory)

a. Division of the NEI EAL set into three groups:

The first character is a letter associated with the category o EALs applicable under all plant operating modes - in which the EAL is located. The second character is a This group would be reviewed by the EAL-user any letter associated with the emergency classification level time emergency classification is considered. (G for General Emergency, S for Site Area Emergency, A o EALs applicable only under hot operating modes- for Alert, and U for Notification of Unusual Event). The This group would only be reviewed by the EAL-user third character is a number associated with one or more when the plant is in Hot Shutdown, Hot Standby, subcategories within a given category. Subcategories are Startup or Power Operation mode. sequentially numbered beginning with the number "1". If a category does not have a subcategory, this character is o EALs applicable only under cold operating modes - assigned the number "1". The fourth character is a This group would only be reviewed by the EAL-user number preceded by a period for each EAL within a when the plant is in Cold Shutdown, Refueling or subcategory. EALs are sequentially numbered within the Defueled mode. emergency classification level of a subcategory beginning The purpose of the groups is to avoid review of hot with the number "1".

condition EALs when the plant is in a cold condition and The EAL identifier is designed to fulfill the following avoid review of cold condition EALs when the plant is in a objectives:

hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-2 of 114 to TXX-15101 EAL Comparison Matrix o Uniqueness - The EAL identifier ensures that there

Choosing the applicable EAL based upon plant type (i.e., BWR vs.

can be no confusion over which EAL is driving the PWR).

need for emergency classification.

Using a numbering scheme other than that provided in NEI 99-01 o Speed in locating the EAL of concern - When the that does not change the intent of the overall scheme.

EALs are displayed in a matrix format, knowledge " Where the NEI 99-01 guidance specifically provides an option to not of the EAL identifier alone can lead the EAL-user to include an EAL if equipment for the EAL does not exist at CPNPP the location of the EAL within the classification (e.g., automatic real-time dose assessment capability).

matrix. The identifier conveys the category, subcategory and classification level. This assists " Pulling information from the bases section up to the actual EAL that ERO responders (who may not be in the same does not change the intent of the EAL.

facility as the ED) to find the EAL of concern in a

Choosing to state ALL Operating Modes are applicable instead of timely manner without the need for a word stating N/A, or listing each mode individually under the Abnormal description of the classification threshold. Rad Level/Radiological Effluent and Hazard and Other Conditions o Possible classification upgrade - The Affecting Plant Safety sections.

category/subcategory/identifier scheme helps the

Using synonymous wording (e.g., greater than or equal to vs. at or EAL-user find higher emergency classification EALs above, less than or equal vs. at or below, greater than or less than that may become active if plant conditions worsen.

vs. above or below, etc.)

Table 2 lists the CPNPP ICs and EALs that correspond to

Adding CPNPP equipment/instrument identification and/or noun the NEI ICs/Example EALs when the above EAL/IC names to EALs.

organization and identification scheme is implemented.

Combining like ICs that are exactly the same but have different operating modes as long as the intent of each IC is maintained and Differences and Deviations the overall progression of the EAL scheme is not affected.

In accordance NRC Regulatory Issue Summary (RIS) 2003-18 "Use of " Any change to the IC and/or EAL, and/or basis wording, as stated in Nuclear Energy Institute (NEI) 99-01, Methodology for Development of NEI 99-01, that does not alter the intent of the IC and/or EAL, i.e.,

Emergency Action Levels" Supplements 1 and 2, a difference is an EAL the IC and/or EAL continues to:

change in which the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, o Classify at the correct classification level.

whether using the basis scheme guidance or the CPNPP EAL. A deviation is o Logically integrate with other EALs in the EAL scheme.

an EAL change in which the basis scheme guidance differs in wording and is o Ensure that the resulting EAL scheme is complete (i.e.,

altered in meaning or intent, such that classification of the event could be classifies all potential emergency conditions).

different between the basis scheme guidance and the CPNPP proposed EAL. The following are examples of deviations:

Administrative changes that do not actually change the textual content are " Use of altered mode applicability.

neither differences nor deviations. Likewise, any format change that does not

Altering key words or time limits.

alter the wording of the IC or EAL is considered neither a difference nor a deviation. " Changing words of physical reference (protected area, safety-related equipment, etc.).

The following are examples of differences:

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Eliminating an IC. This includes the removal of an IC from the Fission Product Barrier Degradation category as this impacts the logic of Fission Product Barrier ICs.

Changing a Fission Product Barrier from a Loss to a Potential Loss or vice-versa.

Not using NEI 99-Oldefinitions as the intent is for all NEI 99-01 users to have a standard set of defined terms as defined in NEI 99-01.

Differences due to plant types are permissible (BWR or PWR).

Verbatim compliance to the wording in NEI 99-01 is not necessary as long as the intent of the defined word is maintained. Use of the wording provided in NEI 99-01 is encouraged since the intent is for all users to have a standard set of defined terms as defined in NEI 99-01.

Any change to the IC and/or EAL, and/or basis wording as stated in NEI 99-01 that does alter the intent of the IC and/or EAL, i.e., the IC and/or EAL:

o Does not classify at the classification level consistent with NEI 99-01.

o Is not logically integrated with other EALs in the EAL scheme.

o Results in an incomplete EAL scheme (i.e., does not classify all potential emergency conditions).

The "Difference/Deviation Justification" columns in the remaining sections of this document identify each difference between the NEI 99-01 IC/EAL wording and the CPNPP IC/EAL wording. An explanation that justifies the reason for each difference is then provided. If the difference is determined to be a deviation, a statement is made to that affect and explanation is given that states why classification may be different from the NEI 99-01 IC/EAL and the reason for its acceptability. In all cases, however, the differences and deviations do not decrease the effectiveness of the intent of NEI 99-01. A summary list of CPNPP EAL deviations from NEI 99-01 is given in Table 3.

4 of 114 to TXX-1 5101 EAL Comparison Matrix Table I - CPNPP EAL Categories/Subcategories CPNPP EALs NEI Category Subcategory Recognition Category Group: Any Operatingq Mode:

1 - Radiological Effluent Abnormal Rad Levels/Radiological Effluent R- Abnormal Rad Levels/Rad Effluent 2 - Irradiated Fuel Event ICs/EALs 3 -Area Radiation Levels H - Hazards and Other Conditions Affecting 1- Security Hazards and Other Conditions Affecting Plant Safety 2- Seismic Event Plant Safety [Cs/EALs 3- Natural or Technological Hazard 4- Fire 5 - Hazardous Gases 6 - Control Room Evacuation 7 - Emergency Coordinator Judgment E - ISFSl 1 - Confinement Boundary ISFSI ICs/EALs Group: Hot Conditions:

1 - Loss of Emergency AC Power System Malfunction ICs/EALs 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4- RCS Activity S - System Malfunction 5- RCS Leakage 6- RPS Failure 7- Loss of Communications 8- Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier None Fission Product Barrier ICs/EALs Group: Cold Conditions:

1 - RCS Level Cold Shutdown./ Refueling System 2 - Loss of Emergency AC Power Malfunction ICs/EALs C - Cold Shutdown/Refueling System 3 - RCS Temperature Malfunction 4 - Loss of Vital DC Power 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems 5 of 114 to TXX-15101 EAL Comparison Matrix Table 2 - NEI / CPNPP EAL Identification Cross-Reference NEI CPNPP IC Example Category and Subcategory EAL EAL AU1 1 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RUI.1 AU1 2 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RUI.1 AU1 3 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.2 AU2 1 R - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event RU2.1 AA1 2 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.1 AA1 2 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.2 AA1 3 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.3 AA1 4 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.4 AA2 1 R - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event RA2.1 AA2 2 R - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event RA2.2 AA2 3 R - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event RA2.3 AA3 1 R - Abnormal Rad Levels / Rad Effluent, 3 - Area Radiation Levels RA3.1 AA3 2 R - Abnormal Rad Levels / Rad Effluent, 3 - Area Radiation Levels RA3.2 ASI 1 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RSI.1 AS1 2 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.2 ASI 3 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.3 6 of 114 to TXX-15101 EAL Comparison Matrix NEI CPNPP 1C Example EAL Category and Subcategory EAL AS2 1 R - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event RS2.1 AG1 1 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RG1.1 AG1 2 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RG1.2 AG1 3 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RG1.3 AG2 1 R - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event RG2.1 CUl 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CU1.1 CU1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CUI.2 CU2 1 C - Cold SD/ Refueling System Malfunction, 2 - Loss of ESF AC Power CU2.1 CU3 1 C - Cold SD/ Refueling System Malfunction, 3 - RCS Temperature CU3.1 CU3 2 C - Cold SD/ Refueling System Malfunction, 3 - RCS Temperature CU3.2 CU4 I C - Cold SD/ Refueling System Malfunction, 4 - Loss of Vital DC Power CU4.1 CU5 1, 2, 3 C - Cold SD/ Refueling System Malfunction, 5 - Loss of Communications CU5.1 CA1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CA1.1 CAI 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CA1.2 CA2 1 C - Cold SD/ Refueling System Malfunction, 1 - Loss of ESF AC Power CA2.1 CA3 1, 2 C - Cold SD/ Refueling System Malfunction, 3 - RCS Temperature CA3.1 CA6 1 C - Cold SD/ Refueling System Malfunction, 6 - Hazardous Event Affecting Safety Systems HA4.1 CS1 I C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CS1.1 7 of 114 to TXX-15101 EAL Comparison Matrix NEI CPNPP IC Example Category and Subcategory EAL EAL CS1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CS1.2 CS1 3 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CSI.3 CG1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CGI.2 CG1 2 C - Cold SD/ Refueling System Malfunction, Il - RCS Level CG1.2 E-HUI 1 E - ISFSI - Confinement Boundary EUI.1 FA1 1 F - Fission Product Barrier Degradation FA1.1 FSI I F - Fission Product Barrier Degradation FSI.1 FG1 1 F - Fission Product Barrier Degradation FG1.1 HUI 1 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HUI.1 HU1 2 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HU1.2 HUI 3 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HU1.3 HU2 1 H - Hazards and Other Conditions Affecting Plant Safety, 2 - Seismic Event HU2.1 HU3 1 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.1 HU3 2 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.2 HU3 3 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.3 HU3 4 H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.4 HU3 5 N/A N/A HU4 1 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.1 8 of 114 to TXX-15101 EAL Comparison Matrix NEI CPNPP Example Category and Subcategory EAL EAL HU4 2 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.2 HU4 3 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.3 HU4 4 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.4 HU7 I H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HU7.1 HAI 1 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HA1.1 HA1 2 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HAI.1 HA5 1 H - Hazards and Other Conditions Affecting Plant Safety, 5 - Hazardous Gases HA5.1 HA6 1 H - Hazards and Other Conditions Affecting Plant Safety, 6 - Control Room Evacuation HA6.1 HA7 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HA7.1 HSI 1 H - Hazards and Other Conditions Affecting Plant Safety, I - Security HSI.1 HS6 I H - Hazards and Other Conditions Affecting Plant Safety, 6 - Control Room Evacuation HS6.1 HS7 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HS7.1 HG1 I H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HGI.1 HG7 2 H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HG7.1 SUl 1 S - System Malfunction, I - Loss of Emergency AC Power SUI.1 SU2 I S - System Malfunction, 3 - Loss of Control Room Indications SU3.1 SU3 1 S - System Malfunction, 4 - RCS Activity SU4.1 SU3 2 S - System Malfunction, 4 - RCS Activity SU4.2 9 of 114 to TXX-1 5101 EAL Comparison Matrix NEI CPNPP IC Example EAL Category and Subcategory EAL SU4 1, 2, 3 S - System Malfunction, 5 - RCS Leakage SU5.1 SU5 1 S - System Malfunction, 6 - RPS Failure SU6.1 SU5 2 S - System Malfunction, 6 - RPS Failure SU6.2 SU6 1, 2, 3 S - System Malfunction, 7 -Loss of Communications SU7.1 SU7 1, 2 S - System Malfunction, 8 -Containment Failure SU8.1 SA1 1 S - System Malfunction, 1 - Loss of Emergency AC Power SA1.1 SA2 I S - System Malfunction, 3 - Loss of Control Room Indications SA3.1 SA5 1 S - System Malfunction, 6 - RPS Failure SA6.1 SA9 I S - Hazardous Event Affecting Safety Systems SA9.1 SS1 1 S - System Malfunction, 1 - Loss of Emergency AC Power SS1.1 SS5 1 S - System Malfunction, 6 - RPS Failure SS6.1 SS8 1 S - System Malfunction, 2 - Loss of Vital DC Power SS2.1 SG1 1 S - System Malfunction, 1 - Loss of Emergency AC Power SG1.1 SG8 2 S - System Malfunction, 1 - Loss of Emergency AC Power SG1.2 10 of 114 to TXX-1 5101 EAL Comparison Matrix Table 3 - Summary of Deviations NEI CPNPP Description IC Example EAL EAL N/A N/A N/A N/A 11 of 114 to TXX-15101 EAL Comparison Matrix Category A Abnormal Rad Levels / Radiological Effluent 12 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording and Mode CPNPP CPNPP IC Wording and Mode Difference/Deviation Justification Applicability IC#(s) Applicability AU1 Release of gaseous or liquid RU1 Release of gaseous or liquid The CPNPP ODCM is the site-specific effluent release radioactivity greater than 2 times radioactivity greater than 2 times the controlling document.

the (site-specific effluent release ODCM limits for 60 minutes or longer controlling document) limits for MODE: All 60 minutes or longer.

MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 Reading on ANY effluent Reading on any Table R-1 effluent Example EALs #1 and #2 have been combined into a single radiation monitor greater than 2 radiation monitor greater than column EAL to simplify presentation.

times the (site-specific effluent "UE" for greater than or equal to 60 The NEI phrase "...effluent radiation monitor greater than 2 release controlling document) mi. (Notes 1, 2, 3) times the (site-specific effluent release controlling limits for 60 minutes or longer: document)" and "effluent radiation monitor greater than 2 (site-specific monitor list and times the alarm setpoint established by a current radioactivity threshold values corresponding discharge permit" have been replaced with "...any Table R-1 to 2 times the controlling RU1.1 effluent radiation monitor greater than column "UE".

document limits) UE thresholds for all CPNPP continuously monitored 2 Reading on ANY effluent gaseous release pathways are listed in Table R-1 to radiation monitor greater than 2 consolidate the information in a single location and, thereby, times the alarm setpoint simplify identification of the thresholds by the EAL user. The established by a current values shown in Table R-1 column "UE", consistent with the radioactivity discharge permit for NEI bases, represent two times the ODCM release limits for 60 minutes or longer, both liquid and gaseous release.

3 Sample analysis for a gaseous or RU1.2 Sample analysis for a gaseous or The CPNPP ODCM is the site-specific effluent release liquid release indicates a liquid release indicates a concentration controlling document.

concentration or release rate or release rate > 2 x ODCM limits for greater than 2 times the (site- greater than or equal to 60 min.

specific effluent release (Notes 1, 2) controlling document) limits for 13 of 114 to TXX-15101 EAL Comparison Matrix NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

60 minutes or longer.

Notes 0 The Emergency Director N/A Note 1: The Emergency Coordinator The classification timeliness note has been standardized should declare the Unusual should declare the event across the CPNPP EAL scheme by referencing the "time Event promptly upon promptly upon determining limit" specified within the EAL wording.

determining that 60 minutes that time limit has been has been exceeded, or will exceeded, or will likely be likely be exceeded. exceeded.

" If an ongoing release is Note 2: If an ongoing release is The classification timeliness note has been standardized detected and the release detected and the release across the CPNPP EAL scheme by referencing the "time start time is unknown, start time is unknown, limit" specified within the EAL wording.

assume that the release assume that the release duration has exceeded 60 duration has exceeded the minutes. specified time limit.

" If the effluent flow past an Note 3: If the effluent flow past an effluent monitor is known to effluent monitor is known to None have stopped due to actions have stopped, indicating that to isolate the release path, the release path is isolated, then the effluent monitor the effluent monitor reading reading is no longer valid for is no longer VALID for classification purposes. classification purposes.

14 of 114 to TXX-15101 EAL Comparison Matrix Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent X-RE-5567 6.52E-4 pCi/mi PVG384 + PVG385 A+ B Plant Vent X-E57 0 Ven (WRGM) 4.OE+7 pLCi/sec 4.OE+6 lOCi/sec 4.OE+5 piCi/sec 4.OE+4 OCi/sec o A+BGM 0 PVF684 + PVF685 U)

' Main Steam MSLu78 u-RE-2325 MSLu79 u-RE-2326 90 jICi/ml* 9.0 liCj/ml* 0.9 pCi/ml* 2 x high alarm MSLu8O u-RE-2327 setpoint*

MSLu81 u-RE-2328 Liquid Waste X-RE-5253 ...............- 2 x high alarm LWE-076 setpoint

._ Service Water u-RE-4269 2 x high alarm

' SSWu65....

SSWu66 u-RE-4270 ....

setpoint

with reactor shutdown 15 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording and Mode CPNPP CPNPP IC Wording and Mode Difference/Deviation Justification Applicability IC#(s) Applicability AU2 UNPLANNED loss of water level RU2 Unplanned loss of water level above None above irradiated fuel. irradiated fuel MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNA CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

a. UNPLANNED water level RU2.1 UNPLANNED water level drop in the Site-specific area radiation monitors are listed in Table R-2.

drop in the REFUELING REFUELING PATHWAY as indicated PATHWAY as indicated by by low water level alarm or indication ANY of the following:

(site-specific level AND indications). UNPLANNED rise in corresponding ANND area radiation levels as indicated by radiation levels as indicated any Table R-2 area radiation monitors by ANY of the following radiation monitors.

(site-specific list of area radiation monitors)

Table R-2 SFP & Refueling Cavity Area Radiation Monitors SFP:

SFP001, LRAM SFP 2 E WALL (X-RE-6272)

SFP002, LRAM SFP 2 N WALL (X-RE-6273)

" SFP003, LRAM SFP 1 E WALL (X-RE-6274)

" SFP004, LRAM SFP 1 S WALL (X-RE-6275)

Refueling Cavity:

RFCuI0, LRAM W REFUEL CAV860 (u-RE-6251)

" RFCu12, LRAM E REFUEL CAV 860 (u-RE-6253) 16 of 114 to TXX-15101 EAL Comparison Matrix NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

Release of gaseous or liquid RA1 Release of gaseous or liquid None radioactivity resulting in offsite radioactivity resulting in offsite dose dose greater than 10 mrem TEDE greater than 10 mrem TEDE or 50 or 50 mrem thyroid CDE. mrem thyroid CDE MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 Reading on ANY of the following RAl.1 Reading on any Table R-1 effluent The CPNPP radiation monitors that detect radioactivity radiation monitors greater than radiation monitor greater than column effluent release to the environment are listed in Table R-1.

the reading shown for 15 "ALERT" for greater than or equal to UE, Alert, SAE and GE thresholds for all CPNPP minutes or longer: 15 min. (Notes 1, 2, 3, 4) continuously monitored gaseous and liquid release pathways are listed in Table R-1 to consolidate the information in a (site-specific monitor list and single location and, thereby, simplify identification of the threshold values) thresholds by the EAL-user.

2 Dose assessment using actual RA1.2 Dose assessment using actual The exclusion area boundary is the site-specific receptor meteorology indicates doses meteorology indicates doses greater point.

greater than 10 mrem TEDE or than 10 mrem TEDE or 50 mrem 50 mrem thyroid CDE at or thyroid CDE at or beyond the the beyond (site-specific dose EXCLUSION AREA BOUNDARY receptor point). (Notes 3, 4) 3 Analysis of a liquid effluent RA1.3 Analysis of a liquid effluent sample The exclusion area boundary is the site-specific receptor sample indicates a concentration indicates a concentration or release point.

or release rate that would result rate that would result in doses greater in doses greater than 10 mrem than 10 mrem TEDE or 50 mrem TEDE or 50 mrem thyroid CDE thyroid CDE at or beyond the the at or beyond (site-specific dose EXCLUSION AREA BOUNDARY for receptor point) for one hour of 60 min. of exposure (Notes 1, 2) exposure.

17 of 114 to TXX-1 5101 EAL Comparison Matrix T r Field survey results indicate RA1.4 The exclusion area boundary is the site-specific receptor 4 Field survey results indicate EITHER EITHER of the following at or point.

of the following at or beyond the beyond (site-specific dose EXCLUSION AREA BOUNDARY:

receptor point):

" Closed window dose rates " Closed window dose rates greater than 10 mR/hr greater than 10 mR/hr expected to continue for 60 expected to continue for minutes or longer. greater than or equal to 60

" Analyses of field survey min.

samples indicate thyroid

Analyses of field survey CDE greater than 50 mrem samples indicate thyroid CDE for one hour of inhalation.

greater than 50 mrem for 60 min. of inhalation.

(Notes 1, 2)

Notes " The Emergency Director N/A Note 1: The Emergency Coordinator The classification timeliness note has been standardized should declare the Alert should declare the event across the CPNPP EAL scheme by referencing the "time promptly upon determining promptly upon determining limit" specified within the EAL wording.

that the applicable time has that time limit has been been exceeded, or will likely exceeded, or will likely be be exceeded. exceeded.

" If an ongoing release is Note 2: If an ongoing release is The classification timeliness note has been standardized detected and the release detected and the release across the CPNPP EAL scheme by referencing the "time start time is unknown, start time is unknown, limit" specified within the EAL wording.

assume that the release assume that the release duration has exceeded 15 duration has exceeded the minutes. specified time limit.

" If the effluent flow past an Note 3: If the effluent flow past an effluent monitor is known to effluent monitor is known to None have stopped due to actions have stopped, indicating to isolate the release path, that the release path is then the effluent monitor isolated, the effluent monitor reading is no longer valid for reading is no longer VALID classification purposes. for classification purposes.

Note 4 The pre-calculated effluent Incorporated site-specific EAL numbers associated with

" The pre-calculated effluent monitor values presented in generic EAL#1.

monitor values oresented in EALs RAI.1. RSI.1 and 18 of 114 to TXX-15101 EAL Comparison Matrix EAL #1 should be used for RG1.1 should be used for emergency classification emergency classification assessments until the results assessments until the from a dose assessment results from a dose using actual meteorology are assessment using actual available. meteorology are available.

19 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

AA2 Significant lowering of water RA2 Significant lowering of water level None level above, or damage to, above, or damage to, irradiated fuel irradiated fuel. MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 Uncovery of irradiated fuel in the RA2.1 Uncovery of irradiated fuel in the None REFUELING PATHWAY. REFUELING PATHWAY 2 Damage to irradiated fuel RA2.2 Damage to irradiated fuel resulting in a Site-specific list of radiation monitors bulletized.

resulting in a release of release of radioactivity radioactivity from the fuel as AND indicated by ANY of the High alarm on any of the following:

following radiation monitors: 0 Any Table R-2 area radiation monitors (site-specific listing of radiation

CAGu97, CNTMT AIR PIG GAS monitors, and the associated (u-RE-5503) readings, alarms) setpoints and/or

CAPu98, CNTMT AIR PIG PART (u-RE-5502) 0 CAIu99, CNTMT AIR PIG IODINE (u-RE-5566) a FBV088, FB VENT EXH (X-RE-5700) 3 Lowering of spent fuel pool level RA2.3 Lowering of spent fuel pool level to El. Post-Fukushima order EA-12-051 required the installation of to (site-specific Level 2 value). 844.3' (Level 2) reliable SFP level indication capable of identifying normal level

[See Developer Notes] (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3).

Comanche Peak designated as Level 2 the water level 10 feet

(+/- 1.0 foot) above the top of the fuel racks (El 844'- 2.75" rounded to 844.3' indicated) 20 of 114 to TXX-15101 EAL Comparison Matrix Table R-2 SFP & Refueling Cavity Area Radiation Monitors SFP:

SFP001, LRAM SFP 2 E WALL (X-RE-6272)

" SFP002, LRAM SFP 2 N WALL (X-RE-6273)

SFP003, LRAM SFP 1 E WALL (X-RE-6274)

SFP004, LRAM SFP I S WALL (X-RE-6275)

Refueling Cavity:

" RFCulO, LRAM W REFUEL CAV860 (u-RE-6251)

" RFCu12, LRAM E REFUEL CAV 860 (u-RE-6253) 21 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

AA3 Radiation levels that impede RA3 Radiation levels that IMPEDE access None access to equipment necessary to equipment necessary for normal for normal plant operations, plant operations, cooldown or cooldown or shutdown shutdown MODE: All MODE: All NEI EALEx.

CPNPP NEI Example EAL Wording EAL # CPNPP EAL Wording Difference/Deviation Justification 1 Dose rate greater than 15 mR/hr RA3.1 Dose rates greater than 15 mR/hr in No other site-specific areas requiring continuous occupancy in ANY of the following areas: EITHER of the following areas: exist at CPNPP.

RoomControl Contrl RoomC Control48 (X-RE-6281)

(XRE-681) orr CRM49 CRM08 CR049 CRM048 (X-RE-6281) and CRM049 (X-RE-6282) are the installed CR ARMs.

Central Alarm Station (X-RE-6282)

(other site-specific OR The CAS does not have installed area radiation monitoring areas/rooms) Central Alarm Station (by survey) and thus must be determined by survey.

2 An UNPLANNED event results RA3.2 An UNPLANNED event results in The list of plant rooms or areas with entry-related mode in radiation levels that prohibit or radiation levels that prohibit or applicability identified specify those rooms or areas that impede access to any of the IMPEDE access to any Table R-3 contain equipment which require a manual/local action as following plant rooms or areas: rooms or areas (Note 5) specified in operating procedures used for normal plant (site-specific list of plant rooms operation, cooldown and shutdown.

or areas with entry-related mode applicability identified)

Note If the equipment in the listed N/A Note 5: If the equipment in the None room or area was already listed room or area was inoperable or out-of-service already inoperable or out-before the event occurred, then of-service before the event no emergency classification is occurred, then no warranted. emergency classification is warranted.

22 of 114 to TXX-15101 EAL Comparison Matrix Table R-3 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Applicability Charging Pump Rooms 1, 2, 3, 4, 5, 6 CVCS Valve Rooms 1, 2, 3, 4, 5, 6 1E Switchgear Rooms All RHR Pump Rooms 4, 5, 6 23 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPN#PP CPNPP IC Wording Difference/Deviation Justification IC#(s)

ASI Release of gaseous radioactivity RS1 Release of gaseous radioactivity None resulting in offsite dose greater resulting in offsite dose greater than than 100 mrem TEDE or 500 100 mrem TEDE or 500 mrem thyroid mrem thyroid CDE CDE MODE: All MODE: All MODE: All NEI Ex. NEI Example EAL Wording CAPN CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

Reading on ANY of the following RS1.1 Reading on any Table R-1 effluent The CPNPP radiation monitors that detect radioactivity radiation monitors greater than radiation monitor greater than column effluent release to the environment are listed in Table R-1.

the reading shown for 15 "SAE" for greater than or equal to 15 UE, Alert, SAE and GE thresholds for all CPNPP continuously minutes or longer: min. monitored gaseous and liquid release pathways are listed in (site-specific monitor list and (Notes 1, 2, 3, 4) Table R-1 to consolidate the information in a single location threshold values) and, thereby, simplify identification of the thresholds by the EAL-user.

2 Dose assessment using actual RS1.2 Dose assessment using actual The exclusion area boundary is the site-specific receptor meteorology indicates doses meteorology indicates doses greater point.

greater than 100 mrem TEDE or than 100 mrem TEDE or 500 mrem 500 mrem thyroid CDE at or thyroid CDE at or beyond the beyond (site-specific dose EXCLUSION AREA BOUNDARY receptor point) (Notes 3, 4) 3 Field survey results indicate RS1.3 Field survey results indicate EITHER The exclusion area boundary is the site-specific receptor EITHER of the following at or of the following at or beyond the point.

beyond (site-specific dose EXCLUSION AREA BOUNDARY:

receptor point): 0 Closed window dose rates

Closed window dose rates greater than 100 mR/hr greater than 100 mR/hr expected to continue for greater expected to continue for 60 than or equal to 60 min.

minutes or longer.

Analyses of field survey 0 Analyses of field survey samples indicate thyroid samples indicate thyroid CDE 24 of 114 to TXX-1 5101 EAL Comparison Matrix CDE greater than 500 greater than 500 mrem for 60 mrem for one hour of min. of inhalation.

inhalation. (Notes 1, 2)

Notes S The Emergency Director sotes ho dmecrgenytrecitere Note 1: The Emergency Coordinator The classification timeliness note has been standardized should declare the Site Area should declare the event across the CPNPP EAL scheme by referencing the "time limit" Emergency promptly upon promptly upon determining specified within the EAL wording.

determining that the that time limit has been applicable time has been exceeded, or will likely be exceeded, or will likely be exceeded, exceeded.

exceeded.

" If an ongoing release is Note 2: If an ongoing release is The classification timeliness note has been standardized detected and the release start detected and the release across the CPNPP EAL scheme by referencing the "time limit" time is unknown, assume that start time is unknown, specified within the EAL wording.

the release duration has assume that the release exceeded 15 minutes. duration has exceeded the

" If the effluent flow past an specified time limit.

effluent monitor is known to have stopped due to actions Note 3: If the effluent flow past an tohsoavestopped rae tactis effluent monitor is known to None to isolate the release path, have stopped, indicating that then the effluent monitor the release path is isolated, reading is no longer valid for the effluent monitor reading classification purposes. is no longer VALID for

The pre-calculated effluent classification purposes.

monitor values presented in Note 5 The pre-calculated effluent Incorporated site-specific EAL numbers associated with EAL #1 should be used for monitor values presented in generic EAL#1.

emergency classification EALs RAI.1, RS1.1 and assessments until the results RG1.1 should be used for from a dose assessment emergency classification using actual meteorology are assessments until the results available. from a dose assessment using actual meteorology are available.

25 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

AS2 Spent fuel pool level at (site- RS2 Spent fuel pool level at the top of the Top of the fuel racks is the site-specific Level 3 description.

specific Level 3 description) fuel racks MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 Lowering of spent fuel pool level RS2.1 Lowering of spent fuel pool level to El. Post-Fukushima order EA-12-051 required the installation of to (site-specific Level 3 value) 835.3' (Level 3) reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3).

Comanche Peak designated as Level 3 the water level greater than 1 foot above the top of the fuel storage racks plus the accuracy of the SFP level instrument channel (El. 835' - 2.75" rounded to 835.3' indicated).

26 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

AG1 Release of gaseous radioactivity RG1 Release of gaseous radioactivity None resulting in offsite dose greater resulting in offsite dose greater than 1,000 mrem TEDE or than 1,000 mrem TEDE or 5,000 5,000 mrem thyroid CDE. mrem thyroid CDE MODE: All MODE: All NEI EALEx. CPNPP Ex NEI Example EAL Wording EAL # CPNPP EAL Wording Difference/Deviation Justification I Reading on ANY of the following RG1.1 Reading on any Table R-1 effluent The CPNPP radiation monitors that detect radioactivity effluent radiation monitors greater than radiation monitor greater than release to the environment are listed in Table R-1. UE, Alert, SAE the reading shown for 15 column "GE" for greater than or and GE thresholds for all CPNPP continuously monitored gaseous minutes or longer: equal to 15 min. or liquid release pathways are listed in Table R-1 to consolidate the (site-specific monitor list and (Notes 1, 2, 3, 4) information in a single location and, thereby, simplify identification of threshold values) the thresholds by the EAL-user.

2 Dose assessment using actual RG1.2 Dose assessment using actual The exclusion area boundary is the site-specific receptor point.

meteorology indicates doses meteorology indicates doses greater than 1,000 mrem TEDE greater than 1000 mrem TEDE or or 5,000 mrem thyroid CDE at 5000 mrem thyroid CDE at or or beyond (site-specific dose beyond the EXCLUSION AREA receptor point). BOUNDARY (Notes 3, 4) 3 Field survey results indicate RGI .3 Field survey results indicate The exclusion area boundary is the site-specific receptor point.

EITHER of the following at or EITHER of the following at or beyond (site-specific dose beyond the EXCLUSION AREA receptor point): BOUNDARY:

e Closed window dose rates Closed window dose rates greater than 1,000 mR/hr greater than 1000 mR/hr expected to continue for 60 expected to continue for minutes or longer, greater than or equal to 60

Analyses of field survey min.

samples indicate thyroid CDE greater than 5,000 mrem for

Analyses of field survey 27 of 114 to TXX-15101 EAL Comparison Matrix one hour of inhalation. samples indicate thyroid CDE greater than 5000 mrem for 60 min. of inhalation.

(Notes 1, 2)

Notes " The Emergency Director Note 1: The Emergency The classification timeliness note has been standardized across the should declare the Site Area Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within Emergency promptly upon declare the event the EAL wording.

determining that the promptly upon applicable time has been determining that time exceeded, or will likely be limit has been exceeded. exceeded, or will likely be exceeded.

" If an ongoing release is The classification timeliness note has been standardized across the detected and the release Note 2: If an ongoing release is CPNPP EAL scheme by referencing the "time limit" specified within start time is unknown, detected and the the EAL wording.

assume that the release release start time is duration has exceeded 15 unknown, assume that minutes. the release duration has exceeded the specified

If the effluent flow past an time limit.

effluent monitor is known to have stopped due to actions Note 3: If the effluent flow past None to isolate the release path, an effluent monitor is then the effluent monitor known to have stopped, reading is no longer valid for indicating that the classification purposes. release path is isolated, the effluent monitor

The pre-calculated effluent reading is no longer monitor values presented in VALID for classification EAL #1 should be used for purposes.

emergency classification assessments until the results Note 5 The pre-calculated Incorporated site-specific EAL numbers associated with generic from a dose assessment effluent monitor values EAL#1.

using actual meteorology are presented in EALs available. RA1.1, RSI.1 and RG1.1 should be used for emergency classification assessments until the results from a dose 28 of 114 to TXX-15101 EAL Comparison Matrix assessment using actual meteorology are available.

29 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)

AG2 Spent fuel pool level cannot be RG2 Spent fuel pool level cannot be Top of the fuel racks is the site-specific Level 3 description.

restored to at least (site-specific restored to at least the top of the fuel Level 3 description) for 60 racks for 60 minutes or longer minutes or longer MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

I Spent fuel pool level cannot be RG2.1 Spent fuel pool level cannot be Post-Fukushima order EA-1 2-051 required the installation of restored to at least (site-specific restored to at least El. 835.3' (Level 3) reliable SFP level indication capable of identifying normal level Level 3 value) for 60 minutes or for greater than or equal to 60 min. (Level 1), SFP level 10 ft. above the top of the fuel racks longer (Note 1) (Level 2) and SFP level at the top of the fuel racks (Level 1).

Comanche Peak designated as Level 3 the water level greater than 1 foot above the top of the fuel storage racks plus the accuracy of the SFP level instrument channel (El. 835'- 2.75" rounded to 835.3' indicated).

Note The Emergency Director should N/A Note 1: The Emergency Coordinator The classification timeliness note has been standardized declare the General Emergency should declare the event across the CPNPP EAL scheme by referencing the "time limit" promptly upon determining that promptly upon determining specified within the EAL wording.

60 minutes has been exceeded, that time limit has been or will likely be exceeded. exceeded, or will likely be exceeded.

30 of 114 to TXX-15101 EAL Comparison Matrix Category C Cold Shutdown / Refueling System Malfunction 31 of 114 to TXX-15101 EAL Comparison Matrix CPNPP NEI IC# NEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification CU1 UNPLANNED loss of (reactor CUl UNPLANNED loss of RCS None vessel/RCS [PWR] or RCP inventory for 15 minutes or

[BWR]) inventory for 15 minutes longer or longer. MODE: 5 - Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling NEI EALEx.

NEI Example EAL Wording CPNPP EAL # CPNPP EAL Wording Difference/Deviation Justification 1 UNPLANNED loss of reactor CUI.1 UNPLANNED loss of reactor None coolant results in (reactor coolant results in RCS water vessel/RCS [PWR] or RCP level less than a required lower

[BWR]) level less than a limit for greater than or equal to required lower limit for 15 15 min. (Note 1) minutes or longer.

2 a. (Reactor vessel/RCS [PWR] CU1.2 RCS water level cannot be monitored Table C-1 provides a tabularized list of site-specific applicable smsadtns or RCP [BWR]) level cannot AND EITHER sumps and tanks.

be monitored. Added bulleted criteria "Visual observation of UNISOLABLE RCS AND ° UNPLANNED increase in leakage" to include direct observation of RCS leakage.

any Table C-1 sump/tank

b. UNPLANNED increase in level due to loss of RCS (site-specific sump and/or inventory tank) levels.

Visual observation of UNISOLABLE RCS leakage Note The Emergency Director N/A Note 1: The Emergency The classification timeliness note has been standardized across the should declare the Unusual Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within Event promptly upon declare the event the EAL wording.

determining that 15 minutes promptly upon has been exceeded, or will determining that time likely be exceeded. limit has been exceeded, or will likely 32 of 114 to TXX-15101 EAL Comparison Matrix I I I be exceeded.II Table C-1 Sumps/Tanks

Containment Sump 1

Containment Sump 2

Reactor Cavity Sump

CCW Surge Tank A

CCWSurgeTankB

PRT

RCDT 33 of 114 to TXX-1 5101 EAL Comparison Matrix CPNPP NEI IC# NEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification CU2 Loss of all but one AC power CU2 Loss of all but one AC power "Safeguard" is the site-specific term for emergency buses.

source to emergency buses for source to safeguard buses for 15 15 minutes or longer. minutes or longer.

MODE: Cold Shutdown, MODE: 6 - Cold Shutdown, Refueling, Defueled Refueling, Defueled NE! Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 a. AC power capability to (site- CU2.1 AC power capability, Table C-3, 6.9KV safeguard buses uEA1 and uEA2 are the emergency buses.

specific emergency buses) is to 6.9 KV safeguard buses uEA1 Site-specific AC power sources are tabularized in Table C-3.

reduced to a single power and uEA2 reduced to a single source for 15 minutes or power source for greater than or longer, equal to 15 min.

AND (Note 1)

AND

b. Any additional single power source failure loss of all AC will result power in toAnadioalsgeTbeC- Any additional single Table C-3 SAFETY SYSTE MS. power source failure will result in loss of all AC power to SAFETY SYSTEMS Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within promptly upon determining that declare the event the EAL wording.

15 minutes has been exceeded, promptly upon or will likely be exceeded. determining that time limit has been exceeded, or will likely be exceeded.

34 of 114 to TXX-1 5101 EAL Comparison Matrix Table C-3 AC Power Sources Offsite:

0 138 KV switchyard circuit a 345 KV switchyard circuit Onsite:

" uEGI

" uEG2 35 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)

CU3 UNPLANNED increase in RCS CU3 UNPLANNED increase in RCS None temperature temperature MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

I UNPLANNED increase in RCS CU3.1 UNPLANNED increase in RCS 200'F is the site-specific Tech. Spec. cold shutdown temperature temperature to greater than (site- temperature to greater than limit.

specific Technical Specification 200°F due to loss of decay heat Added "due to loss of decay heat removal capability" to reinforce the cold shutdown temperature limit) removal capability (Note 9) generic bases that states "EAL #1 involves a loss of decay heat removal capability" 2 Loss of ALL RCS temperature CU3.2 Loss of all RCS temperature and None and (reactor vessel/RCS [PWR] RCS level indication for greater or RCP [BWR]) level indication than or equal to 15 min. (Note 1) for 15 minutes or longer.

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within promptly upon determining that declare the event the EAL wording.

15 minutes has been exceeded, promptly upon or will likely be exceeded determining that time limit has been exceeded, or will likely be exceeded.

N/A N/A N/A Note 9: Begin monitoring hot Added note to remind end-user that the hot condition EALs become condition EALs applicable once operating mode changes to hot conditions.

concurrently.

36 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)

CU4 Loss of Vital DC power for 15 CU4 Loss of vital DC power for 15 None minutes or longer. minutes or longer.

MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 -

Refueling Refueling NEI EALEx.

NEICPNPP NIEapeALWrig EAL # CPNPP EAL Wording Difference/Deviation Justification 1 Indicated voltage is less than CU4.1 Less than 105 VDC bus voltage 105 VDC is the site-specific minimum vital DC bus voltage.

(site-specific bus voltage value) indications on Technical DC operability requirements are specified in Technical on required Vital DC buses for 15 Specification required 125 VDC Specifications.

minutes or longer, buses (uED1, uED2, uED3, uED4) for greater than or equal to 15 min. (Note 1)

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within promptly upon determining that declare the event promptly the EAL wording.

15 minutes has been exceeded, upon determining that or will likely be exceeded. time limit has been exceeded, or will likely be exceeded.

37 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

CU5 Loss of all onsite or offsite CU5 Loss of all onsite or offsite None communications capabilities, communications capabilities.

MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling, Defueled Refueling, Defueled NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

I Loss of ALL of the following CU5.1 Loss of all Table C-5 onsite Example EALs #1, 2 and 3 have been combined into a single onsite communication methods: communication methods EAL for simplification of presentation.

OR (site specific list of Loss of all Table C-5 offsite Table C-5 provides a site-specific list of onsite, offsite (ORO) and communications methods) communication methods NRC communications methods.

OR 2 Loss of ALL of the following ORO Loss of all Table C-5 NRC communications methods: communication methods (site specific list of communications methods) 3 Loss of ALL of the following NRC communications methods:

(site specific list of communications methods) 38 of 114 to TXX-15101 EAL Comparison Matrix Table C-5 Communication Methods System Onsite Offsite NRC Gai-tronics Page/Party (PA) X Plant Radios X PABX X X X Public Telephone X X X Federal Telephone System (FTS) X X 39 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification CA1 Loss of (reactor vessel/RCS CA1 Loss of RCS inventory None

[PWR] or RCP [BWR]) inventory MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

I Loss of (reactor vessel/RCS CAl. 1 Loss of RCS inventory as RCS level less than 48 in. above upper core plate (top) is the site-

[PWR] or RCP [BWR]) inventory indicated by RCS level less than specific reactor vessel level corresponding to potential RHR pump as indicated by level less than 48 in. above upper core plate cavitation in the shutdown cooling mode..

(site-specific level). (top) 2 a. (Reactor vessel/RCS [PWR] CA1.2 RCS water level cannot be Table C-1 provides a tabularized list of site-specific applicable sumps or RCP [BWR]) level cannot monitored for greater than or and tanks.

be monitored for 15 minutes equal to 15 min. (Note 1) Added bulleted criteria "Visual observation of UNISOLABLE RCS or longer AND EITHER leakage" to include direct observation of RCS leakage.

AND 9UNPLANNED increase in

b. UNPLANNED increase in any Table C-1 sump/tank (site-specific sump and/or level due to a loss of RCS tank) levels due to a loss of inventory (reactor vessel/RCS [PWR]

Visual observation of or RCP [BWR]) inventory. UNISOLABLE RCS leakage Note The Emergency Director should N/A Note 1:The Emergency The classification timeliness note has been standardized across the declare the Alert promptly upon Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within determining that 15 minutes has declare the event the EAL wording.

been exceeded, or will likely be promptly upon exceeded determining that time limit has been exceeded, or will likely be exceeded.

40 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

CA2 Loss of all offsite and all onsite CA2 Loss of all offsite and all onsite "Safeguard" is the site-specific term for emergency buses.

AC power to emergency buses AC power to safeguard buses for 15 minutes or longer for 15 minutes or longer.

MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling, Defueled Refueling, Defueled NEI EALEx.

NEI Example EAL Wording CPNPP EAL # CPNPP EAL Wording Difference/Deviation Justification I Loss of ALL offsite and ALL CA2.1 Loss of all offsite and all onsite 6.9KV safeguard buses uEA1 and uEA2 are the site-specific onsite AC Power to (site-specific AC power capability, Table C-3, emergency buses.

emergency buses) for 15 to 6.9 KV safeguard buses Site-specific AC power sources are tabularized in Table C-3.

minutes or longer. uEA1 and uEA2 for greater than or equal to 15 min. (Note 1)

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within promptly upon determining that declare the event the EAL wording.

15 minutes has been exceeded, promptly upon or will likely be exceeded. determining that time limit has been exceeded, or will likely be exceeded.

41 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)

CA3 Inability to maintain the plant in CA3 Inability to maintain the plant in None cold shutdown. cold shutdown.

MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording bifference/Deviation Justification EAL # EAL #

1 UNPLANNED increase in RCS UNPLANNED increase in RCS Example EALs #1 and #2 have been combined into a single EAL temperature to greater than temperature to greater than as EAL # is the alternative threshold based on a loss of RCS (site-specific Technical 200OF for greater than Table C- temperature indication.

Specification cold shutdown 4 duration 200'F is the site-specific Tech. Spec. cold shutdown temperature temperature limit) for greater (Note 1, 9) limit.

than thanthe the duration specified in follo iong tle. Cn OR Table C-4 is the site-specific implementation of the generic RCS the following table. CA3.1 Heat-up Duration Threshold table.

2 UNPLANNED RCS pressure increase greater than 10 psig 10 psig is the site-specific pressure increase readable by Control increase greater than (site- due to a loss of RCS cooling Room indications.

specific pressure reading). (This EAL does not apply (This EAL does not apply during during water-solid plant water-solid plant conditions, conditions)

[PWR])

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within promptly upon determining that declare the event the EAL wording.

15 minutes has been exceeded, promptly upon or will likely be exceeded. determining that time limit has been exceeded, or will likely be exceeded.

42 of 114 to TXX-1 5101 EAL Comparison Matrix N/A N/A Note 9: Begin monitoring hot Added note to remind end-user that the hot condition EALs become condition EALs applicable once operating mode changes to hot conditions.

concurrently.

Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Status Heat-up Duration Intact (but not at reduced Not applicable 60 minutes*

inventory [PWR])

Not intact (or at reduced Established 20 minutes*

inventory [PWR]) Not Established 0 minutes

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

Table C-4: RCS Heat-up Duration Thresholds RCS Status CONTAINMENT CLOSURE Heat-up Duration Status Intact (but not REDUCED N/A 60 mi.*

INVENTORY)

Not intact Established 20 min.*

OR REDUCED INVENTORY Not established 0 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.

43 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

CA6 Hazardous event affecting a CA6 Hazardous event affecting a None SAFETY SYSTEM needed for SAFETY SYSTEM needed for the current operating mode. the current operating mode.

MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling 44 of 114 to TXX-15101 EAL Comparison Matrix NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

a. The occurrence of ANY of CA6.1 The occurrence of any Table The hazardous events have been tabularized in Table C-6.

the following hazardous C-6 hazardous event Replaced "Shift Manager" with "Emergency Coordinator" as the EC

Seismic event AND EITHER: can be either the SM or augmented ERO EC.

(earthquake) e Event damage has caused

Internal or external intdcation of d aded flooding event degraded indications of in

High winds or tornado performance at least one strike train of a SAFETY SYSTEM stFIRE needed for the current

EXPLOSION operating mode

(site-specific hazards) e The event has caused

Other events with similar VISIBLE DAMAGE to a hazard characteristics as SAFETY SYSTEM determined by the Shift component or structure Manager needed for the current AND operating mode

b. EITHER of the following:

1. Event damage. has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.

OR

2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.

45 of 114 to TXX-15101 EAL Comparison Matrix Table C-6 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 Emergency Coordinator 46 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

CS1 Loss of (reactor vessel/RCS CS1 Loss of RCS inventory affecting None

[PWR] or RCP [BWR]) inventory core decay heat removal affecting core decay heat capability removal capability. MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 a. CONTAINMENT CLOSURE CS1.1 With CONTAINMENT When RCS level less than 27.25 in. (rounded to 27.3 for instrument not established. CLOSURE not established, readability) above upper core plate (top), water level is six inches AND RCS level less than 27.3 in. below the elevation of the bottom of the RCS hot leg penetration.

above upper core plate (top)

b. (Reactor vessel/RCS [PWR]

or RCP [BWR]) level less than (site-specific level).

2 a. CONTAINMENT CLOSURE CS1.2 With CONTAINMENT When Reactor Vessel water level drops to or below 0 in. above upper established. CLOSURE established, RCS core plate (top) 823'-0" elevation, core uncovery is about to occur.

AND level less than or equal to 0 in.

above upper core plate (top)

b. (Reactor vessel/RCS [PWR]

or RCP [BWR]) level less than (site-specific level).

3 a. (Reactor vessel/RCS [PWR] CS1.3 RCS water level cannot be Table C-1 provides a tabularized list of site-specific applicable sumps or RCP [BWR]) level cannot monitored for greater than or and tanks.

be monitored for 30 minutes equal to 30 mn.(Note 1) Containment HRRM greater than 20,000 mR/hr would be indicative AND Core. uncovery iof AND Core uNce is indicated by possible core uncovery in the Refueling mode.

any of the following:

b. Core uncovery is indicated by

UNPLANNED increase in ANY of the following: any Table C-1 sump/tank 47 of 114 to TXX-1 5101 EAL Comparison Matrix

" (Site-specific radiation level of sufficient magnitude monitor) reading greater to indicate core uncovery than (site-specific value)

Erratic Source Range

" Erratic source range Monitor indication monitor indication [PWR]

greater than 20,000 R/hr on

" UNPLANNED increase in any of the following:

(site-specific sump and/or tank) levels of sufficient - CTEu16, Containment magnitude to indicate HRRM (u-RE-6290A) core uncovery - CTWu17, Containment

" (Other site-specific HRRM (u-RE-6290B) indications)

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Site Area Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within Emergency promptly upon declare the event the EAL wording.

determining that 30 minutes has promptly upon been exceeded, or will likely be determining that time exceeded limit has been exceeded, or will likely be exceeded.

48 of 114 to TXX-15101 EAL Comparison Matrix NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification Loss of (reactor vessel/RCS CG1 Loss of RCS inventory affecting None

[PWR] or RCP [BWR]) inventory fuel clad integrity with affecting fuel clad integrity with containment challenged containment challenged MODE: Cold Shutdown, MODE: Cold Shutdown, Refueling Refueling NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL IIEAL #

a. (Reactor vessel/RCS [PWR] or CGI.1 RCS level less than or equal to 0 When Reactor Vessel water level drops to or below 0 in. above RCP [BWR]) level less than in. above upper core plate (top) upper core plate (top) 823'-0" elevation, core uncovery is about to (site-specific level) for 30 for greater than or equal to 30 occur.

minutes or longer. min. (Note 1)

AND AND Table C-2 provides a tabularized list of containment challenge

b. ANY indication from the indications.

Containment Challenge Table Any Containment Challenge (see below), indication, Table C-2 2 a. (Reactor vessel/RCS [PWR] or CG1.2 RCS water level cannot be Table C-1 provides a tabularized list of site-specific applicable RCP [BWR]) level cannot be monitored for greater than or sumps and tanks.

monitored for 30 minutes or equal to 30 min. (Note 1) Containment HRRM greater than 20,000 mR/hr would be indicative longer. AND of possible core uncovery in the Refueling mode.

AND Core uncovery is indicated by any of the following: Table C-2 provides a tabularized list of containment challenge

b. Core uncovery is indicated by UNPLANNED increase indications.

ANY of the following: in any Table C-1 4% hydrogen concentration in the presence of oxygen represents 0 (Site-specific radiation sump/tank level of an explosive mixture in containment.

monitor) reading greater sufficient magnitude to Specified a 1 psig pressure rise as minimum observable than (site-specific value) indicate core uncovery containment pressure increase.

Erratic source range Erratic Source Range monitor indication [PWR] Monitor indication

UNPLANNED increase in Greater than 20,000 R/hr 49 of 114 to TXX-15101 EAL Comparison Matrix (site-specific sump and/or on any of the following:

tank) levels of sufficient - CTEu16, Containment magnitude to indicate core HRRM (u-RE-6290A) uncovery

- CTWu17, Containment e (Other site-specific HRRM (u-RE-6290B) indications)

AND AND Any Containment Challenge

c. ANY indication from the indication, Table C-2 Containment Challenge Table (see below).

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across declare the General Emergency Coordinator should the CPNPP EAL scheme by referencing the "time limit" specified promptly upon determining that declare the event within the EAL wording.

30 minutes has been exceeded, promptly upon or will likely be exceeded. determining that time limit has been exceeded, or will likely be exceeded.

Note 6: If CONTAINMENT Note 6 implements the asterisked note associated with the generic N/A CLOSURE is re-established prior to Containment Challenge table.

exceeding the 30-minute time limit, declaration of a General Emergency is not required.

Containment Challenge Table

" CONTAINMENT CLOSURE not established*

(Explosive mixture) exists inside containment

UNPLANNED increase in containment pressure E Secondary containment radiation monitor reading above (site-specific value) [BWR]

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

50 of 114 to TXX-15101 EAL Comparison Matrix Table C-2 Containment Challenge Indications

CONTAINMENT CLOSURE not established (Note 6)

" Containment hydrogen concentration greater than 4%

Unplanned rise greater than 1 psig in Containment pressure 51 of 114 to TXX-15101 EAL Comparison Matrix Category D Permanently Defueled Station Malfunction 52 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

PD-AU1 Recognition Category D N/A N/A NEI Recognition Category PD ICs and EALs are applicable only to PD-AU2 Permanently Defueled Station permanently defueled stations. CPNPP is not a defueled station.

PD-SU1 PD-HU1 PD-HU2 PD-HU3 PD-AA1 PD-AA2 PD-HA1 PD-HA3 53 of 114 to TXX-1 5101 EAL Comparison Matrix Category E Independent Spent Fuel Storage Installation 54 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)

E-HU1 Damage to a loaded cask EU1 Damage to a loaded cask None CONFINEMENT BOUNDARY CONFINEMENT BOUNDARY MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

I Damage to a loaded cask EU1.1 Damage to a loaded cask The specified dose rate represents 2 times the cask technical CONFINEMENT BOUNDARY as CONFINEMENT BOUNDARY specification allowable levels per the ISFSI Technical Specifications indicated by an on-contact as indicated by an on-contact (CoC).

radiation reading greater than (2 radiation reading greater than times the site-specific cask EITHER:

specific technical specification allowable radiation level) on the 60 t mrem/hr (v + rp)on the surface of the spent fuel cask. top of the overpack o 600 mrem/hr (-r + rj on the side of the overpack (excluding inlet and outlet ducts) 55 of 114 to TXX-1 5101 EAL Comparison Matrix Category F Fission Product Barrier Degradation 56 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

FAl Any Loss or any Potential Loss of FA1 Any loss or any potential loss of None either the Fuel Clad or RCS either Fuel Clad or RCS barrier. MODE: 1 - Power Operation, 2 -

MODE: Power Operation, Hot Startup, 3 - Hot Standby, 4 - Hot Standby, Startup, Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 Any Loss or any Potential Loss FAI.1 Any loss or any potential loss of Table F-1 provides the fission product barrier loss and potential loss of either the Fuel Clad or RCS either Fuel Clad or RCS (Table thresholds.

barrier. F-i) 57 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

FS1 Loss or Potential Loss of any two FS1 Loss or potential loss of any two None barriers barriers MODE: Power Operation, Hot MODE: 1 - Power Operation, 2 -

Standby, Startup, Hot Shutdown Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 Loss or Potential Loss of any two FS1.1 Loss or potential loss of any two Table F-1 provides the fission product barrier loss and potential loss barriers barriers thresholds.

58 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

FG1 Loss of any two barriers and FG1 Loss of any two barriers and loss None Loss or Potential Loss of third or potential loss of the third barrier barrier MODE: Power Operation, Hot MODE: 1 - Power Operation, 2 -

Standby, Startup, Hot Shutdown Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL #

Loss of any two barriers and FG1.1 Loss of any two barriers Table F-1 provides the fission product barrier loss and potential loss Loss or Potential Loss of third thresholds.

barrier AND Loss or potential loss of the third barrier (Table F-i) 59 of 114 to TXX-1 5101 EAL Comparison Matrix PWR Fuel Clad Fission Product Barrier Degradation Thresholds NEI CPNPP NEI NEI Threshold Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FPB #(s)

FC Loss RCS or SG Tube Leakage N/A N/A N/A 1 Not Applicable FC Loss Inadequate Heat Removal FC Loss CSFST Core Cooling-RED Consistent with the generic developers note options CSFST Core 2 A. Core exit thermocouple 1.1 Path conditions met Cooling Red Path is used in lieu of CET temperatures.

readings greater than (site-specific temperature value).

FC Loss RCS Activity/CMNT Rad FC Loss Containment radiation greater CTEu16 Containment HRRM (u-RE-6290A) or CTWu17 than 85 R/hr Containment HRRM (u4-RE-6290B) are the site-specific containment 3 A. Containment radiation C.1 CTEu16 Containment HRRM high range radiation monitors. The specified monitors and values monitor reading greater than (u-RE-6290A), or are containment radiation monitor readings corresponding to 2%

(site-specific value) CTWuI 7 Containment HRRM clad failures.

OR (u-RE-6290B)

B. (Site-specific indications that reactor coolant activity is greater than 300 l.LCi/gm dose FC Loss Dose equivalent 1-131 coolant Site-specific units for DEl is pCi/cc.

equivalent 1-131) C.2 activity greater than 300 pCi/cc FC Loss CNMT Integrity or Bypass N/A N/A N/A 4 Not Applicable FC Loss Other Indications FC Loss Gross Failed Fuel Monitor, The Gross Failed Fuel Monitor threshold of 1.0E04 pCi/ml A. (site-specific as applicable) C.3 FFLju60 (u_-RE-0406), radiation represents approximately 2% fuel clad failure.

greater than I.0E04 pCi/ml 60 of 114 to TXX-15101 EAL Comparison Matrix NE!

NPI CPNPP NEI Threshold Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FPB #(s)

FC Loss ED Judgment FC Loss Any condition in the opinion of None the Emergency Coordinator A. ANY condition in the E.1 that indicates loss of the fuel opinion of the Emergency ca are Director that indicates Loss of clad barrier the Fuel Clad Barrier.

FC RCS or SG Tube Leakage N/A N/A See FC P-Loss B.1. The RCS level threshold is implemented as P-Loss A. RCS/reactor vessel level CSFST Core Cooling Orange Path conditions met.

1 less than (site-specific level)

FC Inadequate Heat Removal FC CSFST Core Cooling- Consistent with the generic developers note options CSFST Core P-LossP-os A. Core exit thermocouple B.1 P-Loss ORANGE Path conditions met Cooling Orange Path is used in lieu of CET temperatures.

2 readings greater than (site-specific temperature value)

OR FC CSFST Heat Sink-RED Path Consistent with the generic developers note options CSFST Heat B. Inadequate RCS heat P-Loss conditions met Sink Red Path is used.

removal capability via steam B.2 AND The phrase "and heat sink required" was added to preclude the generators as indicated by Heat sink is required need for classification for conditions in which RCS pressure is less (site-specific indications). than SG pressure or Heat Sink-RED path entry was created through operator action directed by an EOP.

FC RCS Activity/CMNT Rad N/A N/A N/A P-Loss Not Applicable 3

FC CNMT Integrity or Bypass N/A N/A N/A P-Loss Not Applicable 4

FC Other Indications N/A N/A No other site-specific Fuel Clad Potential Loss indication has been P-Loss identified for CPNPP.

A. (site-specific as applicable) 5 61 of 114 to TXX-1 5101 EAL Comparison Matrix NEI FPB CPNPP NEI Threshold Wording FPB #(s) CPNPP FPB Wording Difference/Deviation Justification FPB# FPB FC Emergency Director FC Any condition in the opinion of None P-Loss Judgment P-Loss the Emergency Coordinator that 6 A. Any condition in the opinion E.1 indicates potential loss of the fuel clad barrier of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.

62 of 114 to TXX-15101 EAL Comparison Matrix PWR RCS Fission Product Barrier Degradation Thresholds NEI NEI CPNPP NEI IC Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FP13 #(s)

RCS RCS or SG Tube Leakage RCS Loss An automatic or manual None Loss A. An automatic or manual A.1 ECCS (SI) actuation required I ECCS (SI) actuation is by EITHER:

required by EITHER of the

UNISOLABLE RCS following: leakage

1. UNISOLABLE RCS

SG tube RUPTURE leakage OR

2. SG tube RUPTURE.

RCS Inadequate Heat Removal N/A N/A N/A Loss Not Applicable 2

RCS RCS Activity/CMNT Rad RCS Loss Containment radiation greater CTEu16 Containment HRRM (u-RE-6290A) or CTWu17 Loss A. Containment radiation C.1 than 5 R/hr Containment HRRM (u-RE-6290B) are the site-specific 3 monitor reading greater than CTEu16 Containment HRRM containment high range radiation monitors. The specified monitors (site-specific value). (nu-RE-6290A),or and values are containment radiation monitor readings CTWu17 Containment HRRM corresponding to TS limit coolant activity.

(u-RE-6290B)

RCS CNMT Integrity or Bypass N/A N/A N/A Loss Not Applicable 4

RCS Other Indications N/A N/A No other site-specific RCS Loss indication has been identified for Loss CPNPP.

A. (site-specific as applicable) 5 63 of 114 to TXX-15101 EAL Comparison Matrix NEI NEI CPNPP NEI IC Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FPB #(s)

RCS Emergency Director Judgment RCS Loss Any condition in the opinion None Loss Los Aof A. ANY condition in the opinion E.1 thattheindicates Emergency loss Coordinator of the RCS of the Emergency Director that barrier 6

indicates Loss of the RCS Barrier.

RCS RCS or SG Tube Leakage RCS Operation of a standby None P-Loss 1 A. Operation of a standby P-Loss A.1 charging pump is required by charging (makeup) pump is EITHER:

required by EITHER of the 9 UNISOLABLE RCS following: leakage

1. UNISOLABLE RCS

SG tube leakage leakage OR RCS CSFST Integrity-RED Path Consistent with the generic developers note options CSFST

2. SG tube leakage. P-Loss A.2 conditions met Integrity Red Path is used.

OR B. RCS cooldown rate greater than (site-specific pressurized thermal shock criteria/limits defined by site-specific indications).

RCS Inadequate Heat Removal RCS CSFST Heat Sink-RED Path Consistent with the generic developers note options CSFST Heat P-Loss B.1 conditions met Sink Red Path is used.

P-Loss 2 A. Inadequate RCS heat AND removal capability via steam The phrase "and heat sink required" was added to preclude the generators as indicated by Heat sink is required need for classification for conditions in which RCS pressure is less (site-specific indications), than SG pressure or Heat Sink-RED path entry was created through operator action directed by an EOP.

RCS CS Activity/IMNT Rad N/A N/A N/A P-Loss 3 Not Applicable 64 of 114 to TXX-1 5101 EAL Comparison Matrix NEI NEI IC Wording CPNPP FPB Wording Difference/Deviation Justification FPB#

RCS CNMT Integrity or Bypass N/A N/A P-Loss 4 Not Applicable RCS Other Indications N/A No other site-specific RCS Potential Loss indication has been identified for CPNPP.

P-Loss 5 A. (site-specific as applicable)

RCS Emergency Director Judgment RCS Any condition in the opinion of None P-Loss E.1 the Emergency Coordinator that P-Loss 6 A. ANY condition in the opinion indicates potential loss of the of the Emergency Director that RCS barrier indicates Potential Loss of the RCS Barrier.

65 of 114 to TXX-15101 EAL Comparison Matrix PWR Containment Fission Product Barrier Degradation Thresholds NEI NEI CPNPP NEI IC Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FPB #(s)

CNMT RCS or SG Tube Leakage CNTMT A leaking or RUPTURED SG is None Loss A A leaking or RUPTURED SG is A. Loss FAULTED outside of containment 1 FAULTED outside of containment. A.1 CNMT Inadequate Heat Removal N/A N/A N/A Loss Not Applicable 2

CNMT RCS Activity/CMNT Rad N/A N/A N/A Loss Not applicable 3

CNMT CNMT Integrity or Bypass CNTMT Containment isolation is required None Loss Loss A. Containment isolation is required AND EITHER:

4 D.1 AND " Containment integrity has been EITHER of the following: lost based on Emergency Coordinator judgment

1. Containment integrity has been lost based on Emergency

UNISOLABLE pathway from Director judgment. Containment to the environment exists OR

2. UNISOLABLE pathway from CNTMT Indications of RCS leakage outside of None the containment to the Loss containment environment exists. D.2 OR B. Indications of RCS leakage outside of containment.

66 of 114 to TXX-15101 EAL Comparison Matrix NE!

FPB CPNPP NEI IC Wording FPB CPNPP FPB Wording Difference/Deviation Justification FPB# FPB #(s)

CNMT Other Indications N/A N/A No other site-specific Containment Loss indication has Loss A. (site-specific as applicable) been identified for CPNPP.

5 CNMT Emergency Director Judgment CNTMT Any condition in the opinion of the None Loss 6 ANY condition in the opinion of the NYcntinnthopnoofteloss Loss Emergency Coordinator barrier of the containment that indicates Emergency Director that indicates Loss E.1 of the Containment Barrier.

CNMT RCS or SG Tube Leakage N/A N/A N/A P-Loss Not Applicable CNMT Inadequate Heat Removal CNTMT CSFST Core Cooling-RED Path Consistent with the generic developers note options P-Loss P-Loss conditions met CSFST Core Cooling Red Path is used in lieu of CET A. 1. (Site-specific criteria for entry AND temperatures and RCS levels.

2 into core cooling restoration B.1 procedure) Restoration procedures not effective Added Note 1 consistent with other thresholds with a AND within 15 min. (Note 1) timing component.

2. Restoration procedure not effective within 15 minutes.

CNMT RCS Activity/CMNT Rad CNTMT Containment radiation greater than CTEu16 Containment HRRM (u-RE-6290A) or P-Loss A. Containment radiation monitor P-Loss 1,110 R/hr CTWu17 Containment HRRM (u-RE-6290B) are the 3reading greater than (site-specific C. CTEu16 Containment HRRM (u-RE- site-specific containment high range radiation value). 6290A), or monitors. The specified monitors and values are CTWu17 Containment HRRM (u-RE- containment radiation monitor readings corresponding 6290B) to 20% clad damage.

CNMT CNTMT Integrity or Bypass CNTMT CSFST Containment-RED Path Consistent with the generic developers note options P-Loss A. Containment pressure greater than P-Loss conditions met CSFST Containment Red Path is used in lieu of 4 (site-specific value) D.1 containment pressure.

67 of 114 to TXX-15101 EAL Comparison Matrix NEI CPNPP NEB NEI IC Wording FPB #(s) CPNPP FPB Wording Difference/Deviation Justification FPB# FPB OR CNTMT Containment hydrogen concentration 4% hydrogen concentration in the presence of oxygen B. Explosive mixture exists inside P-Loss greater than 4% represents an explosive mixture in containment.

containment D.2 OR C. 1. Containment pressure greater than (site-specific pressure setpoint) CNTMT Containment pressure greater than 18 The Containment pressure setpoint (18 psig) is the AND P-Loss psig with neither Containment Spray pressure at which the Containment Spray System

2. Less than one full train of (site- D.3 system train operating per design for should actuate and begin performing its function.

specific system or equipment) greater than or equal to 15 min. (Note Added Note 1 consistent with other thresholds with a is operating per design for 15 1 timing component.

minutes or longer.

CNMT Other Indications N/A N/A No other site-specific Containment Potential Loss P-Loss A. (site-specific as applicable) indication has been identified for CPNPP.

5 CNMT Emergency Director Judgment CNTMT Any condition in the opinion of the None P-Loss A. ANY condition in the opinion of the P-Loss Emergency Coordinator that indicates 6 Emergency Director that indicates E.1 potential loss of the containment Potential Loss of the Containment barrier Barrier.

68 of 114 to TXX-1 5101 EAL Comparison Matrix Category H Hazards and Other Conditions Affecting Plant Safety 69 of 114 to TXX-1 5101 EAL Comparison Matrix NEI NEI IC Wording CPNPP IC# IC#(s)

IC#(s) CPNPP IC Wording Difference/Deviation Justification HU1 Confirmed SECURITY HU1 Confirmed SECURITY None CONDITION or threat CONDITION or threat.

MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 A SECURITY CONDITION that HU1.1 A SECURITY CONDITION that The security shift supervision is defined as the Security Shift does not involve a HOSTILE does not involve a HOSTILE Supervisor ACTION as reported by the (site- ACTION as reported by the specific security shift supervision). Security Shift Supervisor 2 Notification of a credible security HU1.2 Notification of a credible security None threat directed at the site. threat directed at the site 3 A validated notification from the HU1.3 A validated notification from the None NRC providing information of an NRC providing information of an aircraft threat. aircraft threat 70 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

HU2 Seismic event greater than OBE HU2 Seismic event greater than OBE None level level MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 Seismic event greater than HU2.1 Seismic event greater than OBE The CPNPP OBE indicators are either annunciator 2A-3.1, OBE Operating Basis Earthquake as indicated by annunciator 2A- EXCEEDED, or yellow OBE light on Seismic Monitoring system (OBE) as indicated by: ' 3.1, OBE EXCEEDED, or yellow panel (site-specific indication that a OBE light on Seismic Monitoring seismic event met or exceeded system panel OBE limits) 71 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)

HU3 Hazardous event. HU3 Hazardous event None MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 A tornado strike within the HU3.1 A tornado strike within the None PROTECTED AREA. PROTECTED AREA 2 Internal room or area flooding of a HU3.2 Internal room or area FLOODING None magnitude sufficient to require of a magnitude sufficient to manual or automatic electrical require manual or automatic isolation of a SAFETY SYSTEM electrical isolation of a SAFETY component needed for the current SYSTEM component needed for operating mode. the current operating mode 3 Movement of personnel within the HU3.3 Movement of personnel within the None PROTECTED AREA is impeded PROTECTED AREA is due to an offsite event involving IMPEDED due to an offsite event hazardous materials (e.g., an involving hazardous materials offsite chemical spill or toxic gas (e.g., an offsite chemical spill or release). toxic gas release) 4 A hazardous event that results in HU3.4 A hazardous event that results in Added reference to Note 7.

on-site conditions sufficient to on-site conditions sufficient to prohibit the plant staff from prohibit the plant staff from accessing the site via personal accessing the site via personal vehicles. vehicles (Note 7) 5 (Site-specific list of natural or N/A N/A No other site-specific hazard has been identified for CPNPP.

technological hazard events)

Note EAL #3 does not apply to routine N/A Note 7: This EAL does not This note, designated Note #7, is intended to apply to generic traffic impediments such as fog, apply to routine traffic example EAL #4, not #3 as specified in the generic guidance.

72 of 114 to TXX-15101 EAL Comparison Matrix snow, ice, or vehicle breakdowns impediments such as or accidents. fog, snow, ice, or vehicle breakdowns or accidents.

73 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

HU4 FIRE potentially degrading the HU4 FIRE potentially degrading the None level of safety of the plant. level of safety of the plant MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

a. A FIRE is NOT extinguished HU4.1 A FIRE is not extinguished Table H-1 provides a tabularized list of site-specific fire areas.

within 15-minutes of ANY of the within 15 min. of any of the following FIRE detection following FIRE detection indications: indications (Note 1):

" Report from the field (i.e.,

Report from the field (i.e.,

visual observation) visual observation)

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

" Field verification of a single

Field verification of a single fire alarm fire alarm AND AND

b. The FIRE is located within The FIRE is located within any ANY of the following plant rooms Table H-1 area or areas:

(site-specific list of plant rooms or areas) 2 a. Receipt of a single fire alarm HU4.2 Receipt of a single fire alarm Table H-1 provides a tabularized list of site-specific fire areas.

(i.e., no other indications of a (i.e., no other indications of a FIRE). FIRE)

AND AND I b. The FIRE is located within The fire alarm is indicating a 74 of 114 to TXX-1 5101 EAL Comparison Matrix ANY of the following plant rooms FIRE within any Table H-1 area or areas: AND (site-specific list of plant rooms or The existence of a FIRE is not areas) verified within 30 min. of alarm AND receipt (Note 1)

c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.

3 A FIRE within the plant or ISFSI HU4.3 A FIRE within the ISFSI or plant CPNPP has an ISFSI located outside the plant Protected Area.

[for plants with an ISFSI outside PROTECTED AREA not the plant ProtectedArea] extinguished within 60 min. of PROTECTED AREA not the initial report, alarm or extinguished within 60-minutes of indication (Note 1) the initial report, alarm or indication.

4 A FIRE within the plant or ISFSI HU4.4 A FIRE within the ISFSI or plant CPNPP has an ISFSI located outside the plant Protected Area.

[for plants with an ISFSI outside PROTECTED AREA that the plant ProtectedArea] requires firefighting support by PROTECTED AREA that requires an offsite fire response agency firefighting support by an offsite to extinguish fire response agency to extinguish.

Note Note: The Emergency Director N/A Note 1: The Emergency The classification timeliness note has been standardized across the should declare the Unusual Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within Event promptly upon determining declare the event the EAL wording.

that the applicable time has been promptly upon exceeded, or will likely be determining that time exceeded. limit has been exceeded, or will likely be exceeded.

75 of 114 to TXX-1 5101 EAL Comparison Matrix Table H-1 Fire Areas u-Containment Su--Safeguards Building

X-Auxiliary Building

X-Electrical & Control Building

X-Fuel Building

X-Service Water Intake Structure

u-Diesel Generator Building

u-Normal Switchgear Rooms

u-CST

u-RWST 76 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

HU7 Other conditions exist which in HU7 Other conditions existing that in None the judgment of the Emergency the judgment of the Emergency Director warrant declaration of a Coordinator warrant declaration (NO)UE of a UE MODE: All MODE: All NEI EA Ex.

E CPNPP NEI Example EAL Wording EAL # CPNPP EAL Wording Difference/Deviation Justification EAL # EAL Other conditions exist which in HU7.1 Other conditions exist which in None the judgment of the Emergency the judgment of the Emergency Director indicate that events are Coordinator indicate that events in progress or have occurred are in progress or have occurred which indicate a potential which indicate a potential degradation of the level of safety degradation of the level of safety of the plant or indicate a security of the plant or indicate a security threat to facility protection has threat to facility protection has been initiated. No releases of been initiated. No releases of radioactive material requiring radioactive material requiring offsite response or monitoring are offsite response or monitoring expected unless further are expected unless further degradation of safety systems degradation of SAFETY occurs. SYSTEMS occurs.

77 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

HA1 HOSTILE ACTION within the HA1 HOSTILE ACTION within the None OWNER CONTROLLED AREA or OWNER CONTROLLED AREA airborne attack threat within 30 or airborne attack threat within 30 minutes. minutes MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

I A HOSTILE ACTION is occurring or HA1.1 A HOSTILE ACTION is The security shift supervision is defined as the Security Shift has occurred within the OWNER occurring or has occurred within Supervisor CONTROLLED AREA as reported the OWNER CONTROLLED by the (site-specific security shift AREA as reported by the supervision). Security Shift Supervisor 2 A validated notification from NRC of HA1.2 A NRCvalidated notification of an aircraft from attack None an aircraft attack threat within 30 trean 30rcraf the minutesthreat minuts ite.site ofthe within 30 min. of the 78 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

HA5 Gaseous release impeding HA5 Gaseous release IMPEDING None access to equipment necessary access to equipment necessary for normal plant operations, for normal plant operations, cooldown or shutdown. cooldown or shutdown MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

a. Release of a toxic, corrosive, HA5.1 Release of a toxic, corrosive, The list of plant rooms or areas with entry-related mode asphyxiant or flammable gas asphyxiant or flammable gas into applicability identified specify those rooms or areas that contain into any of the following plant any Table H-2 rooms or areas equipment which require a manual/local action as specified in rooms or areas: AND AND operating procedures used for normal plant operation, cooldown and shutdown.

(site-specific list of plant rooms or areas with entry- Entry into the room or area is The control room has adequate protection from hazardous gases.

related mode applicability prohibited or IMPEDED (Note 5) identified)

AND b.Entry into the room or area is prohibited or impeded.

Note Note: If the equipment in the N/A Note 5: If the equipment in the None listed room or area was already listed room or area was inoperable or out-of-service already inoperable or out-before the event occurred, then of-service before the no emergency classification is event occurred, then no warranted. emergency classification is warranted.

79 of 114 to TXX-15101 EAL Comparison Matrix Table H-2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode Applicability Charging Pump Rooms 1,2, 3, 4, 5, 6 CVCS Valve Rooms 1,2,3,4,5,6 1E Switchgear Rooms All RHR Pump Rooms 4,5,6 80 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

HA6 Control Room evacuation HA6 Control Room evacuation None resulting in transfer of plant resulting in transfer of plant control to alternate locations, control to alternate locations MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

I An event has resulted in plant HA6.1 An event has resulted in plant Remote Shutdown Panel (RSP) is the site-specific remote shutdown control being transferred from the control being transferred from the panels/local control stations.

Control Room to (site-specific Control Room to the Remote remote shutdown panels and Shutdown Panel (RSP) local control stations).

81 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

HA7 Other conditions exist which in the HA7 Other conditions exist that in the None judgment of the Emergency Director judgment of the Emergency Coordinator warrant declaration of an Alert. warrant declaration of an Alert MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 Other conditions exist which, in the HA7.1 Other conditions exist which, in the None judgment of the Emergency Director, judgment of the Emergency Coordinator, indicate that events are in progress or indicate that events are in progress or have occurred which involve an actual or have occurred which involve an actual or potential substantial degradation of the potential substantial degradation of the level of safety of the plant or a security level of safety of the plant or a security event that involves probable life event that involves probable life threatening risk to site personnel or threatening risk to site personnel or damage to site equipment because of damage to site equipment because of HOSTILE ACTION. Any releases are HOSTILE ACTION. Any releases are expected to be limited to small fractions expected to be limited to small fractions of the EPA Protective Action Guideline of the EPA Protective Action Guideline exposure levels, exposure levels.

82 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

HS1 HOSTILE ACTION within the HS1 HOSTILE ACTION within the None PROTECTED AREA PROTECTED AREA MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 A HOSTILE ACTION is occurring HS1.1 A HOSTILE ACTION is occurring or has The security shift supervision is defined as the Security Shift or has occurred within the occurred within the PROTECTED AREA Supervisor PROTECTED AREA as reported as reported by the Security Shift by the (site-specific security shift Supervisor supervision).

83 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

HS6 Inability to control a key safety HS6 Inability to control a key safety function None function from outside the Control from outside the Control Room Room.

MODE: All MODE: All NEI EALEx.

NEI Example EAL Wording CPNPP EAL # CPNPP EAL Wording Difference/Deviation Justification 1 a. An event has resulted in plant HS6.1 An event has resulted in plant control Remote Shutdown Panel (RSP) is the site-specific remote control being transferred from the being transferred from the Control Room shutdown panels/local control stations.

Control Room to (site-specific to the Auxiliary Shutdown Panel (RSP) remote shutdown panels and local AND control stations).

AND Control of any of the following key safety functions is not reestablished within 15

b. Control of ANY of the min. (Note 1):

following key safety functions is not reestablished within (site-specific number of minutes).

Core cooling

" Reactivity control e RCS heat removal

" Core cooling [PWR] / RCP water level [BWR]

RCS heat removal 84 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

HS7 Other conditions exist which in HS7 Other conditions existing that in the None the judgment of the Emergency judgment of the Emergency Coordinator Director warrant declaration of a warrant declaration of a Site Area Site Area Emergency. Emergency MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

I Other conditions exist which in HS7.1 Other conditions exist which in the Replaced "site boundary" with "EXCLUSION AREA the judgment of the Emergency judgment of the Emergency Coordinator BOUNDARY".

Director indicate that events are indicate that events are in progress or EXCLUSION AREA BOUNDARY is a synonymous term for in progress or have occurred have occurred which involve actual or site boundary. CPNPP FSAR Section 2.1.1.3 and Figure 2.1-which involve actual or likely likely major failures of plant functions 2 define the Exclusion Area Boundary. This boundary is major failures of plant functions needed for protection of the public or used for establishing effluent release limits with respect to needed for protection of the HOSTILE ACTION that results in the requirements of 10CFR20. See also CPNPP Emergency public or HOSTILE ACTION that intentional damage or malicious acts, (1) Plan Appendix E, Complex and Owner Controlled Area and results in intentional damage or toward site personnel or equipment that CCNPP ODCM Section 5.0 Design Features.

malicious acts, (1) toward site could lead to the likely failure of or, (2) personnel or equipment that that prevent effective access to could lead to the likely failure of equipment needed for the protection of or, (2) that prevent effective the public. Any releases are not access to equipment needed for expected to result in exposure levels the protection of the public. Any which exceed EPA Protective Action releases are not expected to Guideline exposure levels beyond the result in exposure levels which EXCLUSION AREA BOUNDARY.

exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

85 of 114 to TXX-15101 EAL Comparison Matrix CPNPP NEI IC# NEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification HG1 HOSTILE ACTION resulting in HG1 HOSTILE ACTION resulting in loss of None loss of physical control of the physical control of the facility facility. MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 a. A HOSTILE ACTION is HG1.1 A HOSTILE ACTION is occurring or has The security shift supervision is defined as the Security Shift occurring or has occurred within occurred within the PROTECTED AREA Supervisor the PROTECTED AREA as as reported by the Security Shift reported by the (site-specific Supervisor security shift supervision). AND EITHER of the following has AND occurred:

b. EITHER of the following has One or more of the following safety occurred: functions cannot be controlled or

1. ANY of the following safety maintained functions cannot be

Reactivity control controlled or maintained.

Core cooling

" Reactivity control

RCS heat removal

" Core cooling OR

[PWR]/RCP water level [BWR] Damage to spent fuel has occurred

RCS heat removal or is IMMINENT OR

2. Damage to spent fuel has occurred or is IMMINENT.

86 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

HG7 Other conditions exist which in HG7 Other conditions exist which in the None the judgment of the Emergency judgment of the Emergency Coordinator Director warrant declaration of a warrant declaration of a General General Emergency Emergency MODE: All MODE: All NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

Other conditions exist which in HG7.1 Other conditions exist which in the None the judgment of the Emergency judgment of the Emergency Coordinator Director indicate that events are indicate that events are in progress or in progress or have occurred have occurred which involve actual or which involve actual or IMMINENT substantial core degradation IMMINENT substantial core or melting with potential for loss of degradation or melting with containment integrity or HOSTILE potential for loss of containment ACTION that results in an actual loss of integrity or HOSTILE ACTION physical control of the facility. Releases that results in an actual loss of can be reasonably expected to exceed physical control of the facility. EPA Protective Action Guideline Releases can be reasonably exposure levels offsite for more than the expected to exceed EPA immediate site area.

Protective Action Guideline exposure levels offsite for more than the immediate site area.

87 of 114 to TXX-15101 EAL Comparison Matrix Category S System Malfunction 88 of 114 to TXX-15101 EAL Comparison Matrix CPNPP NEI IC# NEI IC Wording lC#(s) CPNPP IC Wording Difference/Deviation Justification SU1 Loss of all offsite AC power SU1 Loss of all offsite AC power "Safeguard" is the site-specific term for emergency buses.

capability to emergency buses for capability to safeguard buses for 15 minutes or longer. 15 minutes or longer MODE: Power Operation, Startup, MODE: 1 - Power Operation, 2 -

Hot Standby, Hot Shutdown Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 Loss of ALL offsite AC power SUI.1 Loss of all offsite AC power 6.9KV safeguard buses uEA1 and uEA2 are the site-specific capability to (site-specific capability, Table S-1, to 6.9 KV emergency buses.

emergency buses) for 15 minutes safeguard buses uEA1 and uEA2 Site-specific AC power sources are tabularized in Table S-1.

or longer, for greater than or equal to 15 min. (Note 1)

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within promptly upon determining that declare the event the EAL wording.

15 minutes has been exceeded, promptly upon or will likely be exceeded. determining that time limit has been exceeded, or will likely be exceeded.

Table S-1 AC Power Sources Offsite:

138 KV switchyard circuit

345 KV switchyard circuit Onsite:

uEG1

uEG2 89 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

SU2 UNPLANNED loss of Control SU3 UNPLANNED loss of Control None Room indications for 15 minutes Room indications for 15 minutes or longer, or longer.

MODE: Power Operation, MODE: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording CPN PP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 An UNPLANNED event results in SU3.1 An UNPLANNED event results in The site-specific Safety System Parameter list is tabulated in Table the inability to monitor one or the inability to monitor one or S-2.

more of the following parameters more Table S-2 parameters from Added the words "to at least one S/G" to Auxiliary or emergency from within the Control Room for within the Control Room for feedwater flow. This is consistent with Level in at least one S/G.

15 minutes or longer, greater than or equal to 15 m fin.

(Note 1)

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should CPNPP EAL-scheme by referencing the "time limit" specified within promptly upon determining that declare the event the EAL wording.

15 minutes has been exceeded, promptly upon or will likely be exceeded. determining that time limit has been exceeded, or will likely be exceeded.

90 of 114 to TXX-15101 EAL Comparison Matrix

[BWR parameterlist] [PWR parameterlist]

Reactor Power Reactor Power RCP Water Level RCS Level RCP Pressure RCS Pressure Primary Containment Pressure In-Core/Core Exit Temperature Suppression Pool Level Levels in at least (site-specific number) steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow Table S-2 Safety System Parameters

Reactor power

RCS level

RCS pressure

Core Exit TIC temperature

Level in at least one SG

Auxiliary or emergency feed flow in at least one SG 91 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)

SU3 Reactor coolant activity greater SU4 Reactor coolant activity greater None than Technical Specification than Technical Specification allowable limits, allowable limits MODE: Power Operation, Startup, MODE: 1 - Power Operation, 2 -

Hot Standby, Hot Shutdown Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 (Site-specific radiation monitor) SU4.2 Gross Failed Fuel Monitor, The High Alarm (RED) setpoint is based on the Technical reading greater than (site-specific FFLu60 (u-RE-0406), High Alarm Specifications maximum allowable concentration of radioactivity in value). (RED) the reactor coolant, 87 pCi/gm.

2 Sample analysis indicates that a SU4.1 Reactor coolant Dose Equivalent CPNPP T.S. Section 3.4.16 provides the TS allowable coolant reactor coolant activity value is 1-131 specific activity greater than activity limits.

greater than an allowable limit 60 pCi/gm specified in Technical OR Specifications. Reactor coolant Dose Equivalent XE-133 specific activity greater than 500 pCi/gm 92.of 114 to TXX-1 5101 EAL Comparison Matrix CPNPP NEI IC# NEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification SU4 RCS leakage for 15 minutes or SU5 RCS leakage for 15 minutes or None longer. longer MODE: Power Operation, MODE: I - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

I RCS unidentified or pressure SU5.1 RCS unidentified or pressure Example EALs #1, 2 and 3 have been combined into a single EAL boundary leakage greater than boundary leakage greater than for usability.

(site-specific value) for 15 10 gpm for greater than or equal Added the defined term "UNISOLABLE" to the third condition to minutes or longer, to 15 min. emphasize the generic bases "In this case, RCS leakage has been 2 RCS identified leakage greater OR detected and operators, following applicable procedures, have been than (site-specific value) for 15 RCS identified leakage greater unable to promptly isolate the leak."

minutes or longer, than 25 gpm for greater than or equal to 15 min.

3 Leakage from the RCS to a OR location outside containment greater than 25 gpm for 15 UNISOLABLE leakage from the minutes or longer. RCS to a location outside containment greater than 25 gpm for greater than or equal to 15 min.

(Note 1)

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within promptly upon determining that declare the event the EAL wording.

15 minutes has been exceeded, promptly upon or will likely be exceeded. determining that time limit has been exceeded, or will likely 93 of 114 to TXX-1e5101 EAL Comparison Matrix I I I I be exceeded.II 94 of 114 to TXX-15101 EAL Comparison Matrix NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

Automatic or manual (trip SU6 Automatic or manual trip fails to None

[PWR] / scram [BWR]) fails to shut down the reactor shutdown the reactor. MODE: 1 - Power Operation MODE: Power Operation NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL # Dfeec/eito utfcto 1 a. An automatic (trip [PWR] / SU6.1 An automatic trip did not shut As specified in the generic developers guidance "Developers may scram [BWR]) did not shutdown down the reactor as indicated by include site-specific EOP criteria indicative of a successful reactor the reactor. reactor power greater than 5% shutdown in an EAL statement, the Basis or both (e.g., a reactor after any RPS setpoint is power level)." Reactor power less than or equal to 5% is the site-AND exceeded specific indication of a successful reactor trip.

b. A subsequent manual action AND Added the words "... as indicated by reactor power greater than 5%

taken at the reactor control after any RPS setpoint is exceeded" to clarify that it is a failure of the consoles is successful in A subsequent automatic trip or automatic trip when a valid trip signal has been exceed.

shutting down the reactor. manual trip action taken at the reactor control consoles MCB reactor trip switches or deenergizing uB3 and uB4 are the site-(MCB reactor trip switches or specific reactor control console trip switches credited for a deenergizing uB3 and uB4) is successful manual trip.

successful in shutting down the reactor as indicated by reactor power less than or equal to 5%

(Note 8)

a. A manual trip ([PWR] / SU6.2 A manual trip did not shut down As specified in the generic developers guidance "Developers may scram [BWR]) did not shutdown the reactor as indicated by include site-specific EOP criteria indicative of a successful reactor the reactor. reactor power greater than 5% shutdown in an EAL statement, the Basis or both (e.g., a reactor AND after any manual trip action was power level)." Reactor power less than or equal to 5% is the site-initiated specific indication of a successful reactor trip.

b. EITHER of the following: AND Added the words "... as indicated by reactor power greater than 5%

1. A subsequent manual A subsequent automatic trip or after any manual trip action was initiated" to clarify that it is a failure action taken at the reactor manual trip action taken at the of any manual trip when an actual manual trip signal has been control consoles is 95 of 114 to TXX-1 5101 EAL Comparison Matrix successful in shutting reactor control console inserted.

down the reactor. (MOB reactor trip switches or deentheeactr.eactrrgzing sw so Combined conditions b.1 and b.2 into a single statement to simplify OR ~~~~~deenergizing 2133 and uB4) is thprsnai.

OR successful in shutting down the the presentation.

2 A subsequent automatic reactor as indicated by reactor MCB reactor trip switches or deenergizing uB3 and uB4 are the site-(trip [PWR] / scram power less than or equal to 5% specific reactor control console trip switches credited for a

[BWR]) is successful in (Note 8) successful manual trip.

shutting down the reactor.

Notes Note: A manual action is any N/A Note 8: A manual action is any None operator action, or set of actions, operator action, or set of which causes the control rods to actions, which causes be rapidly inserted into the core, the control rods to be and does not include manually rapidly inserted into the driving in control rods or implementation of boron include manually driving injection strategies. in control rods or implementation of boron injection strategies.

96 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

SU6 Loss of all onsite or offsite SU7 Loss of all onsite or offsite None communications capabilities, communications capabilities.

MODE: Power Operation, MODE: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 Loss of ALL of the following SU7.1 Loss of all Table S-4 onsite Example EALs #1, 2 and 3 have been combined into a single EAL onsite communication methods: communication methods for simplification of presentation.

(site-specific list of OR Table S-4 provides a site-specific list of onsite, offsite (ORO) and communications methods) Loss of all Table S-4 offsite NRC communications methods.

2 Loss of ALL of the following communication methods ORO communications methods: OR (site-specific list of Loss of all Table S-4 NRC communications methods) communication methods 3 Loss of ALL of the following NRC communications methods:

(site-specific list of communications methods) 97 of 114 to TXX-15101 EAL Comparison Matrix Table S-4 Communication Methods System Onsite Offsite NRC Gai-tronics Page/Party (PA) X Plant Radios X PABX X X X Public Telephone X X X Federal Telephone System (FTS) X X 98 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

SU7 Failure to isolate containment or SU8 Failure to isolate containment or None loss of containment pressure loss of containment pressure control. [PWR] control MODE: Power Operation, MODE: I - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 a. Failure of containment to Any penetration is not isolated Reworded EAL to better describe the intent. Penetrations cannot isolate when required by an within 15 min. of a VALID close, but they can be isolated by closure of one or more isolation actuation signal. containment isolation signal valves associated with that penetration. The revised wording OR maintains the generic example EAL intent while more clearly AND Containment pressure greater describing failure to isolate threshold.

penetrations than 18 psig with neither not required

b. ALL

b. requiedwitinetionuts Containment Spray system The containment pressure setpoint (18 psig) is the pressure at r nt cluationsewiignal.1operating per design for greater which the containment depressurization equipment should actuate of the actuation signal. than or equal to 15 min. and begin performing its function. One train of containment SU8.1 (Note 1) depressurization equipment is defined as a Containment Spray 2 a. Containment pressure system.

greater than (site-specific pressure).

AND

b. Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer.

N/A N/A N/A Note 1: The Emergency Added Note 1 to be consistent in its use for EAL thresholds with a Coordinator should timing component.

declare the event 99 of 114 to TXX)-15101 EAL Comparison Matrix promptly upon determining that time limit has been exceeded, or will likely be exceeded.

100 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

SA1 Loss of all but one AC power SA1 Loss of all but one AC power "Safeguard" is the site-specific term for emergency buses.

source to emergency buses for source to safeguard buses for 15 15 minutes or longer. minutes or longer.

MODE: Power Operation, MODE: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NE! Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

a. AC power capability to (site- SAl.1 AC power capability, Table S-1, 6.9KV safeguard buses uEA1 and uEA2 are the site-specific specific emergency buses) is to 6.9 KV safeguard buses uEA1 emergency buses.

reduced to a single power source and uEA2 reduced to a single Site-specific AC power sources are tabularized in Table S-1.

for 15 minutes or longer, power source for greater than or AND equal to 15 min. (Note 1)

AND

b. Any additional single power source failure will result in a loss Any additional single power of all AC power to SAFETY source failure will result in loss of SYSTEMS. all AC power to SAFETY SYSTEMS Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Alert promptly upon Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within determining that 15 minutes has declare the event the EAL wording.

been exceeded, or will likely be promptly upon exceeded. determining that time limit has been exceeded, or will likely be exceeded.

101 of 114 to TXX-15101 EAL Comparison Matrix Table S-1 AC Power Sources Offsite:

138 KV switchyard circuit

345 KV switchyard circuit Onsite:

uEGI

uEG2 102 of 114 to TXX-15101 EAL Comparison Matrix CPNPP NEI IC# NEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification SA2 UNPLANNED loss of Control SA3 UNPLANNED loss of Control None Room indications for 15 minutes Room indications for 15 minutes or longer with a significant or longer with a significant transient in progress. transient in progress.

MODE: Power Operation, MODE: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 An UNPLANNED event results in SA3.1 An UNPLANNED event results in The site-specific Safety System Parameter list is tabulated in Table the inability to monitor one or the inability to monitor one or S-2.

more of the following parameters more Table S-2 parameters from The site-specific significant transients list to tabulated in Table S-3.

from within the Control Room for within the Control Room for 15 minutes or longer, greater than or equal to 15 min. CPNPP is a PWR and thus does not include thermal power AND (Note 1) oscillations greater than 10%.

ANY of the following transient AND events in progress. Any significant transient is in

" Automatic or manual progress, Table S-3 runback greater than 25%

thermal reactor power

" Electrical load rejection greater than 25% full electrical load

" Reactor scram [BWR] / trip

[PWR]

ECCS (SI) actuation

Thermal power oscillations greater than 10% [BWR]

103 of 114 to TXX-1 5101 EAL Comparison Matrix Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within promptly upon determining that declare the event the EAL wording.

15 minutes has been exceeded, promptly upon or will likely be exceeded. determining that time limit has been exceeded, or will likely be exceeded.

[BWR parameterlist] [PWR parameterlist]

Reactor Power Reactor Power RCP Water Level RCS Level RCP Pressure RCS Pressure Primary Containment Pressure In-Core/Core Exit Temperature Suppression Pool Level Levels in at least (site-specific number) steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow Table S-2 Safety System Parameters

Reactor power

RCS level

RCS pressure

Core Exit T/C temperature

Level in at least one SG

Auxiliary or emergency feed flow in at least one SG Table S-3 Significant Transients

Reactor trip

Runback greater than or equal to 25%

thermal power

Electrical load rejection greater than 25%

electrical load 104 of 114 to TXX-15101 EAL Comparison Matrix

. ECCS actuation NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(S)

SA5 Automatic or manual (trip [PWR] SA6 Automatic or manual trip fails to None

/ scram [BWR]) fails to shutdown shut down the reactor and the reactor, and subsequent subsequent manual actions manual actions taken at the taken at the reactor control reactor control consoles are not consoles are not successful in successful in shutting down the shutting down the reactor reactor. MODE: 1 - Power Operation MODE: Power Operation NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

a. An automatic or manual (trip SA6.1 An automatic or manual trip fails As specified in the generic developers guidance "Developers may

[PWR] / scram [BWR]) did not to shut down the reactor as include site-specific EOP criteria indicative of a successful reactor shutdown the reactor. indicated by reactor power shutdown in an EAL statement, the Basis or both (e.g., a reactor AND greater than 5% power level)." Reactor power less than or equal to 5% is the site-AND specific indication of a successful reactor trip.

b. Manual actions taken at the MCB reactor trip switches or deenergizing qB3 and uB4 are the site-reactor control consoles are not Manual trip actions taken at the sCi reactor trip switches credited for a successful in shutting down the reactor control console (MCB specific reactor control console trip switches credited for a reactor. reactor trip switches or successful manual trip.

deenergizing uB3 and uB4) are not successful in shutting down the reactor as indicated by reactor power greater than 5%

(Note 8)

Notes Note: A manual action is any N/A Note 8: A manual action is any None operator action, or set of actions, operator action, or set of which causes the control rods to actions, which causes be rapidly inserted into the core, the control rods to be and does not include manually 105 of 114 to TXX-15101 EAL Comparison Matrix driving in control rods or rapidly inserted into the implementation of boron injection core, and does not strategies. include manually driving in control rods or implementation of boron injection strategies.

106 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

SA9 Hazardous event affecting a SA9 Hazardous event affecting a None SAFETY SYSTEM needed for SAFETY SYSTEM needed for the current operating mode. the current operating mode MODE: Power Operation, MODE: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown 107 of 114 to TXX-15101 EAL Comparison Matrix NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 a. The occurrence of ANY of SA9.1 The occurrence of any Table S- The hazardous events have been tabularized in Table S-5.

the following hazardous events: 5 hazardous event Replaced "Shift Manager" with "Emergency Coordinator" as the EC

" Seismic event (earthquake) AND EITHER: can be either the SM or augmented ERO EC.

" Internal or external flooding " Event damage has caused event indications of degraded performance in at least one

" High winds or tornado strike train of a SAFETY SYSTEM

" FIRE needed for the current operating mode

" EXPLOSION

" The event has caused

" (site-specific hazards) VISIBLE DAMAGE to a

" Other events with similar SAFETY SYSTEM hazard characteristics as component or structure determined by the Shift needed for the current Manager operating mode AND

b. EITHER of the following:

1. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.

OR

2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.

108 of 114 to TXX-15101 EAL Comparison Matrix Table S-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 Emergency Coordinator 109 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

SS1 Loss of all offsite and all onsite SS1 Loss of all offsite and all onsite "Safeguard" is the site-specific term for emergency buses.

AC power to emergency buses AC power to safeguard buses for 15 minutes or longer, for 15 minutes or longer MODE: Power Operation, MODE: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 Loss of ALL offsite and ALL SS1.1 Loss of all offsite and all onsite 6.9KV safeguard buses uEA1 and uEA2 are the site-specific onsite AC power to (site-specific AC power capability, Table S-1, emergency buses.

emergency buses) for 15 minutes to 6.9 KV safeguard buses Site-specific AC power sources are tabularized in Table S-1.

or longer. uEA1 and uEA2 for greater than or equal to 15 min. (Note 1)

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within promptly upon determining that declare the event the EAL wording.

15 minutes has been exceeded, promptly upon or will likely be exceeded. determining that time limit has been exceeded, or will likely be exceeded.

110 of 114 to TXX-15101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification SS5 Inability to shutdown the reactor SS6 Inability to shut down the None causing a challenge to (core reactor causing a challenge to cooling [PWR] / RCP water level core cooling or RCS heat

[BWR]) or RCS heat removal, removal MODE: Power Operation MODE: 1 - Power Operation NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

a. An automatic or manual (trip SS6.1 An automatic or manual trip fails As specified in the generic developers guidance "Developers may

[PWR] / scram [BWR]) did not to shut down the reactor as include site-specific EOP criteria indicative of a successful reactor shutdown the reactor. indicated by reactor power shutdown in an EAL statement, the Basis or both (e.g., a reactor AND greater than 5% power level)." Reactor power less than or equal to 5% is the site-AND specific indication of a successful reactor trip.

b. All manual actions to that core cooling is extremely challenged is manifested by shuw shutdown m te acnl the reactor have been actions to All actions to sIndication shut down the CSTCoeoligRDPtcndinsm.

unsuccessful. reactor are not successful as AND indicated by reactor power Indication that heat removal is extremely challenged is manifested greater than 5% by CSFST Heat Sink RED Path conditions met.

c. EITHER of the following AND EITHER:

conditions exist:

(Site-specific indication of e CSFST Core Cooling an inability to adequately RED Path conditions met remove heat from the e CSFST Heat Sink RED core) Path conditions met (Site-specific indication of an inability to adequately remove heat from the RCS) 111 of 114 to TXX-1 5101 EAL Comparison Matrix NEI IC# NEI IC Wording CPNPP CPNPP IC Wording Difference/Deviation Justification IC#(s)

SS8 Loss of all Vital DC power for 15 SS2 Loss of all vital DC power for 15 None minutes or longer. minutes or longer.

MODE: Power Operation, MODE: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

1 Indicated voltage is less than SS2.1 Less than 105 VDC on all 125 105 VDC is the site-specific minimum vital DC bus voltage.

(site-specific bus voltage value) VDC safeguard buses uED1, DC buses uED1, uED2, uED3 and uED4 are the site-specific vital on ALL (site-specific Vital DC uED2, uED3 and uED4 for DC buses.u busses) for 15 minutes or longer, greater than or equal to 15 min.

(Note 1)

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should declare the CPNPP EAL scheme by referencing the "time limit" specified within promptly upon determining that event promptly upon the EAL wording.

15 minutes has been exceeded, determining that time limit has or will likely be exceeded. been exceeded, or will likely be exceeded.

112 of 114 to TXX-15101 EAL Comparison Matrix CPNPP NEI IC# NEI IC Wording IC#(s) CPNPP IC Wording Difference/Deviation Justification SG1 Prolonged loss of all offsite and SGla Prolonged loss of all offsite and "Safeguard" is the site-specific term for emergency buses.

all onsite AC power to all onsite AC power to emergency buses. safeguard buses MODE: Power Operation, MODE: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording CPNPP CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

a. Loss of ALL offsite and ALL SGI.1 Loss of all offsite and all onsite 6.9KV safeguard buses uEA1 and uEA2 are the site-specific onsite AC power to (site-specific AC power capability, Table S-1, emergency buses.

emergency buses). to 6.9 KV safeguard buses uEA1 Credit is given to APDGs as alternate AC power sources capable of AND and uEA2 powering a train of decay heat removal.

b. EITHER of the following: AND EITHER: 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is the site-specific SBO coping analysis time.

Restoration of at least Restoration of at least one CSFST Core Cooling RED Path conditions met indicates significant bus in emergency bus from a core exit superheating and core uncovery.

less AC one thanemergency (site-pencysic Table S-1 source or APDG less than (site-specific in less than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not hours) is not likely, likely (Note 1)

(Site-specific indication of CSFST Core Cooling RED an inability to adequately Path conditions met remove heat from the core)

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the General Emergency Coordinator should CPNPP EAL scheme by referencing the "time limit" specified within promptly upon determining that declare the event the EAL wording.

(site-specific hours) has been promptly upon exceeded, or will likely be determining that time exceeded. limit has been exceeded, or will likely be exceeded.

113 of 114 to TXX-15101 EAL Comparison Matrix CPNPP NEI IC# NEI IC Wording lC#(s) CPNPP IC Wording Difference/Deviation Justification SG8 Loss of all AC and Vital DC SG1 b Loss of all AC and vital DC None power sources for 15 minutes or power sources for 15 minutes or longer, longer MODE: Power Operation, MODE: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI EA Ex.

E CPNPP NEI Example EAL Wording EAL CPNPP EAL Wording Difference/Deviation Justification EAL # EAL #

a. Loss of ALL offsite and ALL SG1.2 Loss of all offsite and all onsite 6.9KV safeguard buses uEA1 and uEA2 are the site-specific onsite AC power to (site-specific AC power capability, Table S-1, emergency buses.

emergency buses) for 15 minutes to 6.9 KV safeguard buses Site-specific AC power sources are tabularized in Table S-1.

or longer. uEA1 and uEA2 for greater than AND or equal to 15 min. 105 VDC is the site-specific minimum vital DC bus voltage.

b. Indicated voltage is less than AND buses. uED1, uED2, uED3 and uED4 are the site-specific vital DC buses (site-specific bus voltage value) Less than 105 VDC on all 125 on ALL (site-specific Vital DC VDC safeguard buses uED1, busses) for 15 minutes or longer. uED2, uED3 and uED4 for greater than or equal to 15 min.

(Note 1)

Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should declare the CPNPP EAL scheme by referencing the "time limit" specified within promptly upon determining that 15 event promptly upon the EAL wording.

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

114 of 114

CP-201500668, License Amendment Request 15-003 for Revision to Units 1 & 2 Emergency Action Levels

Text

SUBJECT:

Dear Sir or Madam:

SUMMARY

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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