HNP-15-025, License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.

License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.

ML15126A117
Person / Time
Site:	Harris
Issue date:	04/30/2015
From:	Waldrep B Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15126A083	List: HNP-15-025, License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. ML15126A077 ML15126A078 ML15126A082 ML15126A089
References
HNP-15-025
Download: ML15126A117 (226)

Text

UKE Benjamin C.

Vice Waidrep President ENERGY. Harris Nuclear Plant 5413 Shearon Harris Road New Hill NC 27562-9300 919.362.2000 10 CFR 50.90 10 CFR 50 Appendix E,Section IV.B April 30, 2015 Serial: HNP-15-025 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant (HNP), Unit 1 Docket No. 50-400 Renewed License No. NPF-63

Subject:

License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors" Ladies and Gentlemen:

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, Duke Energy Progress, Inc., (Duke Energy) is requesting approval of a proposed change in the Emergency Action Levels (EALs) used at the Shearon Harris Nuclear Plant (HNP), Unit 1.

Duke Energy is proposing to change the EALs from a scheme based upon Revision 5 of NEI 99-01, "Methodology for Development of Emergency Action Levels," to one based upon Revision 6 of NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors."

This change in scheme requires NRC approval prior to implementation.

The revised EALs will be implemented as two charts, one based upon Operating Modes 1, 2, 3, and 4 (hot operating conditions), and one based upon Operating Modes 5, 6, and Defueled (cold operating conditions). Initiating conditions that are applicable to both hot and cold operating conditions are provided on both charts. provides an evaluation of the proposed change to the EAL scheme. Enclosure 2 provides a comparison matrix between the NEI 99-01, Revision 6, EALs and the proposed HNP EALs. This matrix identifies and provides justification for all differences from the NEI 99-01, Revision 6, EALs. Enclosure 3 provides the EAL Technical Bases Document (clean version) for HNP. Enclosure 4 provides a redline and strikeout version of the EAL Technical Bases Document for HNP that shows site specific changes to the generic guidance. Enclosure 5 provides the supporting calculation for the HNP EAL Table R-1, "Effluent Monitor Classification Thresholds." Enclosure 6 provides the proposed HNP EAL Wallcharts.

Duke Energy requests approval of the proposed EAL scheme by April 30, 2016, with a 180-day implementation period.

U.S. Nuclear Regulatory Commission Serial HNP-15-025 Page 2 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated North Carolina State Official.

This letter contains a regulatory commitment as identified in Enclosure 7.

Should you have any questions regarding this submittal, please contact Dave Corlett, HNP Regulatory Affairs Manager, at (919)-362-3137.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 30, 2015.

Sincerely, Benjamin C. Waldre

Enclosures:

1. Evaluation of Proposed Change

2. Harris Nuclear Plant NEI 99-01 Revision 6 EAL Comparison Matrix

3. Harris Nuclear Plant Emergency Action Level Technical Bases Document, EP-EAL, "Emergency Action Level Technical Bases" (Clean Version)

4. Harris Nuclear Plant Emergency Action Level Technical Bases Document, EP-EAL, "Emergency Action Level Technical Bases" (Redline and Strikeout Version)

5. Supporting Calculation for Harris Nuclear Plant Radiological Effluent EAL Values

6. Harris Nuclear Plant Emergency Action Level Wallcharts

7. Regulatory Commitment cc: Mr. J. D. Austin, NRC Sr. Resident Inspector, HNP Mr. W. L. Cox, Ill, Section Chief, N.C. DHSR Ms. M. Barillas, NRC Project Manager, HNP Mr. V. M. McCree, NRC Regional Administrator, Region II

U.S. Nuclear Regulatory Commission Serial HNP-15-025, Enclosure 1 SERIAL HNP-15-025 ENCLOSURE 1 EVALUATION OF PROPOSED CHANGE SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 RENEWED LICENSE NUMBER NPF-63

U.S. Nuclear Regulatory Commission Page 1 of 7 Serial HNP-15-025 Shearon Harris Nuclear Power Plant (HNP), Unit 1 Docket No. 50-400/Renewed License No. NPF-63 Evaluation of the Proposed Change License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99- 01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors" 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, Duke Energy Progress, Inc. (Duke Energy), is proposing a change to the Shearon Harris Nuclear Power Plant (HNP), Unit 1, Emergency Plan by revising the Emergency Action Level (EAL) scheme.

Duke Energy proposes to change the EALs from a scheme based upon NEI 99-01, "Methodology for Development of Emergency Action Levels," Revision 5 (Reference 1), to one based upon NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (Reference 2). This change in scheme requires Nuclear Regulatory Commission (NRC) approval prior to implementation. The proposed change continues to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50.

2.0 Detailed Description HNP currently uses an emergency classification scheme based on NEI 99-01, Revision 5, as accepted by the NRC in a letter dated April 25, 2010 (Reference 3). Duke Energy requests approval to change the HNP EAL scheme basis to that described in NEI 99-01, Revision 6.

NEI 99-01, Revision 6, addresses lessons learned since the implementation of NEI 99-01, Revision 5. In February 2008, NEI published NEI 99-01, Revision 5, in order to clarify the developmental guidance of numerous EALs and to enhance the guidance associated with the development of security-related EALs. In November 2012, NEI published NEI 99-01, Revision 6. The NRC formally endorsed the NEI 99-01, Revision 6, guidance as documented in a letter dated March 28, 2013 (Reference 4) and is the most recently accepted EAL methodology endorsed by the NRC.

The HNP NEI 99-01, Revision 6, EAL Comparison Matrix (Enclosure 2) provides a line-by-line comparison between the proposed HNP Initiating Conditions (ICs), Mode Applicability, and EAL wording with those described in NEI 99-01, Revision 6. This document provides a means of assessing HNP's differences from the NRC endorsed guidance within NEI 99-01, Revision 6.

No deviations from the NEI 99-01, Revision 6 are present.

Discussion of HNP EAL bases and lists of source document references are provided in the EAL Technical Bases document (Enclosures 3 and 4). The EAL Technical Bases document provides background information for use with the HNP NEI 99-01, Revision 6, EAL Comparison Matrix (Enclosure 2).

U.S. Nuclear Regulatory Commission Page 2 of 7 Serial HNP-15-025 Enclosure 1 3.0 Technical Evaluation The ICs and EALs that comprise the proposed scheme are presented in Enclosure 2. This matrix provides a cross reference between each generic IC and EAL contained in NEI 99-01, Revision 6, and the proposed HNP-specific IC and EAL.

The matrix follows the Recognition Category presentation order of NEI 99-01, Revision 6, as follows: Abnormal Rad Levels/Radiological Effluent, Cold Shutdown/Refueling System Malfunction, Fission Product Barrier Degradation, Hazards and Other Conditions Affecting Plant Safety, and System Malfunction. The Permanently Defueled Station section is not used since HNP is an operating unit. The guidance for Independent Spent Fuel Storage Installation (ISFSI) events was not used since HNP does not have an ISFSI.

Differences and Deviations As discussed in Regulatory Issue Summary (RIS) 2003-18, Supplement 2 (Reference 5),

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.

° 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.).

Differences and deviations were identified in accordance with the guidance discussed in RIS 2003-18 (and supplements). The proposed HNP specific ICs and EALs do not contain any deviations from the NEI 99-01, Revision 6, guidance. The basis for each difference is included in Enclosure 2. The identified differences do not alter the meaning or intent of the ICs or EALs.

Related Documents includes the HNP EAL Technical Basis Document for each recognition category for the proposed scheme. A redline and strikeout version of the HNP EAL Technical Basis Document is provided as Enclosure 4. These documents include the applicable information from the basis information contained in NEI 99-01, Revision 6. Enclosure 5 contains the supporting calculation for HNP EAL Table R-1, "Effluent Monitor Classification Thresholds." contains the proposed HNP 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, with the exception of Mode 6. NEI 99-01, Revision 6, defines Mode 6 as one or more vessel head closure bolts less than fully tensioned. HNP Technical Specifications define Mode 6 as a state in which the reactivity condition (keff) is less than or equal to 0.95 and the average reactor coolant temperature less than or equal to 140 degrees Fahreinheit, in addition

U.S. Nuclear Regulatory Commission Page 3 of 7 Serial HNP-15-025 to the condition in which fuel is in the reactor vessel with the vessel head closure bolts less than fully tensioned or with the head removed. The additional criteria HNP applies to Mode 6 does not adversely affect the use of the NEI 99-01, Revision 6, guidance that applies to Mode 6. The Operating Modes for HNP, as defined in the HNP Technical Specifications, are listed below.

MODE TITLE REACTIVITY  % RATED Average Reactor CONDITION THERMAL Coolant (kef) POWER Temperature (°F) 1 Power Operation > 0.99 >5 > 350 2 Startup > 0.99 <5 > 350 3 Hot Standby < 0.99 0 > 350 4 Hot Shutdown < 0.99 0 350 > Tavg > 200 5 Cold Shutdown < 0.99 0 < 200 6 Refueling < 0.95 0 < 140 In addition to these operating modes, NEI 99-01, Revision 6, defines the "Defueled" mode, which is defined as the condition present when all reactor fuel is removed from the Reactor Vessel (full core off load during refueling or an extended outage). HNP procedures recognize, and are consistent with, this Mode definition.

State and Local Government Review of Proposed Changes Duke Energy HNP personnel meet with the North Carolina and local emergency management agencies frequently throughout the year. Duke Energy has committed to provide a review of the new classification scheme to state and local emergency management officials following NRC approval of the requested EAL scheme revision and prior to implementation, as identified in .

Implementation Description Duke Energy plans to begin implementation of the proposed emergency classification scheme following NRC approval. Duke Energy requests approval of the proposed EAL scheme by April 30, 2016, as stated in the cover letter of this submittal. The EAL Technical Basis Document (Enclosure 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

U.S. Nuclear Regulatory Commission Page 4 of 7 Serial HNP-15-025 4.1 Applicable Regulatory Requirements/Criteria The regulations in 10 CFR 50.54(q) provide direction to licensees seeking to revise their Emergency Plan. The requirements related to nuclear power plant Emergency Plans are provided in the standards in 10 CFR 50.47, "Emergency Plans," and the requirements of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR 50.

Paragraph (a)(1) of 10 CFR 50.47 states in part that, "no initial operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency." Section 50.47 establishes standards that onsite and offsite emergency response plans must meet for the NRC staff to make such a positive finding. One of these standards, 10 CFR 50.47(b)(4), stipulates that Emergency Plans include a standard emergency classification and action level scheme.

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 minimum initial offsite response measures."

Section 1.8, "Conformance to NRC Regulatory Guides," of the HNP Final Safety Analysis Report (FSAR), confirms that the HNP will follow a format for emergency procedures in accordance with 10 CFR 50, Appendix E. 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.

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 10 CFR 50.54(q) for all other emergency action level changes."

NRC Regulatory Guide 1.101, Revision 4 (Reference 7), endorsed Nuclear Management and Resources Council, Inc./National Environmental Studies Project (NUMARC/NESP)-007,

U.S. Nuclear Regulatory Commission Page 5 of 7 Serial HNP-15-025 Revision 2, issued in January 1992, and NEI 99-01, Revision 4, EAL guidance as acceptable alternatives to the guidance provided in NUREG-0654 for development of EALs to comply with 10 CFR 50.47 and Appendix E to 10 CFR Part 50. NRC RIS 2005-02, Revision 1 (Reference 6), also discusses that a change in an EAL scheme to incorporate the improvements provided in NUMARC/NESP-007 or NEI 99-01 would not decrease the overall effectiveness of the Emergency Plan. However, due to the potential safety significance of the change, the change needs prior NRC review and approval.

In a letter dated March 28, 2013 (Reference 4), the NRC staff concluded that the guidance contained in NEI 99-01, Revision 6, is an acceptable method to develop an EAL scheme in accordance with the requirements of Appendix E to 10 CFR Part 50.

4.2 Significant Hazards Consideration Duke Energy has evaluated whether or not a significant hazards consideration (SHC) is warranted with the proposed amendment by addressing the three criterion set forth in 10 CFR 50.92(c) as discussed below:

(1) Does the proposed amendment involve a significant increase in the probabilityor consequences of an accident previously evaluated?

These changes affect the HNP Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. The proposed changes do not reduce the effecteness of the HNP Emergency Plan or the HNP Emergency Response Organization. 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 accidentpreviously evaluated?

These changes affect the HNP Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. These changes 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 initiator 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?

These changes affect the HNP 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

U.S. Nuclear Regulatory Commission Page 6 of 7 Serial HNP-15-025 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.

Based on the above, Duke Energy concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

Accordingly, a finding of "no significant hazards consideration" is justified.

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 HNP EAL Scheme, (2) operation of HNP will continue to be conducted in compliance with the Commission's 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 Duke Energy 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 would it change inspection or surveillance requirements. Duke Energy 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 Ill. 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). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs be prepared in connection with the proposed amendment.

6.0 References

1. NEI 99-01, Revision 5, Methodology for Development of Emergency Action Levels, dated February 2008, (Agency-wide Documents Access and Management System (ADAMS) Accession No. ML080450149)

2. NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 2012, (ADAMS Accession Number ML12326A805)

3. Letter from Eric J. Leeds (NRC) to Christopher L. Burton (Duke Energy), Shearon Harris Nuclear Power Plant, Unit I - Changes to the Emergency Action Level Scheme (TAC Nos.

ME1227), dated April 25, 2010, (ADAMS Accession Number ML100610685)

4. Letter from Mark Thaggard (NRC) to Susan Perkins-Grew (Nuclear Energy Institute),

U.S. Nuclear Regulatory Commission Review and Endorsementof NEI 99-01, Revision

U.S. Nuclear Regulatory Commission Page 7 of 7 Serial HNP-15-025 6, November2012 (TAC NO. D92368), dated March 28, 2013, (ADAMS Accession Number ML12346A463)

5. NRC, Regulatory Issue Summary 2003-18, Supplement 2, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, dated December 12, 2005 (ADAMS Accession No. ML051450482)

6. NRC, Regulatory Issue Summary 2005-02, Revision 1, Clarifying the Process for Making Emergency Plan Changes, dated April 19, 2011, (ADAMS Accession Number ML100340545)

7. NRC, Regulatory Guide 1.101, Revision 4, Emergency Planningand Preparednessfor Nuclear Power Reactors, dated July 2003 (ADAMS Accession No. ML032020276)

U.S. Nuclear Regulatory Commission Serial HNP-15-025, Enclosure 2 SERIAL HNP-15-025 ENCLOSURE 2 HARRIS NUCLEAR PLANT NEI 99-01 REVISION 6 EAL COMPARISON MATRIX SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 RENEWED LICENSE NUMBER NPF-63

,%DUKE ENERGYe Harris Nuclear Plant NEI 99-01 Revision 6 EAL Comparison Matrix Revision 0 [4/29/15]

EAL Comparison Matrix Table of Contents Section Paqe Introduction M--1-------------------

Comparison Matrix Format.. .. . ... . . ... . .1 EAL Wording s-------------------------- ------

EAL Emphasis Techniques ------------------ 1--

Global Differences- -- -- -- - - ---- -- - ----- ---

Differences and Deviations --- -- -- - --- ----- -- -- -- --- -- - -

Category A - Abnormal Rad Levels / Rad Effluents ---- ------------- - --------------- 12 Category C - Cold Shutdown / Refueling System Malfunction 30 Category D - Permanently Defueled Station Malfunction ------------ ------------------ ------------------------- 51 Category E - Events Related to Independent Spent Fuel Storage Installations ------------------ 53 Category F - Fission Product Barrier Degradation --- ------------------------------------------ --------- 56 Category H - Hazards and Other Conditions Affecting Plant Safety--- ---------- 69 Category S - System Malfunction 8 Table 1 - HNP EAL Categories/Subcategories ------------ 5 Table 2 - NEI / HNP EAL Identification Cross-Reference -----------......................... 6 Table 3 - Summary of Deviations - - --- -- -- - - - --- ---- -- -- -------- 11 i ofi

EAL Comparison Matrix Introduction power plant sites and better positioning to adopt future industry-wide scheme This document provides a line-by-line comparison of the Initiating Conditions enhancements" (ICs), Mode Applicability and Emergency Action Levels (EALs) in NEI 99-01 EAL Emphasis Techniques Rev. 6 Final, Development of Emergency Action Levels for Non-Passive Due to the width of the table columns and table formatting constraints in this Reactors, ADAMS Accession Number ML12326A805, and the Harris Nuclear document, line breaks and indentation may differ slightly from the Plant (HNP) ICs, Mode Applicability and EALs. This document provides a appearance of comparable wording in the source documents. NEI 99-01 is means of assessing HNP differences and deviations from the NRC endorsed the source document for the NEI EALs; the HNP EAL Technical Bases guidance given in NEI 99-01. Discussion of HNP EAL bases and lists of Document for the HNP EALs.

source document references are given in the EAL Technical Bases Document. It is, therefore, advisable to reference the EAL Technical Bases The print and paragraph formatting conventions summarized below guide Document for background information while using this document. HNP has presentation of the HNP EALs in accordance with the EAL writing criteria.

taken no deviation from the generic guidance. Space restrictions in the EAL table of this document sometimes override this criteria in cases when following the criteria would introduce undesirable complications in the EAL layout.

Comparison Matrix Format

" Upper case-bold print is used for the logic terms AND, OR and The ICs and EALs discussed in this document are grouped according to NEI EITHER.

99-01 Recognition Categories. Within each Recognition Category, the ICs

" Bold font is used for certain logic terms, negative terms (not, and EALs are listed in tabular format according to the order in which they are cannot, etc.), any, all.

given in NEI 99-01. Generally, each row of the comparison matrix provides the following information:

• Upper case print is reserved for defined terms, acronyms, system abbreviations, logic terms (and, or, etc. when not used as a

• NEI EAL/IC identifier conjunction), annunciator window engravings.

• NEI EALJIC wording

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

• HNP EAL/IC identifier following..." or "All of the following..." Items of the list begin with

• HNP EAL/IC wording bullets when a priority or sequence is not inferred.

• Description of any differences or deviations

• The use of AND/OR logic within the same EAL has been avoided when possible. When such logic cannot be avoided, indentation and separation of subordinate contingent phrases is employed.

EAL Wording In Section 4.1, NEI recommends the following: "The guidance in NEI 99-01 is Global Differences not intended to be applied to plants "as-is"; however, developers should The differences listed below generally apply throughout the set of EALs and attempt to keep their site-specific schemes as close to the generic guidance are not repeated in the Justification sections of this document. The global as possible. The goal is to meet the intent of the generic Initiating Conditions (ICs) and Emergency Action Levels (EALs) within the context of site-specific differences do not decrease the effectiveness of the intent of NEI 99-01.

characteristics - locale, plant design, operating features, terminology, etc. 1. The NEI phrase "Notification of Unusual Event" has been changed to Meeting this goal will result in a shorter and less cumbersome NRC review "Unusual Event" or abbreviated "UE" to reduce EAL-user reading and approval process, closer alignment with the schemes of other nuclear burden.

1 of 113

EAL Comparison Matrix

2. NEI 99-01 IC Example EALs are implemented in separate plant o EALs applicable under all plant operating modes -

EALs to improve clarity and readability. For example, NEI lists all IC This group would be reviewed by the EAL-user any HU3 Example EALs under one IC. The corresponding HNP EALs time emergency classification is considered.

appear as unique EALs (e.g., HU3.1 through HU3.4).

o EALs applicable only under hot operating modes -

3. Mode applicability identifiers (numbers/letter) modify the NEI 99-01 This group would only be reviewed by the EAL-user mode applicability names as follows: 1 - Power Operation, 2 - when the plant is in Hot Shutdown, Hot Standby, Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Startup or Power Operation mode.

Refueling, D - Defueled. NEI 99-Oldefines Defueled as follows:

"Reactor Vessel contains no irradiated fuel (full core off-load during o EALs applicable only under cold operating modes -

refueling or extended outage)." This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling or

4. NEI 99-01 uses the terms greater than, less than, greater than or Defueled mode.

equal to, etc. in the wording of some example EALs. For consistency The purpose of the groups is to avoid review of hot and reduce EAL-user reading burden, HNP has adopted use of boolean symbols in place of the NEI 99-01 text modifiers within the condition EALs when the plant is in a cold condition and EAL wording. avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the

5. "min." is the standard abbreviation for"minutes" and is used to total number of EALs that must be reviewed by the EAL-reduce EAL user reading burden. user for a given plant condition and, thereby, speeds

6. The term "Emergency Director" has been replaced by "Emergency identification of the EAL that applies to the emergency.

Coordinator" consistent with site-specific nomenclature. b. Within each of the above three groups, assignment of

7. Wherever the generic bracketed PWR term "reactor vessel/RCS" is EALs to categories/subcategories - Category and provided, HNP uses the term "RCS" as the site-specific subcategory titles are selected to represent conditions nomenclature. that are operationally significant to the EAL-user.

Subcategories are used as necessary to further divide the

8. IC/EAL identification: EALs of a category into logical sets of possible

• NEI Recognition Category A "Abnormal Radiation Levels/ emergency classification thresholds. The HNP EAL Radiological Effluents" has been changed to Category R categories/subcategories and their relationship to NEI "Abnormal Rad Levels / Rad Effluents." The designator "R" is Recognition Categories are listed in Table 1.

more intuitively associated with radiation (rad) or radiological c. Unique identification of each EAL - Four characters events. NEI IC designators beginning with "A" have likewise comprise the EAL identifier as illustrated in Figure 1.

been changed to "R."

• NEI 99-01 defines the thresholds requiring emergency classification (example EALs) and assigns them to ICs which, in turn, are grouped in "Recognition Categories." The HNP IC/EAL scheme includes the following features:

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

2 of 113

EAL Comparison Matrix Figure 1 - EAL Identifier EAL-user find higher emergency classification EALs that may become active if plant conditions worsen.

EAL Identifier XXX.X Table 2 lists the HNP ICs and EALs that correspond to the NEI ICs/Example (R.H,E. S. F. C)Q Categfory number Sequrential withinsubcategorylolss~ilication EALs when the above EAL/IC organization and identification scheme is Emergency (G,.S,A, U)~

classification I Subcategory (1lifnosubcategory) number implemented.

The first character is a letter associated with the category Differences and Deviations in which the EAL is located. The second character is a letter associated with the emergency classification level In accordance NRC Regulatory Issue Summary (RIS) 2003-18 "Use of (G for General Emergency, S for Site Area Emergency, A Nuclear Energy Institute (NEI) 99-01, Methodology for Development of for Alert, and U for Notification of Unusual Event). The Emergency Action Levels" Supplements 1 and 2, a difference is an EAL third character is a number associated with one or more change in which the basis scheme guidance differs in wording but agrees in subcategories within a given category. Subcategories are meaning and intent, such that classification of an event would be the same, sequentially numbered beginning with the number "1". If a whether using the basis scheme guidance or the HNP EAL. A deviation is an category does not have a subcategory, this character is EAL change in which the basis scheme guidance differs in wording and is assigned the number "1". The fourth character is a altered in meaning or intent, such that classification of the event could be number preceded by a period for each EAL within a different between the basis scheme guidance and the HNP proposed EAL.

subcategory. EALs are sequentially numbered within the Administrative changes that do not actually change the textual content are emergency classification level of a subcategory beginning neither differences nor deviations. Likewise, any format change that does not with the number "1". alter the wording of the IC or EAL is considered neither a difference nor a The EAL identifier is designed to fulfill the following deviation.

objectives: The following are examples of differences:

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 of the EAL identifier alone can lead the EAL-user to

• Where the NEI 99-01 guidance specifically provides an option to not the location of the EAL within the classification include an EAL if equipment for the EAL does not exist at HNP (e.g.,

matrix. The identifier conveys the category, automatic real-time dose assessment capability).

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 timely manner without the need for a word

• Choosing to state ALL Operating Modes are applicable instead of description of the classification threshold. stating N/A, or listing each mode individually under the Abnormal Rad Level/Radiological Effluent and Hazard and Other Conditions o Possible classification upgrade -The Affecting Plant Safety sections.

category/subcategory/identifier scheme helps the 3 of 113

EAL Comparison Matrix

• Using synonymous wording (e.g., greater than or equal to vs. at or

• Any change to the IC and/or EAL, and/or basis wording as stated in above, less than or equal vs. at or below, greater than or less than NEI 99-01 that does alter the intent of the IC and/or EAL, i.e., the IC vs. above or below, etc.) and/or EAL:

" Adding HNP equipment/instrument identification and/or noun names o Does not classify at the classification level consistent with to EALs. NEI 99-01.

• Combining like ICs that are exactly the same but have different o Is not logically integrated with other EALs in the EAL operating modes as long as the intent of each IC is maintained and scheme.

the overall progression of the EAL scheme is not affected. o Results in an incomplete EAL scheme (i.e., does not classify

• Any change to the IC and/or EAL, and/or basis wording, as stated in all potential emergency conditions).

NEI 99-01, that does not alter the intent of the IC and/or EAL, i.e., The "Difference Justification" columns in the remaining sections of this the IC and/or EAL continues to: document identify each difference between the NEI 99-01 IC/EAL wording o Classify at the correct classification level. and the HNP IC/EAL wording. An explanation that justifies the reason for each difference is then provided. If the difference is determined to be a o Logically integrate with other EALs in the EAL scheme.

deviation, a statement is made to that affect and explanation is given that o Ensure that the resulting EAL scheme is complete (i.e., states why classification may be different from the NEI 99-01 IC/EAL and the classifies all potential emergency conditions). reason for its acceptability. In all cases, however, the differences and The following are examples of deviations: deviations do not decrease the effectiveness of the intent of NEI 99-01. HNP has identified no deviations from the NEI 99-01 guidance as represented in

• Use of altered mode applicability. Table 3.

• Altering key words or time limits.

" Changing words of physical reference (protected area, safety-related equipment, etc.).

• 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 99-01definitions 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.

4 of 113

EAL Comparison Matrix Table 1 - HNP EAL Categories/Subcategories HNP EALs NEI Category Subcategory Recognition Category Group: Any Operatina 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 ICs/EALs 3- Natural or Technological Hazard 4- Fire 5- Hazardous Gases 6- Control Room Evacuation 7- Emergency Coordinator Judgment NIA ISFSI ICs/EALs N/A 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 113

EAL Comparison Matrix Table 2 - NEI / HNP EAL Identification Cross-Reference NEI HNP Example Category and Subcategory EAL AU1 I R -Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.1 AUl 2 R -Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.1 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 1 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 AS1 1 R -Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.1 AS1 2 R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.2 AS1 3 R -Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.3 6 of 113

EAL Comparison Matrix NEI HNP IC 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 CU1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CUI.1 CUl 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CU1.2 CU2 1 C - Cold SD/ Refueling System Malfunction, 2 - Loss of Emergency 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 1 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 CA1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CA1.2 CA2 1 C - Cold SD/ Refueling System Malfunction, 1 - Loss of Emergency 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 CA6.1 CS1 1 C -Cold SD/ Refueling System Malfunction, 1 - RCS Level CS1.1 7 of 113

EAL Comparison Matrix NEI HNP 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 CS1.3 CG1 1 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CG1.1 CG1 2 C - Cold SD/ Refueling System Malfunction, 1 - RCS Level CG1.2 E-HU1 1 N/A N/A FA1 1 F - Fission Product Barrier Degradation FA1. 1 FS1 1 F - Fission Product Barrier Degradation FS1.1 FG1 1 F - Fission Product Barrier Degradation FG1.1 HU1 1, 2, 3 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HUI.1 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 HU4.1 HU4 2 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire HU4.2 HU4 3 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire HU4.3 8 of 113

EAL Comparison Matrix NEI HNP IC Example Category and Subcategory EAL EAL HU4 4 H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire HU4.4 HU7 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - EC udgment HU7.1 HA1 1, 2 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HA1.1 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 - EC Judgment HA7.1 HS1 1 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HS1 .1 HS6 1 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 - EC Judgment HS7.1 HG1 1 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HG1.1 HG7 1 H - Hazards and Other Conditions Affecting Plant Safety, 7 - EC Judgment HG7.1 SUl 1 S - System Malfunction, 1 - Loss of Emergency AC Power SU1.1 SU2 1 S - System Malfunction, 3 - Loss of Control Room Indications SU3.1 SU3 1 S - System Malfunction, 4 - RCS Activity SU4.2 SU3 2 S - System Malfunction, 4 - RCS Activity SU4.1 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 9 of 113

EAL Comparison Matrix NEI HNP IC Example EAL Category and Subcategory EAL 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 1 S - System Malfunction, 3 - Loss of Control Room Indications SA3.1 SA5 1 S - System Malfunction, 6 - RPS Failure SA6.1 SA9 1 S - System Malfunction, 9 - 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 1 S - System Malfunction, 1 - Loss of Emergency AC Power SG1.2 10 of 113

EAL Comparison Matrix Table 3 - Summary of Deviations NEI HNP NEIAL Description IC Example EAL EAL N/A N/A N/A N/A 11 of 113

EAL Comparison Matrix Category A Abnormal Rad Levels I Radiological Effluent 12 of 113

EAL Comparison Matrix NEI IC# NEI IC Wording and Mode HNP HNP IC Wording and Mode Difference Justification Applicability IC#(s) Applicability AU1 Release of gaseous or liquid RU1 Release of gaseous or liquid The HNP 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 EALEx.

1. HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 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 > column "UE" for > EAL to simplify presentation.

times the (site-specific effluent 60 min. The NEI phrase "...effluent radiation monitor greater than 2 release controlling document) (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 RUI.1 effluent radiation monitor > column "UE".

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

3 Sample analysis for a gaseous or RU1.2 Sample analysis for a gaseous or The HNP 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- 60 min.

specific effluent release (Notes 1, 2) 1 controlling document) limits for II 13 of 113

EAL Comparison Matrix NEI Ex.HNP NEI Ex. NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification EAL # A#

60 minutes or longer.

Notes

• 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 HNP EAL scheme by referencing the "time limit" Event promptly upon promptly upon determining specified within the EAL wording and deleting the specific determining that 60 minutes that time limit has been classification.

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 detected and the release detected and the release The classification timeliness note has been standardized start time is unknown, start time is unknown, across the HNP EAL scheme by referencing the "time limit" assume that the release assume that the release specified within the EAL wording.

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 have stopped due to actions have stopped, indicating that None 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 113

EAL Comparison Matrix Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent RM-21AV-3509-1SA 1.05E+8 pjCi/sec 1.05E+7 pCi/sec 1.05E+6 pCVsec 8.93E+3 pCi/sec 0 Turbine Building RM-1TV-3536-1 4.60E+8 pCi/sec 4.60E+7 giCLsec 4.60E+6 pCi/sec 1.08E+4 pCi/sec 0

Waste Process Building Vent 5 RM-1WV-3546-1 7.74E+9 gCi/sec 7.74E+8 p.Ctsec 7.75E+7 gCi/sec 1.95E+5 pCi/sec Waste Process Budding Vent RM-1VVV-3547-1 7.76E+9 pCVsec 7.76E+8 pCi/sec 7.76E+7 gCVsec 1.14E+4 pCi/sec 5A Treated Laundry & Hot Shower REM-iWL-3540 1.83E+5 cpm Tank Discharge

= Waste Monitor/Waste Evaporator REM-21WL-3541 5.13E+5 cpm U Condensate Tank Discharge REM-21WL-35_1_ _ _ ______5.13E+5_cpm Secondary Waste Sample Tank Discharge REM-21WS-3542 1.83E+5 cpm 15 of 113

EAL Comparison Matrix NEI IC# NEI IC Wording and Mode HNP HNP IC Wording and Mode Difference 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 HNP EAL HNP EAL Wording Difference Justification EAL # EAL #

1 a. UNPLANNED water level RU2.1 UNPLANNED water level drop in the The site-specific list of radiation monitors are listed in Table drop in the REFUELING REFUELING PATHWAY as indicated R-2 for ease of reading.

PATHWAY as indicated by by low water level alarm or indication ANY of the following: AND (site-specific level UNPLANNED rise in corresponding indications), area radiation levels as indicated by ANND any Table R-2 area radiation monitors

b. UNPLANNED rise in area radiation levels as indicated by ANY of the following radiation monitors.

(site-specific list of area radiation monitors) 16 of 113

EAL Comparison Matrix Table R-2 Refueling Pathway Area Radiation Monitors Containment

• RM-1CR-3561A-SA Containment Ventilation Isolation

• RM-1 CR-3561 B-SB Containment Ventilation Isolation

• RM-1 CR-3561 C-SA Containment Ventilation Isolation

• RM-1CR-3561D-SB Containment Ventilation Isolation Fuel Handling Building

• RM-1FR-3564A-SA Spent Fuel Pool SW, SE, SW

• RM-1FR-3564B-SB Spent Fuel Pool SW, SE, SE

• RM-1FR-3565A-SA Spent Fuel Pool SW, SE, SW

• RM-1FR-3565B-SB Spent Fuel Pool SW, SE, SE

• RM-1FR-3566A-SA Spent Fuel Pool NE, NW, NE

• RM-1FR-3566B-SB Spent Fuel Pool NW, NE, NW

• RM-1FR-3567A-SA Spent Fuel Pool NW, NE, NW

• RM-1FR-3567B-SB Spent Fuel Pool NE, NW, NE 17 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification AA1 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 EALEx.

E HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 1 Reading on ANY of the following RA1.1 Reading on any Table R-1 effluent The HNP radiation monitors that detect radioactivity effluent radiation monitors greater than radiation monitor > column "ALERT" release to the environment are listed in Table R-1. UE, Alert, the reading shown for 15 for > 15 min. (Notes 1, 2, 3, 4) SAE and GE thresholds for all HNP continuously monitored minutes or longer: gaseous and liquid release pathways are listed in Table R-1 to consolidate the information in a single location and, (site-specific monitor list and thereby, simplify identification of the thresholds by the EAL-threshold values) user.

2 Dose assessment using actual RA1.2 Dose assessment using actual The site boundary is the site-specific receptor point.

meteorology indicates doses meteorology indicates doses > 10 greater than 10 mrem TEDE or mrem TEDE or 50 mrem thyroid CDE 50 mrem thyroid CDE at or at or beyond the SITE BOUNDARY beyond (site-specific dose (Notes 3, 4) receptor point).

3 Analysis of a liquid effluent RA1.3 Analysis of a liquid effluent sample The site boundary is the site-specific receptor point.

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

18 of 113

EAL Comparison Matrix Field survey results indicate RA1.4 The site boundary is the site-specific receptor point.

4 Field survey results indicate EITHER EITHER of the following at or of the following at or beyond the SITE beyond (site-specific dose receptor point): BOUNDARY:

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

minutes or longer.

" Analyses of field survey " Analyses of field survey samples indicate thyroid samples indicate thyroid CDE CDE greater than 50 mrem > 50 mrem for 60 min. of for one hour of inhalation. 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 HNP EAL scheme by referencing the "time limit" promptly upon determining promptly upon determining specified within the EAL wording and deleting the specific that the applicable time has that time limit has been classification.

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 detected and the release detected and the release The classification timeliness note has been standardized start time is unknown, start time is unknown, across the HNP EAL scheme by referencing the "time limit" assume that the release assume that the release specified within the EAL wording.

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 have stopped due to actions have stopped, indicating None 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 Note 4 The pre-calculated effluent

" The pre-calculated effluent monitor values presented in Incorporated site-specific EAL numbers associated with monitor values presented in EALs RA1.1, RS1.1 and generic EAL#1.

EAL #1 should be used for RG1.1 should be used for emergency classification emergency classification Added the words "Ifdose assessment results are available, declaration should be based on dose assessment instead of 19 of 113

EAL Comparison Matrix assessments until the results assessments until the radiation monitor values." to reinforce the intent of the note.

from a dose assessment results from a dose using actual meteorology are assessment using actual available. meteorology are available. If dose assessment results are available, declaration should be based on dose assessment instead of radiation monitor values.

20 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 EA Ex.

E HNP NEI Example EAL Wording EAL HNP EAL Wording Difference 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 The NEI phrase "...from the fuel as indicated by ANY of the resulting in a release of release of radioactivity following radiation monitors" has been replaced with "...AND radioactivity from the fuel as A high alarm on any of the following" for clarification that the indicated by ANY of the following AND classification requires two conditions: damage to fuel and a radiation monitors: A high alarm on any of the following: resultant high radiation alarm.

(site-specific listing of radiation

• Table R-2 refueling pathway The site-specific list of radiation monitors are listed in bullet monitors, and the associated area radiation monitors format for ease of reading.

readings, setpoints and/or The high setpoints for the radiation monitors are indicative of alarms)

• REM-*1 FL-3508A-SA, FHB *hhihstonsfrterdaonmiosaeidctvef Emergency Exhaust significant increases in area and/or airborne radiation.

0 REM-*1FL-3508B-SB, FHB Emergency Exhaust 3 Lowering of spent fuel pool level RA2.3 Lowering of spent fuel pool level < Post-Fukushima order EA-12-051 required the installation of to (site-specific Level 2 value). 270.7 ft. (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).

The SFP level instruments consist of a three independent remote indicating channels (LI-5101A, LI-5102A and LI-5103A) each spanning approximately 25 ft. (260 ft. - 285 ft.

indicated). Level 2 corresponds to an indicated SFP level of 270.7 ft. or approximately 10 ft. above the top of the SFP 21 of 113

EAL Comparison Matrix I I I Iracks.

22 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 EA Ex.

E HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification EAL # EAL #

1 Dose rate greater than 15 mR/hr RA3.1 Dose rate > 15 mR/hr in EITHER of No other site-specific areas requiring continuous occupancy in ANY of the following areas: the following areas: exist at HNP.

• Control Room Control Room RM-21 RR-3560-SA monitors the Control room for area

• Central Alarm Station (RM-21 RR-3560-SA) radiation.

• (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 Table R-3/H-2 contains the site-specific list of plant rooms or in radiation levels that prohibit or radiation levels that prohibit or impede areas with entry-related mode applicability identified.

impede access to any of the access to any Table R-3/H-2 rooms or following plant rooms or areas: areas (Note 5)

(site-specific list of plant rooms or areas with entry-related mode applicability identified)

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

warranted.

23 of 113

EAL Comparison Matrix Table R-3/H-2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode(s)

RAB 190 (RHR pumps) 4 RAB 216 (BIT) 1,2,3,4,5 RAB 236 (CSIP, Primary Sample Sink, AFW pumps, CCW pumps and HX, Boric Acid Transfer Pumps, Mezzanine Area) 1, 2, 3, 4, 5 RAB 261 (RHR Heat Exchangers, Demin. Valve Gallery, VCT Valve Gallery) 1, 2, 3, 4, 5 RAB 286 (Switchgear) 3,4,5 Containment Building 3 Steam Tunnel 1, 2, 3, 4 ESW intakes 1,2,3,4,5 24 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification AS1 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 HNP# HNP EAL Wording Difference Justification EAL # EAL 1 Reading on ANY of the following RSI.1 Reading on any Table R-1 effluent The HNP radiation monitors that detect radioactivity effluent radiation monitors greater than radiation monitor > column "SAE" for release to the environment are listed in Table R-1. UE, Alert, the reading shown for 15 > 15 min. SAE and GE thresholds for all HNP continuously monitored minutes or longer: (Notes 1, 2, 3, 4) gaseous and liquid release pathways are listed in Table R-1 to (site-specific monitor list and consolidate the information in a single location and, thereby, threshold values) simplify identification of the thresholds by the EAL-user.

2 Dose assessment using actual RS1.2 Dose assessment using actual The site boundary is the site-specific receptor point.

meteorology indicates doses meteorology indicates doses > 100 greater than 100 mrem TEDE or mrem TEDE or 500 mrem thyroid CDE 500 mrem thyroid CDE at or at or beyond the SITE BOUNDARY beyond (site-specific dose (Notes 3, 4) receptor point) 3 Field survey results indicate RS1.3 Field survey results indicate EITHER The site boundary is the site-specific receptor point.

EITHER of the following at or of the following at or beyond the SITE beyond (site-specific dose BOUNDARY:

receptor point): o Closed window dose rates >

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

expected to continue for 60 minutes or longer. o Analyses of field survey

" Analyses of field survey samples indicate thyroid CDE >

samples indicate thyroid 500 mrem for 60 min. of 25 of 113

EAL Comparison Matrix CDE greater than 500 inhalation.

mrem for one hour of (Notes 1, 2)

__________ inhalation. ____ ______________________________________________

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

applicable time has been exceeded, or will likely be exceeded, or will likely be exceeded. exceeded.

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

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 to isolate the release path, effluent monitor is known to have stopped, indicating that None then the effluent monitor reading is no longer valid for the release path is isolated, classification purposes. the effluent monitor reading is no longer VALID for

• The pre-calculated effluent classification purposes.

monitor values presented in Note 4 The pre-calculated effluent EAL #1 should be used for monitor values presented in Incorporated site-specific EAL numbers associated with emergency classification EALs RAI.1, RS1.1 and generic EAL#1.

assessments until the results RG1.1 should be used for from a dose assessment emergency classification Added the words "Ifdose assessment results are available, using actual meteorology are assessments until the results declaration should be based on dose assessment instead of available. from a dose assessment radiation monitor values." to reinforce the intent of the note.

using actual meteorology are available. If dose assessment results are available, declaration should be based on dose assessment instead of radiation monitor values.

26 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 HNP HNP EAL Wording Difference Justification EAL # EAL #

1 Lowering of spent fuel pool level RS2.1 Lowering of spent fuel pool level -< Post-Fukushima order EA-12-051 required the installation of to (site-specific Level 3 value) 260.7 ft. (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).

The SFP level instruments consist of a three independent remote indicating channels (LI-5101A, LI-5102A and LI-5103A) each spanning approximately 25 ft. (260 ft. - 285 ft.

indicated). Level 3 corresponds to an indicated SFP level of 260.7 ft. which is the top of the SFP racks.

27 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording lC#(s) HNP IC Wording Difference Justification 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 5,000 than 1,000 mrem TEDE or 5,000 mrem thyroid CDE. mrem thyroid CDE MODE: All MODE: All NEI Ex. NEI Example EAL Wording HNP HNP EAL Wording Difference Justification EAL # EAL #

Reading on ANY of the following RG1.1 Reading on any Table R-1 effluent The HNP radiation monitors that detect radioactivity effluent release radiation monitors greater than radiation monitor > column "GE" to the environment are listed in Table R-1. UE, Alert, SAE and GE the reading shown for 15 for > 15 min. thresholds for all HNP continuously monitored gaseous or liquid minutes or longer: (Notes 1, 2, 3, 4) release pathways are listed in Table R-1 to consolidate the (site-specific monitor list and 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 site boundary is the site-specific receptor point.

meteorology indicates doses meteorology indicates doses >

greater than 1,000 mrem TEDE 1,000 mrem TEDE or or 5,000 mrem thyroid CDE at 5,000 mrem thyroid CDE at or or beyond (site-specific dose beyond the SITE BOUNDARY receptor point). (Notes 3, 4) 3 Field survey results indicate RG1.3 Field survey results indicate The site 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 SITE BOUNDARY:

receptor point): e Closed window dose rates >

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

expected to continue for 60 minutes or longer. e Analyses of field survey

• Analyses of field survey samples indicate thyroid CDE samples indicate thyroid CDE > 5,000 mrem for 60 min. of greater than 5,000 mrem for inhalation.

28 of 113

EAL Comparison Matrix one hour 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 HNP EAL scheme by referencing the "time limit" specified within the Emergency promptly upon declare the event EAL wording and deleting the specific classification.

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

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

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

• The pre-calculated effluent VALID for classification monitor values presented in purposes.

EAL #1 should be used for emergency classification Note 4 The pre-calculated assessments until the results effluent monitor values Incorporated site-specific EAL numbers associated with generic from a dose assessment presented in EALs EAL#1.

using actual meteorology are RAI.1, RS1.1 and Added the words "Ifdose assessment results are available, available. RGI.1 should be used declaration should be based on dose assessment instead of for emergency radiation monitor values." to reinforce the intent of the note.

classification assessments until the results from a dose assessment using actual meteorology are available. If dose assessment results are available, declaration 29 of 113

EAL Comparison Matrix should be based on dose assessment instead of radiation monitor values.

30 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 NEI EALEx.

E HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 1 Spent fuel pool level cannot be RG2.1 Spent fuel pool level cannot be Post-Fukushima order EA-12-051 required the installation restored to at least (site-specific restored to at least 260.7 ft. (Level 3) of reliable SFP level indication capable of identifying normal Level 3 value) for 60 minutes or for > 60 min. (Note 1) level (Level 1), SFP level 10 ft. above the top of the fuel racks longer (Level 2) and SFP level at the top of the fuel racks (Level 3).

The SFP level instruments consist of a three independent remote indicating channels (LI-5101A, LI-5102A and LI-5103A) each spanning approximately 25 ft. (260 ft. - 285 ft.

indicated). Level 3 corresponds to an indicated SFP level of 260.7 ft. which is the top of the SFP racks.

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 HNP EAL scheme by referencing the "time limit" promptly upon determining that promptly upon determining specified within the EAL wording and deleting the specific 60 minutes has been exceeded, that time limit has been classification.

or will likely be exceeded. exceeded, or will likely be exceeded.

31 of 113

EAL Comparison Matrix Category C Cold Shutdown I Refueling System Malfunction 32 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification CUI UNPLANNED loss of (reactor CUI 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, 6 -

MODE: Cold Shutdown, Refueling Refueling NEI EALEx.

1. HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 1 UNPLANNED loss of reactor CU1.1 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 ? 15 min. (Note 1) required lower limit for 15 minutes or longer.

2 a. (Reactor vessel/RCS [PWR] CU1.2 RCS water level cannot be Added the phrase "due to a loss of RCS inventory" because the NEI or RCP [BWR]) level cannot monitored basis states: "Sump and/or tank level changes must be evaluated be monitored. AND EITHER against other potential sources of water flow to ensure they are AND Uindicative of leakage from the RCS."

any Table C-i sump or tank Table C-1 lists site-specific applicable sumps and tanks.

b. UNPLANNED increase in due to a loss of RCS Added bulleted criteria "Visual observation of UNISOLABLE RCS (site-specific sump and/or inventory leakage" to include direct observation of RCS leakage.

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 HNP EAL scheme by referencing the "time limit" specified within the Event promptly upon declare the event EAL wording and deleting the specific classification.

determining that 15 minutes promptly upon has been exceeded, or will determining that time likely be exceeded. limit has been 33 of 113

EAL Comparison Matrix exceeded, or will likely be exceeded.

Table C-1 Sumps I Tanks

• Containment sumps

• PRT

• RCDT

• CCW surge tank

• RAB sumps

• RWST

• RMWST

• Recycle Holdup Tank 34 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification CU2 Loss of all but one AC power CU2 Loss of all but one AC power None source to emergency buses for source to emergency buses for 15 minutes or longer. 15 minutes or longer.

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

Refueling, Defueled Refueling, D - Defueled NEI E# Ex. HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification EAL # EAL #

1 a. AC power capability to (site- CU2.1 AC power capability to 6.9 KV buses 1A-SA and 1B-SB are the site-specific emergency specific emergency buses) is emergency 6.9 KV buses 1A-SA buses.

reduced to a single power and 1B-SB reduced to a single source for 15 minutes or power source for > 15 min.

longer. (Note 1)

AND AND

b. Any source additional single failure will inAnadioalsgepwr Any additional single power power result source failure will result in loss of loss of all AC power to all AC power to SAFETY SAFETY SYSTEMS. 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 HNP EAL scheme by referencing the "time limit" specified within the promptly upon determining that declare the event EAL wording and deleting the specific classification.

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

35 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification CU3 UNPLANNED increase in RCS CU3 UNPLANNED increase in RCS None temperature temperature MODE: Cold Shutdown, MODE: Cold Shutdown, 6 -

Refueling Refueling NEI EALEx.

E HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 1 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 > 200OF due to limit.

specific Technical Specification loss of decay heat removal Added "due to loss of decay heat removal capability" to reinforce the cold shutdown temperature limit) capability 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 > 15 min.

or RCP [BWR]) level indication (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 HNP EAL scheme by referencing the "time limit" specified within the promptly upon determining that declare the event EAL wording and deleting the specific classification.

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

36 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 EA Ex.

E HNP NEI Example EAL Wording HL # HNP EAL Wording Difference Justification EAL # EAL 1 Indicated voltage is less than CU4.1 < 105 VDC bus voltage indications 105 VDC is the site-specific minimum vital DC bus voltage.

(site-specific bus voltage value) on Technical Specification DC operability requirements are specified in Technical on required Vital DC buses for 15 required 125 VDC buses (DP-1A- Specifications.

minutes or longer. SA, DP-1 B-SB) for > 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 HNP EAL scheme by referencing the "time limit" specified within promptly upon determining that declare the event promptly the EAL wording and deleting the specific classification.

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

37 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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, 6 -

Refueling, Defueled Refueling, D - Defueled NEI Ex. NEI Example EAL Wording HNP EAL HNP EAL Wording Difference Justification EAL # EAL #

1 Loss of ALL of the following CU5.1 Loss of all Table C-4 onsite Example EALs #1, 2 and 3 have been combined into a single onsite communication methods: communication methods EAL for simplification of presentation.

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

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

(site specific list of communications methods) 38 of 113

EAL Comparison Matrix Table C-4 Communication Methods System Onsite ORO NRC PABX telephone (desk phones) X X X HE&EC PABX telephone X X Site paging system X Satellite phone X X DEMNET X Radio communications networks X NRC ETS phone X NRC HPN phone X 39 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification CA1 Loss of (reactor vessel/RCS CA1 Loss of RCS inventory None

[PWR] or RCP [BWR]) inventory MODE: Cold Shutdown, 6 -

MODE: Cold Shutdown, Refueling Refueling NEI Ex. NEI Example EAL Wording HNP# HNP EAL Wording Difference Justification EAL # EAL 1 Loss of (reactor vessel/RCS CAl.1 Loss of RCS inventory as LI-403 or RCS standpipe level of - 82" corresponds to the minimum

[PWR] or RCP [BWR]) inventory indicated by LI-403 or RCS RCS level for continued RHR pump operation.

as indicated by level less than standpipe level < - 82 in.

(site-specific level).

2 a. (Reactor vessel/RCS [PWR] CA1.2 RCS water level cannot be Added the phrase "due to a loss of RCS inventory" because the NEI or RCP [BWR]) level cannot monitored for > 15 min. (Note 1) basis states: "Sump and/or tank level changes must be evaluated be monitored for 15 minutes against other potential sources of water flow to ensure they are or longer AND EITHER indicative of leakage from the RCS."

AND 9 UNPLANNED increase in Table C-1 lists site-specific applicable sumps and tanks.

any Table C-1 sump or tank

b. UNPLANNED increase in due to a loss of RCS Added bulleted criteria "Visual observation of UNISOLABLE RCS (site-specific sump and/or inventory leakage" to include direct observation of RCS leakage.

tank) levels(reatorvessl/RS due to a loss of

[PR] Visual observation of (reactor vessel/RCS [PWR] UNISOLABLE RCS leakage or RCP [BWR]) inventory.

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 declare the HNP EAL scheme by referencing the 'time limit" specified within the determining that 15 minutes has event promptly upon EAL wording and deleting the specific classification.

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

40 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification CA2 Loss of all offsite and all onsite CA2 Loss of all offsite and all onsite None AC power to emergency buses AC power to emergency buses for 15 minutes or longer for 15 minutes or longer.

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

Refueling, Defueled Refueling, D - Defueled NEI EALEx.

1. HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification 1 Loss of ALL offsite and ALL CA2.1 Loss of all offsite and all onsite 6.9 KV buses 1A-SA and 1B-SB are the site-specific emergency onsite AC Power to (site-specific AC power capability to 6.9 KV buses.

emergency buses) for 15 emergency buses 1A-SA and minutes or longer. 1 B-SB for > 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 Alert promptly upon Coordinator should HNP EAL scheme by referencing the "time limit" specified within the determining that 15 minutes has declare the event EAL wording and deleting the specific classification.

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

41 of 113

EAL Comparison Matrix r I r 1 r HNP NEI IC# NEI IC Wording HNP IC Wording Difference 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, 6 -

Refueling Refueling NEI EALEx. HNP E NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 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 > 200OF for as EAL # is the alternative threshold based on a loss of RCS (site-specific Technical > Table C-3 duration temperature indication.

Specification cold shutdown (Note 1) 200°F is the site-specific Tech. Spec. cold shutdown temperature temperature limit) for greater OR limit.

than the duration specified in the following table. CA3.1 UNPLANNED RCS pressure Table C-3 is the site-specific implementation of the generic RCS increase > 10 psig due to a Heat-up Duration Threshold table.

2 UNPLANNED RCS pressure loss of RCS cooling (this does 10 psig is the site-specific pressure increase readable by Control increase greater than (site- not apply during water-solid Room indications.

specific pressure reading). (This plant conditions)

EAL does not apply during water-solid plant conditions.

[PWR])

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 HNP EAL scheme by referencing the "time limit" specified within determining that 15 minutes has declare the event the EAL wording and deleting the specific classification.

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

42 of 113

EAL Comparison Matrix 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-3: RCS Heat-up Duration Thresholds RCS Status Containment Closure Status Heat-up Duration Intact (but not REDUCED N/A 60 min.*

INVENTORY)

Not intact established 20 min.*

OR At 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 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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, 6 -

Refueling Refueling 44 of 113

EAL Comparison Matrix NEI Ex. NEI Example EAL Wording EAL #_j__________

IAHNP EAL #

HNP EAL Wording Difference Justification 1 a. The occurrence of ANY of CA6.1 The hazardous events have been tabularized in Table C-5.

The occurrence of any Table the following hazardous C-5 hazardous event events:

" Seismic event AND EITHER:

(earthquake)

" Internal or external " Event damage has caused flooding event indications of degraded

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

" FIRE operating mode

" EXPLOSION

• (site-specific hazards) " 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 oWeratina mode.

45 of 113

EAL Comparison Matrix Table C-5 Hazardous Events

" Seismic event (earthquake)

" Internal or external FLOODING event

" High winds or tornado strike

" FIRE

" EXPLOSION

• Other events with similar hazard characteristics as determined by the Shift Manager 46 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification CS1 Loss of (reactor vessel/RCS CS1 Loss of RCS inventory affecting None

[PWRI or RCP [BWR]) inventory core decay heat removal affecting core decay heat capability removal capability. MODE: Cold Shutdown, 6 -

MODE: Cold Shutdown, Refueling Refueling HNP EALEx.

NEI # NEI Example EAL Wording AL # HNP EAL Wording Difference Justification

a. CONTAINMENT CLOSURE CSI. 1 With CONTAINMENT 70% RVLIS Full Range corresponds to the level of six inches below not established. CLOSURE not established, the bottom ID of the RCS hot leg penetration (252.04' el.). 6% has AND RCS level < 70% RVLIS Full been added to the RVLIS setpoint to account for instrument Range uncertainties.

b. (Reactor vessel/RCS [PWR]

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

2 a. CONTAINMENT CLOSURE CS1.2 With CONTAINMENT 63% RVLIS Full Range corresponds to the top of active fuel (249.01' established. CLOSURE established, RCS el.). Other RCS level instruments are off-scale low when core AND level < 63% RVLIS Full Range uncovery occurs. 6% has been added to the RVLIS setpoint to account for instrument uncertainties.

b. (Reactor vesseVRCS [PWR]

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

3 a. (Reactor vessel/RCS [PWR] CS1.3 RCS water level cannot be Added bulleted criteria "Visual observation of UNISOLABLE RCS or RCP [BWR]) level cannot monitored for > 30 min. (Note 1) leakage" to include direct observation of RCS leakage.

be monitored for 30 minutes or longer. AND or longer. Core Core uncover uncovery isisns iindicated d by b Table C-1 lists site-specific applicable sumps and tanks.

AND any of the following: The dose rate due to this core shine should result in indications on 9 UNPLANNED increase in installed area radiation monitors (RM-1CR-3589-SA or RM-ICR-

b. Core uncovery is indicated by 3590-SB). If these radiation monitors reach and exceed 10,000 R/hr, ANY of the following: due to a loss of RCS a loss of inventory with potential to uncover the core is likely to have 47 of 113

EAL Comparison Matrix

" (Site-specific radiation inventory occurred.

monitor) reading greater than (site-specific value) " Visual observation of unisolable RCS leakage

" Erratic source range monitor indication [PWR] " Containment radiation >

10,000 R/hr (RM-1CR-3589-

" UNPLANNED increase in SA or RM-1 CR-3590-SB)

(site-specific sump and/or tank) levels of sufficient " Erratic source range monitor magnitude to indicate indication core uncovery

" (Other site-specific 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 HNP EAL scheme by referencing the "time limit" specified within the Emergency promptly upon declare the event EAL wording and deleting the specific classification.

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 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification CG1 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, 6 -

MODE: Cold Shutdown, Refueling Refueling NEI EALEx.

1. HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 1 a. (Reactor vessel/RCS [PWR] or CG1.1 RCS level < 63% RVLIS Full 63% RVLIS Full Range corresponds to the top of active fuel RCP [BWR]) level less than Range for > 30 min. (Note 1) (249.01' el.). Other RCS level instruments are off-scale low when (site-specific level) for 30 AND core uncovery occurs. 6% has been added to the RVLIS setpoint minutes or longer. Any Containment Challenge to account for instrument uncertainties.

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

b. ANY indication from the indications.

Containment Challenge Table 4% hydrogen concentration in the presence of oxygen represents (see below), an explosive mixture in containment.

2 a. (Reactor vessel/RCS [PWRI or CG1.2 RCS water level cannot be Added bulleted criteria "Visual observation of UNISOLABLE RCS RCP [BWR]) level cannot be monitored for > 30 min. (Note 1) leakage" to include direct observation of RCS leakage.

monitored for 30 minutes or AND The dose rate due to this core shine should result in indications on longer. Core uncovery is indicated by installed area radiation monitors (RM-1 CR-3589-SA or RM-1 CR-AND any of the following: 3590-SB). If these radiation monitors reach and exceed 10,000 b UNPLANNED increase in R/hr, a loss of inventory with potential to uncover the core is likely ANY of the following: any Table C-1 sump or to have occurred.

tank due to a loss of RCS Table C-1 lists site-specific applicable sumps and tanks.

• (Site-specific radiation inventory monitor) reading greater Table C-2 provides a tabularized list of containment challenge than (site-specific value) Visual observation of indications.

tErratic source range leakage 4% hydrogen concentration in the presence of oxygen represents I monitor indication [PWR] an explosive mixture in containment.

monitorinindicationt[oWR]

49 of 113

EAL Comparison Matrix

• UNPLANNED increase in 10,000 R/hr (RM-1 CR-(site-specific sump and/or 3589-SA or RM-1CR-tank) levels of sufficient 3590-SB) magnitude uncovery to indicate core *Erratic source range monitor indication

• (Other site-specific AND indications)

AND Any Containment Challenge indication, Table C-2

c. ANY indication from the 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 HNP EAL scheme by referencing the "time limit" specified promptly upon determining that declare the event within the EAL wording and deleting the specific classification.

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

" 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 113

EAL Comparison Matrix Table C-2 Containment Challenge Indications

• CONTAINMENT CLOSURE not established (Note 6)

• Containment hydrogen concentration > 4%

• UNPLANNED rise in Containment pressure 51 of 113

EAL Comparison Matrix Category D Permanently Defueled Station Malfunction 52 of 113

EAL Comparison Matrix

.1-- r HNP NEI IC# NEI IC Wording HNP IC Wording Difference Justification IC#(s)

I I I 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. HNP is not a defueled station.

PD-SU1 PD-HU1 PD-HU2 PD-HU3 PD-AA1 PD-AA2 PD-HA1 PD-HA3 53 of 113

EAL Comparison Matrix Category E Independent Spent Fuel Storage Installation 54 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification E-HU1 Damage to a loaded cask N/A N/A HNP does not have an ISFSI.

CONFINEMENT BOUNDARY MODE: All NEI EALEx.

E HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification 1 Damage to a loaded cask N/A N/A HNP does not have an ISFSI.

CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific technical specification allowable radiation level) on the surface of the spent fuel cask.

55 of 113

EAL Comparison Matrix Category F Fission Product Barrier Degradation 56 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification FA1 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. HNP EAL # NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 1 Any Loss or any Potential Loss of FA1.1 Any loss or any potential loss of Table F-1 provides the fission product barrier loss and potential loss either the Fuel Clad or RCS either Fuel Clad or RCS (Table thresholds.

barrier. F-i) 57 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 EALEx.

E HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 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 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification FG1 Loss of any two barriers and Loss FG1 Loss of any two barriers and loss None or Potential Loss of third barrier or potential loss of the third MODE: Power Operation, Hot barrier Standby, Startup, Hot Shutdown MODE: 1 - Power Operation, 2 -

Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI EALEx.

E HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification 1 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 113

EAL Comparison Matrix PWR Fuel Clad Fission Product Barrier Degradation Thresholds NEI NEI HNP NEI Threshold Wording FP HNP FPB Wording Difference 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 entry 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 Containment radiation monitor readings greater than 150.3 R/hr, 3 A. Containment radiation CA >150 R/hr rounded to 150 R/hr for readability, indicate the release of reactor monitor reading greater than (RM-1CR-3589-SA or coolant, with elevated activity indicative of fuel damage, into the (site-specific value) RM-1CR-3590-SB) Containment. The reading is derived assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine OR inventory associated with a concentration of 300 pCi/cc dose B. (Site-specific indications equivalent 1-131 into the Containment atmosphere.

that reactor coolant activity is ghatreater th 3 lant dose ii/m FC Loss Dose equivalent 1-131 coolant greater than 300 ýtCi/gm dose activity > 300 pCi/gm None equivalent 1-131) C.2 FC Loss CNMT Integrity or Bypass N/A N/A N/A 4 Not Applicable FC Loss Other Indications N/A N/A No other site-specific Fuel Clad Loss indication has been identified 5 A. (site-specific as applicable) for HNP.

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EAL Comparison Matrix NEI --- HNP FPB NEI Threshold Wording FP HNP FPB Wording Difference Justification FPB# FP13 #(s)

FC Loss ED Judgment FC Loss Any condition in the opinion of None 6 ANY condition in the A. E.1 the Emergency Coordinator 6oA.iAni ofconion the y Em 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-Loss A. Core exit thermocouple P-Loss ORANGE Path entry Cooling Orange Path is used in lieu of CET temperatures.

2 readings greater than (site- B.1 conditions met 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 entry 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 (sierate-speci indicatiiedbneed for classification for conditions in which RCS pressure is less (site-specific indications). Heat sink is required than SG pressure or Heat Sink-RED path entry was created through operator action directed by an EOP.

FC RCS ActivitylCMNT 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 A. (site-specific as applicable) identified for HNP.

5 61 of 113

EAL Comparison Matrix NEI FPB HNP NEI Threshold Wording FP #(s) HNP FPB Wording Difference 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 113

EAL Comparison Matrix PWR RCS Fission Product Barrier Degradation Thresholds NEI NEI IC Wording HNP FPB HNP FPB Wording Difference Justification FPB# #(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 ECCS (SI) actuation is by EITHER:

required by EITHER of the 9 UNISOLABLE RCS following: leakage

1. UNISOLABLE RCS e 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 ActivitylCMNT Rad RCS Loss Containment Leak Detection Containment radiation monitor readings on REM-1 LT-3502A-SA Loss A. Containment radiation C.1 Monitor Noble Gas (REM-1 LT- noble gas channel greater than 8.3E-3 pCi/mI indicate the release 3 monitor reading greater than 3502A-SA) > 8.3E-3 pCi/ml of reactor coolant to the Containment. The readings assume the instantaneous release and dispersal of the reactor coolant noble (site-specific value). gas and iodine inventory associated with normal operating concentrations (i.e., within Technical Specifications) into the Containment atmosphere.

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 HNP.

A. (site-specific as applicable) 5 63 of 113

EAL Comparison Matrix NEI FPB HNP FPB NEI IC Wording #(s HNP FPB Wording Difference Justification FPB# #(s)

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

RCS RCS or SG Tube Leakage RCS RCS leakage > normal HNP makeup capacity is not limited by charging pump capacity P-Loss 1 A. Operation of a standby P-Loss A.1 makeup capacity (> 120 gpm) but by makeup line flow capacity. Normal maximum makeup flow charging (makeup) pump is due to EITHER: with letdown isolated is -120 gpm.

required by EITHER of the 9 UNISOLABLE RCS following: leakage

1. UNISOLABLE RCS 9 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 entry 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 2 A. Inadequate RCS heat P-Loss B.1 conditions met Sink Red Path is used.

removal capability via steam 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.

RCS CS ActivitylCMNT Rad N/A N/A N/A P-Loss 3 Not Applicable 64 of 113

- - EAL. Comparison Matrix NEI FPB HNP FPB NEI IC Wording #(s HNP FPB Wording Difference Justification FPB# #(s)

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

P-Loss 5 RCS Emergency Director Judgment RCS Any condition in the opinion of None P-Loss 6 A. ANY condition in the opinion P-Loss E.1 the Emergency Coordinator that Po he6 A.eANY ncnDitiontin the opindicates potential loss of the of the Emergency Director that RCS barrier indicates Potential Loss of the RCS Barrier.

65 of 113

EAL Comparison Matrix PWR Containment Fission Product Barrier Degradation Thresholds NEI NEI HNP NEI IC Wording FP HNP FPB Wording Difference Justification FPB# FPB #(s)

CNMT RCS or SG Tube Leakage CNMT A leaking or RUPTURED SG is None Loss A. A leaking or RUPTURED SG is 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 CNMT Containment isolation is required None Loss A. Containment isolation is required Loss AND EITHER:

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

1. Containment integrity lost based on Emergency

• UNISOLABLE pathway from Director judgment. containment to the environment exists OR

2. UNISOLABLE pathway from CNMT 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 113

EAL Comparison Matrix NEI NEI IC Wording FP HNP FPB Wording Difference Justification FPB# FPB #(s)

CNMT Other Indications N/A N/A No other site-specific Containment Loss indication has Loss been identified for HNP.

A. (site-specific as applicable) 5 CNMT Emergency Director Judgment CNMT Any condition in the opinion of the None Loss ANY condition in the opinion of the Loss Emergency Coordinator that indicates 6 E.1 loss of the containment barrier Emergency Director that indicates Loss of the Containment Barrier.

CNMT RCS or SG Tube Leakage N/A N/A N/A P-Loss Not Applicable 1

CNMT Inadequate Heat Removal CNMT CSFST Core Cooling-RED Path entry Consistent with the generic developers note options P-Loss A. 1. (Site-specific criteria for entry P-Loss conditions met CSFST Core Cooling Red Path is used in lieu of CET 2 into core cooling restoration B.1 AND temperatures and RCS levels.

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 CNMT Containment radiation > 600 R/hr (RM- Containment radiation monitor readings greater than P-Loss A. Containment radiation monitor P-Loss 1CR-3589-SA or RM-1 CR-3590-SB) 601.2 R/hr, rounded to 600 R/hr for readability, 3 reading greater than (site-specific C.1 indicate significant fuel damage well in excess of that value). required for loss of the RCS barrier and the Fuel Clad barrier.

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

67 of 113

EAL Comparison Matrix NEI HNP FPB NEI IC Wording FP HNP FPB Wording Difference Justification FPB# FPB #(s)

OR CNMT Containment hydrogen concentration 4% hydrogen concentration in the presence of oxygen B. Explosive mixture exists inside P-Loss > 4% represents an explosive mixture in containment.

containment D.2 OR C. 1. Containment pressure greater than (site-specific pressure setpoint) CNMT Containment pressure > 10 psig with < The Containment pressure setpoint (10 psig) is the AND P-Loss one full train of depressurization pressure at which the Containment Spray System

2. Less than one full train of (site- D.3 equipment operating (one CNMT should actuate. Limiting LOCA analyses assume one specific system or equipment) spray pump and two CNMT fan Containment Spray pump and two CNMT fan coolers is operating per design for 15 coolers) per design for > 15 min. (Note operate minutes or longer. 1 Added Note 1 consistent with other thresholds with a timing component.

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 HNP.

5 CNMT Emergency Director Judgment CNMT 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 E1 potential loss of the containment Potential Loss of the Containment barrier Barrier.

68 of 113

EAL Comparison Matrix Category H Hazards and Other Conditions Affecting Plant Safety 69 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification HU1 Confirmed SECURITY HU1 Confirmed SECURITY None CONDITION or threat CONDITION or threat.

MODE: All MODE: All NEI Ex. NEI Example EAL Wording HNP# HNP EAL Wording Difference Justification EAL # EAL 1 A SECURITY CONDITION that HUI.1 A SECURITY CONDITION that Example EALs #1, 2 and 3 have been combined into a single EAL does not involve a HOSTILE does not involve a HOSTILE for ease of presentation and use.

ACTION as reported by the (site- ACTION as reported by the The Security Shift Supervision is defined as the Security Shift specific security shift supervision). Security Shift Supervision Supervision.

2 Notification of a credible security OR threat directed at the site. Notification of a credible security threat directed at the site 3 A validated notification from the OR NRC providing information of an aircraft threat. A validated notification from the NRC providing information of an aircraft threat 70 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification HU2 Seismic event greater than OBE HU2 Seismic event greater than OBE None level level MODE: All MODE: All NEI EA Ex. HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification EAL # EAL #

1 Seismic event greater than HU2.1 Seismic event> OBE as The bulleted items represent site-specific OBE indications.

Operating Basis Earthquake indicated by any of the following:

(OBE) as indicated by: 9 ALB-10/4-4, SEISMIC MON (site-specific indication that a SYS OBE EXCEEDED is seismic event met or exceeded ALARMED OBE limits)

• ALARM light on Seismic Switch Power Supply is LIT

• Any red alarm light is LIT on the Response Spectrum Annunciator 71 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification HU3 Hazardous event. HU3 Hazardous event None MODE: All MODE: All NEI EA Ex.

E HNP NEI Example EAL Wording EAL HNP EAL Wording Difference 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 HNP.

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 113

EAL Comparison Matrix impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

73 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 EA Ex.

E HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification EAL # EAL #

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

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

" Report from the field (i.e.,

• Report from the field (i.e.,

visual observation) visual observation)

" Receipt of multiple (more 9 Receipt of multiple (more than 1) fire alarms or than 1) fire alarms or indications indications

" Field verification of a single o 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 list of site-specific fire areas.

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

AND AND

b. The FIRE is located within The fire alarm is indicating a 74 of 113

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 plant HNP does not have an ISFSI.

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

4 A FIRE within the plant or ISFSI HU4.4 A FIRE within the plant HNP does not have an ISFSI.

[for plants with an /SFS/ outside PROTECTED AREA that the plant ProtectedArea] requires firefighting support by PROTECTED AREA that requires an offsite fire response agency to firefighting support by an offsite 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 Event Coordinator should HNP EAL scheme by referencing the "time limit" specified within the promptly upon determining that declare the event EAL wording and deleting the word "Unusual".

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 113

EAL Comparison Matrix Table H-1 Fire Areas

• Containment

• Reactor Auxiliary Building

" Fuel Handling Building

• Turbine Building (including Transformer Area)

• Emergency Diesel Generator Building

• Diesel Fuel Oil Storage Building (DFOST)

• ESW Intake Structure

• Auxiliary Reservoir Intake Structure

• NSW Structure

" Switchyard

• Yard 261 Duct Banks serving any of the above areas 76 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification HU7 Other conditions exist which in the HU7 Other conditions existing that in None 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 HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification EAL # EAL #

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

77 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording lC#(s) HNP IC Wording Difference Justification 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 EA Ex.

E HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification EAL # EAL #

1 A HOSTILE ACTION is occurring or HA1.1 A HOSTILE ACTION is Example EALs #1 and #2 have been combined into a single EAL has occurred within the OWNER occurring or has occurred within for ease of use.

CONTROLLED AREA as reported the OWNER CONTROLLED The Security Shift Supervision is the site-specific security shift by the (site-specific security shift AREA as reported by the supervision.

supervision). Security Shift Supervision 2 A validated notification from NRC of OR an aircraft attack threat within 30 A validated notification from minutes of the site. NRC of an aircraft attack threat within 30 min. of the site 78 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification HA5 Gaseous release impeding N/A 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 EALEx.

1. HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 1 a. Release of a toxic, HA5.1 Release of a toxic, corrosive, Table R-3/H-2 provides a list of safe shutdown rooms/areas and corrosive, asphyxiant or asphyxiant or flammable gas into applicable operating modes.

flammable gas into any of the any Table R-3/H-2 rooms or following plant rooms or areas: areas (site-specific list of plant rooms AND or areas with entry-related Entry into the room or area is mode applicability identified) prohibited or IMPEDED (Note 5)

AND

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

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

79 of 113

EAL Comparison Matrix Table R-3/1H-2 Safe Operation & Shutdown RoomslAreas RoomlArea Mode(s)

RAB 190 (RHR pumps) 4 RAB 216 (BIT) 1,2,3,4,5 RAB 236 (CSIP, Primary Sample Sink, AFW pumps, CCW pumps and HX, Boric Acid Transfer Pumps, Mezzanine Area) 1, 2, 3, 4, 5 RAB 261 (RHR Heat Exchangers, Demin. Valve Gallery, VCT Valve Gallery) 1, 2, 3, 4, 5 RAB 286 (Switchgear) 3,4,5 Containment Building 3 Steam Tunnel 1, 2, 3, 4 ESW intakes 1,2,3,4, 5 80 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 EALEx,

1. HNP NEI Example EAL Wording AL # HNP EAL Wording Difference Justification 1 An event has resulted in plant HA6.l An event has resulted in plant ACP is the site-specific remote shutdown panels/local control control being transferred from the control being transferred from the stations.

Control Room to (site-specific Control Room to the ACP remote shutdown panels and local control stations).

81 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 HNP EAL HNP EAL Wording Difference 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 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 HNP HNP EAL Wording Difference Justification EAL # EAL #

1 A HOSTILE ACTION is occurring HS1.1 A HOSTILE ACTION is occurring or has The Security Shift Supervision is the site-specific security or has occurred within the occurred within the PROTECTED AREA shift supervision.

PROTECTED AREA as reported as reported by the Security Shift by the (site-specific security shift Supervision supervision).

83 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording HNP ICWording Difference Justification IC#(s)

HS6 Inability to control a key safety HS6 Inability to control a key safety function None function from outside the Control Room. from outside the Control Room MODE: All MODE: All NEI EALEEx. HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 1 a. An event has resulted in plant HS6.1 An event has resulted in plant control The ACP is the site-specific remote shutdown panels/local control being transferred from the being transferred from the Control Room control stations.

Control Room to (site-specific to the ACP 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

• RCS heat removal

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

" RCS heat removal 84 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 EA Ex.

E HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification EAL # EAL #

Other conditions exist which in HS7.1 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 likely likely major failures of plant functions major failures of plant functions needed for protection of the public or needed for protection of the HOSTILE ACTION that results in public or HOSTILE ACTION that intentional damage or malicious acts, (1) results in intentional damage or toward site personnel or equipment that malicious acts, (1) toward site could lead to the likely failure of or, (2) that personnel or equipment that could prevent effective access to equipment lead to the likely failure of or, (2) needed for the protection of the public.

that prevent effective access to Any releases are not expected to result in equipment needed for the exposure levels which exceed EPA protection of the public. Any Protective Action Guideline exposure releases are not expected to levels beyond the SITE BOUNDARY.

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

85 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference 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 EA Ex. HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification EAL # EAL #

1 a. A HOSTILE ACTION is HG1.1 A HOSTILE ACTION is occurring or has The Security Shift Supervision is the site-specific security occurring or has occurred within occurred within the PROTECTED AREA shift supervision.

the PROTECTED AREA as as reported by the Security Shift reported by the (site-specific Supervision security shift supervision). AND EITHER of the following has AND occurred:

b. EITHER of the following has Any of the following safety functions occurred: cannot be controlled or maintained

1. ANY of the following safety 9 Reactivity control functions cannot be controlled or maintained.

" Reactivity control o RCS heat removal

" Core cooling OR

[PWR]IRCP water Damage to spent fuel has occurred level [BWR] or is IMMINENT

" RCS heat removal OR

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

86 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 EALEx.

E HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 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 113

EAL Comparison Matrix Category S System Malfunction 88 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification SU1 Loss of all offsite AC power SU1 Loss of all offsite AC power None capability to emergency buses for capability to emergency 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 EALEx. HNP

1. NEI Example EAL Wording EAL HNP EAL Wording Difference Justification 1 Loss of ALL offsite AC power SUI.1 Loss of all offsite AC power 6.9 KV buses 1A-SA and 1 B-SB are the site-specific emergency capability to (site-specific capability to 6.9 KV emergency buses.

emergency buses) for 15 minutes buses 1A-SA and 1B-SB for > 15 or longer. 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 HNP EAL scheme by referencing the "time limit" specified within the promptly upon determining that 15 declare the event EAL wording and deleting the word "Unusual".

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

89 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 HNP HNP EAL Wording Difference Justification EAL # EAL #

1 An UNPLANNED event results in SU3.1 An UNPLANNED event results in The site-specific Safety System Parameters are listed in Table S-1.

the inability to monitor one or the inability to monitor one or more of the following parameters more Table S-1 parameters from from within the Control Room for within the Control Room for > 15 15 minutes or longer. 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 HNP EAL scheme by referencing the "time limit" specified within the promptly upon determining that declare the event EAL wording and deleting the word "Unusual".

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 113

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 I __ IFeed Water Flow Table S-1 Safety System Parameters

• Reactor power

• RCS level

• RCS pressure

• Core exit T/C temperature

• Level in at least one S/G

• Auxiliary or emergency feed flow in at least one S/G 91 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification SU3 Reactor coolant activity greater SU4 RCS activity greater than Changed 'reactor coolant activity" to "RCS activity" to conform to site than Technical Specification Technical Specification allowable specific terminology.

allowable limits, limits MODE: Power Operation, Startup, MODE: 1 - Power Operation, 2 -

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

E HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification EAL # EAL #

1 (Site-specific radiation monitor) SU4.2 Valid Gross Failed Fuel Detector The Gross Failed Fuel Detector System continuously monitors the reading greater than (site-specific (RS-741 1A) high alarm (> 1E+04 delayed neutron activity in a sample drawn from the RCS. This value). cpm) provides a rapid indication of gross amounts of fission products contained in the RCS resulting from possible fuel defects.

2 Sample analysis indicates that a SU4.1 RCS activity > Technical Changed 'reactor coolant activity" to "RCS activity" to conform to site reactor coolant activity value is Specification Section 3.4.8 limits specific terminology.

greater than an allowable limit HNP T.S. Section 3.4.8 provides the TS allowable coolant activity specified in Technical limits.

Specifications.

92 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification SU4 RCS leakage for 15 minutes or SU5 RCS leakage for 15 minutes or None longer, longer MODE: Power Operation, MODE: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI EALEx.

E HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 1 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 > 10 gpm for > for usability.

(site-specific value) for 15 15 min.

minutes or longer. OR 2 RCS identified leakage greater RCS identified leakage > 25 gpm than (site-specific value) for 15 for ? 15 min.

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

minutes or longer. (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 HNP EAL scheme by referencing the "time limit" specified within the promptly upon determining that declare the event EAL wording and deleting the word "Unusual".

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

93 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification SU5 Automatic or manual (trip [PWR] SU6 Automatic or manual trip fails to None

/ scram [BWR]) fails to shut down the reactor shutdown the reactor. MODE: 1 - Power Operation MODE: Power Operation NEI EALEx.

1. HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification

a. An automatic (trip [PWR] I 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 > 5% after any shutdown in an EAL statement, the Basis or both (e.g., a reactor AND RPS setpoint is exceeded power level)." Reactor power < 5% is the site-specific indication of a AND successful reactor trip.

b. A subsequent manual action taken at the reactor control A subsequent automatic trip or Added the words "... as indicated by reactor power > 5% after any consoles is successful in manual trip action taken at the RPS setpoint is exceeded" to clarify that it is a failure of the shutting down the reactor. reactor control console (actuation automatic trip when a valid trip signal has been exceed.

of MCB Reactor Trip Switch #1, Actuation of MCB Reactor Trip Switch #1, #2 or MCB Turbine Trip

1. 2 or MCB Turbine Trip switch) is switch are the site-specific reactor control console trip switches successful in shutting down the credited for a successful manual trip.

reactor as indicated by reactor power < 5% (Note 8) 2 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 > 5% after any shutdown in an EAL statement, the Basis or both (e.g., a reactor AND manual trip action was initiated power level)." Reactor power < 5% is the site-specific indication of a AND successful reactor trip.

b. EITHER of the following:

A subsequent automatcllowin: Added the words "... as indicated by reactor power > 5% after any

1. A subsequentmanualA subsequent automatic trip or manual trip action was initiated" to clarify that it is a failure of any

1. Asubsquet maualmanual trip action taken at the action taken at the reactor reactor control console (actuation manual trip when an actual manual trip signal has been inserted.

control consoles is of MCB Reactor Trip Switch #1, Combined conditions b.1 and b.2 into a single statement to simplify successful in shutting #2 or MCB Turbine Trip switch) is the presentation.

94 of 113

EAL Comparison Matrix down the reactor. successful in shutting down the Actuation of MCB Reactor Trip Switch #1, #2 or MCB Turbine Trip OR reactor as indicated by reactor switch are the site-specific reactor control console trip switches power < 5% (Note 8) credited for a successful manual trip.

2 A subsequent automatic (trip [PWR] / scram

[BWR]) is successful in 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.

95 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 EI Ex.

E HNP NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification EAL##A 1 Loss of ALL of the following SU7.1 Loss of all Table S-3 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-3 provides a site-specific list of onsite, ORO and NRC communications methods) Loss of all Table S-3 ORO communications methods.

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

(site-specific list of communications methods) 96 of 113

EAL Comparison Matrix Table S-3 Communication Methods System Onsite ORO NRC PABX telephone (desk phones) X X X HE&EC PABX telephone X X Site paging system X Satellite phone X X DEMNET X Radio communications networks X NRC ETS phone X NRC HPN phone X 97 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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: 1 - Power Operation, 2 -

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI EALEx.

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

b. ALL required penetrations OR The containment pressure setpoint (10 psig) is the pressure at are not closed within 15 minutes Containment pressure > 10 which the containment depressurization equipment should actuate of the actuation signal. < one full quipentand psig withdeprssuizaton train of begin performing its function.

SU8.1 depressurization equipment 2 a. Containment pressure operating (one CNMT spray greater than (site-specific pump and two CNMT fan pressure). coolers) per design for

> 15 min.

(Note 1)

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 98 of 113

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

99 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification SA1 Loss of all but one AC power SA1 Loss of all but one AC power None source to emergency buses for source to emergency buses for 15 minutes or longer. 15 minutes or longer.

MODE: Power Operation, Startup MODE: 1 - Power Operation EALEx.

NEI HNP E NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification 1 a. AC power capability to (site- SAI.1 AC power capability to 6.9 KV 6.9 KV buses 1A-SA and 1 B-SB are the site-specific emergency specific emergency buses) is emergency buses 1A-SA and 1B- buses.

reduced to a single power source SB reduced to a single power for 15 minutes or longer, source for > 15 min. (Note 1)

AND AND

b. Any additional single power Any additional single power source failure will result in a loss source failure will result in loss of of all AC power to SAFETY all AC power to SAFETY SYSTEMS. 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 HNP EAL scheme by referencing the "time limit" specified within the determining that 15 minutes has declare the event EAL wording and deleting the word "Alert".

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

100 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference 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: I - Power Operation, 2 -

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

E HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification EAL # EAL #

1 An UNPLANNED event results in SA3.1 An UNPLANNED event results in The site-specific Safety System Parameters are listed in Table S-1.

the moreinability ofability the to monitor one or folltowing pamor the inability to monitor one or more of the following parameters more Tabilet te Table t-1 parmters from S-1 parameters foro The site-specific significant transients are listed in Table S-2.

from within the Control Room for within the Control Room for > 15 HNP is a PWR and thus does not include thermal power oscillations 15 minutes or longer. min. (Note 1) > 10%.

AND AND ANY of the following transient Any significant transient is in events in progress. progress, Table S-2

• Automatic or manual 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]

101 of 113

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 HNP EAL scheme by referencing the "time limit" specified within the promptly upon determining that declare the event EAL wording and deleting the word "Alert".

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] [PWVR 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-1 Safety System Parameters

• Reactor power

• RCS level

• RCS pressure

• Core exit T/C temperature

• Level in at least one S/G

• Auxiliary or emergency feed flow in at least one S/G 102 of 113

EAL Comparison Matrix Table S-2 Significant Transients

• Reactor trip

• Runback > 25% thermal power

• Electrical load rejection > 25% electrical load

• Safety injection actuation 103 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 taken manual actions taken at the at the reactor control consoles reactor control consoles are not are not successful in shutting successful in shutting down the down the reactor reactor. MODE: 1 - Power Operation MODE: Power Operation NEI EA Ex. HNP NEI Example EAL Wording HL # HNP EAL Wording Difference Justification EAL # EAL 1 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 2 5% power level)." Reactor power < 5% is the site-specific indication of a AN D successful reactor trip.

at the

b. Manual actions taken reactor control consoles are not Manual trip actions taken at the Actuation of MCB Reactor Trip Switch #1, #2 or MCB Turbine Trip successful in shutting down the reactor control console (actuation switch are the site-specific reactor control console trip switches reactor. of MCB Reactor Trip Switch #1, credited for a successful manual trip.

1. 2 or MCB Turbine Trip switch) are not successful in shutting down the reactor as indicated by reactor power 2!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 ato rwhich actions, ach causes 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 rand ins not implementation of boron injection include manually driving in control rods or 104 of 113

EAL Comparison Matrix 105 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification SA9 Hazardous event affecting a SA9.1 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 106 of 113

EAL Comparison Matrix NEI Ex. NEI Example EAL Wording HNP# HNP EAL Wording Difference Justification EAL #_[__________ EAL #_

I a. The occurrence of ANY of SA9.1 The occurrence of any Table S- The hazardous events have been listed in Table S-4.

the following hazardous events: 4 hazardous event

" Seismic event (earthquake) AND EITHER:

" 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.

107 of 113

EAL Comparison Matrix Table S-4 Hazardous Events

" Seismic event (earthquake)

" Internal or external FLOODING event

" High winds or tornado strike

" FIRE

" EXPLOSION

" Other events with similar hazard characteristics as determined by the Shift Manager 108 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification SS1 Loss of all offsite and all onsite SS1 Loss of all offsite and all onsite None AC power to emergency buses AC power to emergency 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 HNP HNP EAL Wording Difference Justification EAL # EAL #

1 Loss of ALL offsite and ALL SS1.1 Loss of all offsite and all onsite 6.9 KV buses 1A-SA and 1B-SB are the site-specific emergency onsite AC power to (site-specific AC power capability to 6.9 KV buses.

emergency buses) for 15 minutes emergency buses 1A-SA and or longer. 1B-SB for >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 Site Area Emergency Coordinator should HNP EAL scheme by referencing the "time limit" specified within the promptly upon determining that declare the event EAL wording and deleting the specific classification.

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

109 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference 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] I RCP water level core cooling or RCS heat

[BWR]) or RCS heat removal, removal MODE: Power Operation MODE: 1 - Power Operation NEI EA Ex.

E HNP NEI Example EAL Wording EAL HNP EAL Wording Difference 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 Ž5% power level)." Reactor power < 5% is the site-specific indication of a AND successful reactor trip.

b. All manual actions to shutdown the reactor have been All actions to shut down the Indication that core cooling is extremely challenged is manifested unsuccessful. reactor are not successful as by CSFST Core Cooling RED Path entry conditions met.

AND indicated by reactor power Indication that heat removal is extremely challenged is manifested

> 5% by CSFST Heat Sink RED Path entry conditions met.

c. EITHER of the following AND EITHER:

conditions exist:

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

• Heat Sink RED Path core) entry conditions met (Site-specific indication of an inability to adequately remove heat from the RCS) 110 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification 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 EALEx.

E HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification 1 Indicated voltage is less than SS2.1 Loss of all 125 VDC power 105 VDC is the site-specific minimum vital DC bus voltage.

(site-specific bus voltage value) based on battery bus voltage DC buses DP-1A-SA and DP-1 B-SB are the site-specific vital DC on ALL (site-specific Vital DC indications < 105 VDC on both buses.

busses) for 15 minutes or longer, emergency DC buses (DP-1A-SA, DP-1 B-SB) for > 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 Site Area Emergency Coordinator should declare the HNP EAL scheme by referencing the "time limit" specified within the promptly upon determining that event promptly upon EAL wording and deleting the specific classification.

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

111 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification SG1 Prolonged loss of all offsite and SG1a Prolonged loss of all offsite and NEI ICs SG1 and SG8 are grouped under the same HNP IC for all onsite AC power to all onsite AC power to simplification.

emergency buses. emergency buses The HNP emergency buses are the site-specific emergency buses.

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

Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI EALEx. HNP

1. NEI Example EAL Wording EAL # HNP EAL Wording Difference Justification

a. Loss of ALL offsite and ALL SG1.1 Loss of all offsite and all onsite 6.9 KV buses 1A-SA and 1B-SB are the site-specific emergency onsite AC power to (site-specific AC power capability to 6.9 KV buses.

emergency buses). emergency buses lA-SA and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the site-specific SBO coping analysis time.

CSFST Core Cooling RED Path entry conditions met indicates

b. EITHER of the following: AND EITHER: significant core exit superheating and core uncovery.

• Restoration of at least one R ofn at lemergency one Cemergestoi bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> one AC emergency bus in i o iey(oe1 less than (site-specific is not likely (Note 1) hours) is not likely.

• Core Cooling RED Path

• (Site-specific indication of entry conditions met an inability to adequately 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 HNP EAL scheme by referencing the "time limit" specified within the promptly upon determining that declare the event EAL wording and deleting the specific classification.

(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.

112 of 113

EAL Comparison Matrix HNP NEI IC# NEI IC Wording IC#(s) HNP IC Wording Difference Justification SG8 Loss of all AC and Vital DC SG1b Loss of all AC and vital DC NEI ICs SG1 and SG8 are grouped under the same HNP IC for power sources for 15 minutes or power sources for 15 minutes or simplification.

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 HNP NEI Example EAL Wording EAL HNP EAL Wording Difference Justification EAL # EAL #

1 a. Loss of ALL offsite and ALL SG1.2 Loss of all offsite and all onsite 6.9 KV buses 1A-SA and 1B-SB are the site-specific emergency onsite AC power to (site-specific AC power capability to 6.9 KV buses.

emergency buses) for 15 minutes emergency buses 1A-SA and 105 VDC is the site-specific minimum vital DC bus voltage.

or AND longer. 1B-SB for > 15min.

AND.

1DP-1A-SA and DP-1 B-SB are the site-specific vital DC buses.

AND AND

b. Indicated voltage is less than Loss of all 125 VDC power (site-specific bus voltage value) based on battery bus voltage on ALL (site-specific Vital DC indications < 105 VDC on both busses) for 15 minutes or longer, emergency DC buses (DP-1A-SA, DP-1 B-SB) for > 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 General Emergency Coordinator should declare the HNP EAL scheme by referencing the "time limit" specified within the promptly upon determining that 15 event promptly upon EAL wording and deleting the specific classification.

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

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U.S. Nuclear Regulatory Commission Serial HNP-15-025, Enclosure 3 SERIAL HNP-15-025 ENCLOSURE 3 HARRIS NUCLEAR PLANT EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT, EP-EAL, "EMERGENCY ACTION LEVEL TECHNICAL BASES" (CLEAN VERSION)

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 RENEWED LICENSE NUMBER NPF-63

Harris Nuclear Plant

~ENE RGY9 EMERGENCY ACTION LEVEL TECHNICAL BASES (Clean Version)

Revision 0 4/29/15 I EP-EAL Rev. 0 1 Page 1 of 259

TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE ................................................................................................................................... 3 2.0 DISCUSSION ............................................................................................................................... 3 2.1 Background ............................................................................................................................... 3 2.2 Fission Product Barriers ....................................................................................................... 4 2.3 Fission Product Barrier Classification Criteria ...................................................................... 4 2.4 EAL Organization ...................................................................................................................... 5 2.5 Technical Bases Inform ation ................................................................................................ 7 2.6 Operating Mode Applicability ............................................................................................... 8 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ................................................ 9 3.1 General Considerations ...................................................................................................... 9 3.2 Classification Methodology ............................................................................................... 10

4.0 REFERENCES

.......................................................................................................................... 14 4.1 Developm ental ........................................................................................................................ 14 4.2 Im plem enting .......................................................................................................................... 14 5.0 DEINITIONS, ACRONYM S & ABBREVIATIONS ................................................................. 15 6.0 HNP TO NEI 99-01 Rev. 6 EAL CROSS-REFERENCE ...................................................... 22 7.0 ATTACHM ENTS ........................................................................................................................ 26 1 Em ergency Action Level Technical Bases ............................................................... 27 Category R Abnorm al Rad Release / Rad Effluent .......................................... 27 Category C Cold Shutdown / Refueling System Malfunction ........................... 71 Category H Hazards ........................................................................................... 114 Category S System Malfunction ......................................................................... 154 Category F Fission Product Barrier Degradation ............................................... 200 2 Fission Product Barrier Loss / Potential Loss Matrix and Bases ......................................................................................................... 206 3 Safe Operation & Shutdown Areas Tables R-3/H-2 Bases ......................................... 257 I EP-EAL Rev. 0 1 Page 2 of259

1.0 PURPOSE This document provides an explanation and rationale for each Emergency Action Level (EAL) included in the EAL Upgrade Project for Harris Nuclear Station (HNP). It should be used to facilitate review of the HNP EALs and provide historical documentation for future reference.

Decision-makers responsible for implementation of PEP-1 10, Emergency Classification and Protective Action Recommendations, may use this document as a technical reference in support of EAL interpretation. This information may assist the Emergency Coordinator in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training and for explaining event classifications to off-site officials.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification.

Because the information in a basis document can affect emergency classification decision-making (e.g., the Emergency Coordinator refers to it during an event), the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10 CFR 50.54(q).

2.0 DISCUSSION 2.1 Background EALs are the plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions defined in the HNP Emergency Plan.

In 1992, the NRC endorsed NUMARC/NESP-007 "Methodology for Development of Emergency Action Levels" as an alternative to NUREG-0654 EAL guidance.

NEI 99-01 (NUMARC/NESP-007) Revisions 4 and 5 were subsequently issued for industry implementation. Enhancements over earlier revisions included:

• Consolidating the system malfunction initiating conditions and example emergency action levels which address conditions that may be postulated to occur during plant shutdown conditions.

" Initiating conditions and example emergency action levels that fully address conditions that may be postulated to occur at permanently Defueled Stations and Independent Spent Fuel Storage Installations (ISFSIs).

• Simplifying the fission product barrier EAL threshold for a Site Area Emergency.

Subsequently, Revision 6 of NEI 99-01 has been issued which incorporates resolutions to numerous implementation issues including the NRC EAL Frequently Asked Questions (FAQs).

Using NEI 99-01 Revision 6, "Methodology for the Development of Emergency Action Levels for Non-Passive Reactors," November 2012 (ADAMS Accession Number ML12326A805) (ref.

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4.1.1), HNP conducted an EAL implementation upgrade project that produced the EALs discussed herein.

2.2 Fission Product Barriers Fission product barrier thresholds represent threats to the defense in depth design concept that precludes the release of radioactive fission products to the environment. This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment.

Many of the EALs derived from the NEI methodology are fission product barrier threshold based. That is, the conditions that define the EALs are based upon thresholds that represent the loss or potential loss of one or more of the three fission product barriers. "Loss" and "Potential Loss" signify the relative damage and threat of damage to the barrier. A "Loss" threshold means the barrier no longer assures containment of radioactive materials. A "Potential Loss" threshold implies an increased probability of barrier loss and decreased certainty of maintaining the barrier.

The primary fission product barriers are:

A. Fuel Clad (FC): The Fuel Clad Barrier is the zircalloy tubes that contain the fuel pellets.

B. Reactor Coolant System (RCS): The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

C. Containment (CNMT): The Containment Barrier includes the containment building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve.

Containment Barrier thresholds are used as criteria for escalation of the ECL from Alert to a Site Area Emergency or a General Emergency 2.3 Fission Product Barrier Classification Criteria The following criteria are the bases for event classification related to fission product barrier loss or potential loss:

Alert:

Any loss or any potential loss of either Fuel Clad or RCS barrier Site Area Emergqency:

Loss or potential loss of any two barriers General Emergency:

Loss of any two barriersand loss orpotential loss of the third barrier EP-EAL I Rev. 0 I Page 4 of 259

2.4 EAL Organization The HNP EAL scheme includes the following features:

• Division of the EAL set into three broad groups:

o EALs applicable under all plant operating modes - This group would be reviewed by the EAL-user any time emergency classification is considered.

o EALs applicable only under hot operating modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup, or Power Operation mode.

o EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling or Defueled mode.

The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.

• Within each group, assignment of EALs to categories and subcategories:

Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. The HNP EAL categories are aligned to and represent the NEI 99-01 "Recognition Categories." Subcategories are used in the HNP scheme as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The HNP EAL categories and subcategories are listed below.

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EAL Groups, Categories and Subcategories EAL Group/Category EAL Subcategory Any Operatinaq Mode:

R - Abnormal Rad Levels / Rad Effluent 1 - Radiological Effluent 2 - Irradiated Fuel Event 3 - Area Radiation Levels H - Hazards and Other Conditions 1- Security Affecting Plant Safety 2- Seismic Event 3- Natural or Technological Hazard 4- Fire 5- Hazardous Gas 6- Control Room Evacuation 7- Emergency Coordinator Judgment Hot Conditions:

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

C - Cold Shutdown / Refueling System 1- RCS Level Malfunction 2- Loss of Emergency AC Power 3- RCS Temperature 4- Loss of Vital DC Power 5- Loss of Communications 6- Hazardous Event Affecting Safety Systems The primary tool for determining the emergency classification level is the EAL Classification Matrix. The user of the EAL Classification Matrix may (but is not required to) consult the EAL Technical Bases Document in order to obtain additional information concerning the EALs under classification consideration. The user should consult Section 3.0 and Attachments I & 2 of this document for such information.

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2.5 Technical Bases Information EAL technical bases are provided in Attachment 1 for each EAL according to EAL group (Any, Hot, Cold), EAL category (R, C, H, S, F and E) and EAL subcategory. A summary explanation of each category and subcategory is given at the beginning of the technical bases discussions of the EALs included in the category. For each EAL, the following information is provided:

Category Letter & Title Subcategory Number & Title Initiating Condition (IC)

Site-specific description of the generic IC given in NEI 99-01 Rev. 6.

EAL Identifier (enclosed in rectangle)

Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel. Four characters define each EAL identifier:

1. First character (letter): Corresponds to the EAL category as described above (R, C, H, S, F or E)

2. Second character (letter): The emergency classification (G, S, A or U)

G = General Emergency S = Site Area Emergency A = Alert U = Unusual Event

3. Third character (number): Subcategory number within the given category.

Subcategories are sequentially numbered beginning with the number one (1). If a category does not have a subcategory, this character is assigned the number one (1).

4. Fourth character (number): The numerical sequence of the EAL within the EAL subcategory. If the subcategory has only one EAL, it is given the number one (1).

Classification (enclosed in rectangle):

Unusual Event (U), Alert (A), Site Area Emergency (S) or General Emergency (G)

EAL (enclosed in rectangle)

Exact wording of the EAL as it appears in the EAL Classification Matrix Mode Applicability EP-EAL Rev. 0 Page 7of 259

One or more of the following plant operating conditions comprise the mode to which each EAL is applicable: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5

- Cold Shutdown, 6 - Refueling, D - Defueled, or All. (See Section 2.6 for operating mode definitions)

Definitions:

If the EAL wording contains a defined term, the definition of the term is included in this section. These definitions can also be found in Section 5.1.

Basis:

A Plant-Specific basis section that provides HNP-relevant information concerning the EAL.

This is followed by a Generic basis section that provides a description of the rationale for the EAL as provided in NEI 99-01 Rev. 6.

HNP Basis Reference(s):

Site-specific source documentation from which the EAL is derived 2.6 Operating Mode Applicability (ref. 4.1.7) 1 Power Operations Keff > 0.99 and reactor thermal power > 5% and average coolant temperature > 350OF 2 Startun Keff > 0.99 and reactor thermal power < 5% average coolant temperature > 350OF 3 Hot Standby Keff < 0.99 and average coolant temperature > 350OF 3 Hot Shutdown Keff < 0.99 and average coolant temperature 350OF > Tavg > 200 OF (excluding decay heat) 4 Cold Shutdown Keff < 0.99 and average coolant temperature Tavg < 200OF 5 Refueling Keff < 0.95 and average coolant temperature Tavg - 140'F; fuel in the reactor vessel with the vessel head closure bolts less than fully tensioned or with the head removed D Defueled All reactor fuel removed from reactor pressure vessel (full core off load during refueling or extended outage)

The plant operating mode that exists at the time that the event occurs (prior to any protective system or operator action being initiated in response to the condition) should be compared to the mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the mode that existed at the time the event occurred.

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3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 3.1 General Considerations When making an emergency classification, the Emergency Coordinator must consider all information having a bearing on the proper assessment of an Initiating Condition (IC). This includes the Emergency Action Level (EAL) plus the associated Operating Mode Applicability, Notes, and the informing basis information. In the Recognition Category F matrices, EALs are based on loss or potential loss of Fission Product Barrier Thresholds.

3.1.1 Classification Timeliness NRC regulations require the licensee to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. The NRC staff has provided guidance on implementing this requirement in NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" (ref. 4.1.10).

3.1.2 Valid Indications All emergency classification assessments shall be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicator's operability, the condition's existence, or the report's accuracy. For example, verification could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by plant personnel.

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

3.1.3 Imminent Conditions For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.

3.1.4 Planned vs. Unplanned Events A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that: 1) the activity proceeds as planned, and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or EP-EAL I Rev. 0 Page 9 of 259

component. In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 § CFR 50.72 (ref.

4.1.4).

3.1.5 Classification Based on Analysis The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments, chemistry sampling, RCS leak rate calculation, etc.). For these EALs, the EAL wording or the associated basis discussion will identify the necessary analysis. In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available). The NRC expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift).

3.1.6 Emergency Coordinator Judgment While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 EAL scheme provides the Emergency Coordinator with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The Emergency Coordinator will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition. A similar provision is incorporated in the Fission Product Barrier Tables; judgment may be used to determine the status of a fission product barrier.

3.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL must be consistent with the related Operating Mode Applicability and Notes. If an EAL has been met or exceeded, the associated IC is likewise met, the emergency classification process "clock" starts, and the ECL must be declared in accordance with plant procedures no later than fifteen minutes after the process "clock" started.

When assessing an EAL that specifies a time duration for the off-normal condition, the "clock" for the EAL time duration runs concurrently with the emergency classification process "clock."

For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref. 4.1.10).

3.2.1 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared. For example:

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• If an Alert EAL and a Site Area Emergency EAL are met, whether at one unit or at two different units, a Site Area Emergency should be declared.

There is no "additive" effect from multiple EALs meeting the same ECL. For example:

• If two Alert EALs are met, whether at one unit or at two different units, an Alert should be declared.

Related guidance concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, Clarificationof NRC Guidance for Emergency Notifications During Quickly Changing Events (ref. 4.1.2).

3.2.2 Consideration of Mode Changes During Classification The mode in effect at the time that an event or condition occurred, and prior to any plant or operator response, is the mode that determines whether or not an IC is applicable. If an event or condition occurs, and results in a mode change before the emergency is declared, the emergency classification level is still based on the mode that existed at the time that the event or condition was initiated (and not when it was declared). Once a different mode is reached, any new event or condition, not related to the original event or condition, requiring emergency classification should be evaluated against the ICs and EALs applicable to the operating mode at the time of the new event or condition.

For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicable in the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is entered during the subsequent plant response. In particular, the fission product barrier EALs are applicable only to events that initiate in the Hot Shutdown mode or higher.

3.2.3 Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Coordinator must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Coordinator, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all emergency classification levels, this approach is particularly important at the higher emergency classification levels since it provides additional time for implementation of protective measures.

3.2.4 Emergency Classification Level Upgrading and Downgrading An ECL may be downgraded when the event or condition that meets the highest IC and EAL no longer exists, and other site-specific downgrading requirements are met. If downgrading the ECL is deemed appropriate, the new ECL would then be based on a lower applicable IC(s) and EAL(s). The ECL may also simply be terminated.

As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02 (ref. 4.1.2).

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Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events include an earthquake or a failure of the reactor protection system to automatically trip the reactor followed by a successful manual trip.

3.2.6 Classification of Transient Conditions Many of the ICs and/or EALs employ time-based criteria. These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to the classification of these conditions.

EAL momentarily met during expected plant response - In instances where an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operator actions are performed in accordance with procedures.

EAL momentarily met but the condition is corrected prior to an emergency declaration - If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required. For illustrative purposes, consider the following example:

An ATWS occurs and the high pressure ECCS systems fail to automatically start. RPV level rapidly decreases and the plant enters an inadequate core cooling condition (a potential loss of both the fuel clad and RCS barriers). If an operator manually starts a high pressure ECCS system in accordance with an EOP step and clears the inadequate core cooling condition prior to an emergency declaration, then the classification should be based on the ATWS only.

It is important to stress that the 15-minute emergency classification assessment period (process clock) is not a "grace period" during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event.

Emergency classification assessments must be deliberate and timely, with no undue delays.

The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the Emergency Coordinator completing the review and steps necessary to make the emergency declaration. This provision is included to ensure that any public protective actions resulting from the emergency classification are truly warranted by the plant conditions.

3.2.7 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or EP-EAL Rev. 0 1 Page 12 of 259

condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.

In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022 (ref. 4.1.3) is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR § 50.72 (ref. 4.1.4) within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

3.2.8 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (ref. 4.1.3).

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4.0 REFERENCES

4.1 Developmental 4.1.1 NEI 99-01 Revision 6, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession Number ML12326A805 4.1.2 RIS 2007-02 Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2, 2007.

4.1.3 NUREG-1022 Event Reporting Guidelines: 10CFR50.72 and 50.73 4.1.4 10 § CFR 50.72 Immediate Notification Requirements for Operating Nuclear Power Reactors 4.1.5 10 § CFR 50.73 License Event Report System 4.1.6 FSAR Figure 1.2.2-1, Site Plan 4.1.7 Technical Specifications Table 1.2 Operational Modes 4.1.8 Technical Specifications Section 3/4.9.4 4.1.9 PRO-NGGC-0201 NGG Procedure Writers Guide 4.1.10 NSIR/DPR-ISG-01 Interim Staff Guidance, Emergency Planning for Nuclear Power Plants 4.1.11 PLP-201 Emergency Plan 4.1.12 GP-008 Draining the Reactor Coolant System 4.1.13 NCR 573223 4.2 Implementing 4.2.1 PEP-1 10, Emergency Classification and Protective Action Recommendations 4.2.2 NEI 99-01 Rev. 6 to HNP EAL Comparison Matrix 4.2.3 HNP EAL Matrix IEP-EAL I Rev. 0 1 Page 14 of 259

5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS 5.1 Definitions (ref. 4.1.1 except as noted)

Selected terms used in Initiating Condition and Emergency Action Level statements are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

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

Containment Closure The procedurally defined actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

As applied to HNP, Containment Closure is established when containment penetration closure is established in accordance with Technical Specifications 3/4.9.4 (ref. 4.1.8).

EPA PAGs Environment Protection Agency Protective Action Guidelines. The EPA PAGs are expressed in terms of dose commitment: 1 Rem TEDE or 5 Rem CDE Thyroid. Actual or projected offsite exposures in excess of the EPA PAGs requires HNP to recommend protective actions for the general public to offsite planning agencies.

Explosion A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events require a post-event inspection to determine if the attributes of an explosion are present.

Faulted The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

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

Flooding A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

General Emergency Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or hostile actions that result in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Hostage A person(s) held as leverage against the station to ensure that demands will be met by the station.

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

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

Imminent The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Impede(d)

Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

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Take appropriate action to hold the value of an identified parameter within specified limits.

Normal Levels As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.

Owner Controlled Area That area surrounding the Protected Area beyond which HNP exercises access control.

Projectile An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

Protected Area An area which normally encompasses all controlled areas within the security protected area fence as depicted in FSAR Figure 1.2.2-1, Site Plan (ref. 4.1.6).

RCS Intact The RCS should be considered intact when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams).

Refueling Pathway The reactor refueling cavity, spent fuel pool and fuel transfer canal comprise the refueling pathway.

Reduced Inventory RCS water level greater than 36 inches below the Reactor Vessel Flange (ref. 4.1.12).

Ruptured The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

Restore Take the appropriate action required to return the value of an identified parameter to the applicable limits Safety System A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

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Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Security Condition Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a hostile action.

Site Boundary A circle of approximately 2500 ft. radius from the center of the containment building (0.47 miles) (ref. 4.1.13).

Unisolable An open or breached system line that cannot be isolated, remotely or locally.

Unplanned A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Valid An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment.

Visible Damage Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

I EP-EAL Rev. 0 Page 18of 259

5.2 Abbreviations/Acronyms OF ....................................................................................................... Degrees Fahrenheit

° ........................................................................................................................... D e g ree s AC ....................................................................................................... Alternating Current AP .................................................................................... Abnorm al Operating Procedure ATW S ..................................................................... Anticipated Transient W ithout Scram CDE ...................................................................................... Com m itted Dose Equivalent CFR ..................................................................................... Code of Federal Regulations CSFST ...................................................................... Critical Safety Function Status Tree DBA ............................................................................................... Design Basis Accident DC ............................................................................................................... Direct Current EAL ............................................................................................. Em ergency Action Level EC ............................................................................................... Em ergency Coordinator ECCS ............................................................................ Em ergency Core Cooling System ECL ................................................................................. Em ergency Classification Level EO F .................................................................................. Em ergency O perations Facility EO P ............................................................................... Em ergency O perating Procedure EPA .............................................................................. Environm ental Protection Agency ERG ................................................................................ Em ergency Response G uideline EPIP ................................................................ Em ergency Plan Im plem enting Procedure ESF ........................................................................................ Engineered Safety Feature FAA ................................................................................. Federal Aviation Adm inistration FBI ................................................................................... Federal Bureau of Investigation FEM A ............................................................... Federal Em ergency Managem ent Agency FSAR .................................................................................... Final Safety Analysis Report G E ..................................................................................................... General Em ergency HNP ................................................................................................... Harris Nuclear Plant IC ......................................................................................................... Initiating Condition IPEEE ................. Individual Plant Examination of External Events (Generic Letter 88-20)

ISFSI ........................................................... Independent Spent Fuel Storage Installation Keff ......................................................................... Effective Neutron M ultiplication Factor LCO .................................................................................. Lim iting Condition of O peration LER ............................................................................................... Licensee Event Report LOCA ......................................................................................... Loss of Coolant Accident EP-EAL I Rev. 0 1 Page 19of 259

LW R ................................................................................................. Light W ater Reactor MPC ................................... Maxim um Perm issible Concentration/M ulti-Purpose Canister MSIV ...................................................................................... Main Steam Isolation Valve MSL ........................................................................................................ Main Steam Line m R, m Rem , m rem , m REM .............................................. m illi-Roentgen Equivalent Man MW .................................................................................................................... Megawatt RCS ............................................................................................ Reactor Coolant System NEI .............................................................................................. Nuclear Energy Institute NESP ................................................................... National Environm ental Studies Project NPP .................................................................................................. Nuclear Power Plant NRC ................................................................................ Nuclear Regulatory Com m ission NSSS ................................................................................ Nuclear Steam Supply System NO RAD .................................................. North Am erican Aerospace Defense Com m and (NO )UE ................................................................................ Notification of Unusual Event O BE ...................................................................................... O perating Basis Earthquake OCA .............................................................................................. Owner Controlled Area O DCM ........................................................................... Off-site Dose Calculation Manual O RO ................................................................................. Offsite Response O rganization PA ............................................................................................................. Protected Area PAG ........................................................................................ Protective Action G uideline PRA/PSA ..................... Probabilistic Risk Assessment / Probabilistic Safety Assessment PW R ....................................................................................... Pressurized W ater Reactor PSIG ............................................................................... Pounds per Square Inch Gauge R ........................................................................................................................ Roentgen RAB .......................................................................................... Reactor Auxiliary Building Rem , rem , REM ....................................................................... Roentgen Equivalent Man RETS ......................................................... Radiological Effluent Technical Specifications RPS ........................................................................................ Reactor Protection System RV ............................................................................................................. Reactor Vessel RVLIS ................................................................. Reactor Vessel Level Indicating System SAR ............................................................................................... Safety Analysis Report SBGTS .......................................................................... Stand-By Gas Treatm ent System SBO ......................................................................................................... Station Blackout SCBA ...................................................................... Self-Contained Breathing Apparatus EP-EAL I Rev. 0 1 Page 20 of 259

SG ......................................................................................................... Steam Generator SI .............................................................................................................. Safety Injection SLC ................................................................................ Selected Licensee Com m itm ent SPDS ........................................................................... Safety Param eter Display System SRO ............................................................................................ Senior Reactor Operator SSF .............................................................................................. Safe Shutdown Facility TEDE ............................................................................... Total Effective Dose Equivalent TOAF .................................................................................................... Top of Active Fuel TSC .......................................................................................... Technical Support Center W OG .................................................................................. W estinghouse Owners Group I EP-EAL Rev. 0 Page 21 of 259

ATTACHMENT 1 EAL Bases 6.0 HNP-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of a HNP EAL within the NEI 99-01 IC/EAL identification scheme. Further information regarding the development of the HNP EALs based on the NEI guidance can be found in the EAL Comparison Matrix.

HNP NEI 99-01 Rev. 6 EAL IC Example EAL RU1.1 AU1 1,2 RU1.2 AU1 3 RU2.1 AU2 1 RAI.1 AA1 1 RA1.2 AA1 2 RA1.3 AA1 3 RA1.4 AA1 4 RA2.1 AA2 1 RA2.2 AA2 2 RA2.3 AA2 3 RA3.1 AA3 1 RA3.2 AA3 2 RS1.1 AS1 1 RS1.2 AS1 2 RS1.3 AS1 3 RS2.1 AS2 1 RG1.1 AG1 1 RG1.2 AG1 2 RG1.3 AG1 3 EP-EAL Rev. 0 Page 22 of 259

ATTACHMENT 1 EAL Bases HNP NEI 99-01 Rev. 6 EAL IC Example EAL RG2.1 AG2 1 CU1.1 Cui 1 CU1.2 CUl 2 CU2.1 CU2 1 CU3.1 CU3 1 CU3.2 CU3 2 CU4.1 CU4 1 CU5.1 CU5 1,2,3 CA1.1 CA1 1 CA1.2 CA1 2 CA2.1 CA2' 1 CA3.1 CA3 1,2 CA6.1 CA6 1 CS1.1 CS1 1 CS1.2 CS1 2 CS1.3 CS1 3 CG1.1 CG1 1 CG1.2 CG1 2 FAI.1 FA1 1 FS1.1 FS1 1 FG1.1 FG1 1 HU1.1 HU1 1,23 HU2.1 HU2 1 HU3.1 HU3 1 I EP-EAL Rev. 0 1 Page 23 of 259

ATTACHMENT 1 EAL Bases HNP NEI 99-01 Rev. 6 EAL IC Example EAL HU3.2 HU3 2 HU3.3 HU3 3 HU3.4 HU3 4 HU4.1 HU4 1 HU4.2 HU4 2 HU4.3 HU4 3 HU4.4 HU4 4 HU7.1 HU7 1 HA1.1 HAl 1,2 HA5.1 HA5 1 HA6.1 HA6 1 HA7.1 HA7 1 HS1.1 HS1 1 HS6.1 HS6 1 HS7.1 HS7 1 HG1.1 HG1 1 HG7.1 HG7 1 SUI.1 SUl 1 SU3.1 SU2 1 SU4.1 SU3 2 SU4.2 SU3 1 SU5.1 SU4 1,2,3 SU6.1 SU5 1 SU6.2 SU5 2 I EP-EAL Rev. 0 1 Page 24 of 259

ATTACHMENT 1 EAL Bases HNP NEI 99-01 Rev. 6 EAL IC Example EAL SU7.1 SU6 1,2,3 SU8.1 SU7 1,2 SA1.1 SA1 1 SA3.1 SA2 1 SA6.1 SA5 1 SA9.1 SA9 1 SS1.1 SSI 1 SS2.1 SS8 1 SS6.1 SS5 1 SG1.1 SG1 1 SG1.2 SG8 1 I EP-EAL Rev. 0 Page 25 of 259

ATTACHMENT 1 EAL Bases 7.0 ATTACHMENTS 7.1 Attachment 1, Emergency Action Level Technical Bases 7.2 Attachment 2, Fission Product Barrier Matrix and Basis 7.3 Attachment 3, Safe Operation & Shutdown Areas Tables R-3/H-2 Bases I EP-EAL Rev. 0 1 Page 26 of 259

ATTACHMENT 1 EAL Bases Category R - Abnormal Rad Release / Rad Effluent EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

Many EALs are based on actual or potential degradation of fission product barriers because of the elevated potential for offsite radioactivity release. Degradation of fission product barriers though is not always apparent via non-radiological symptoms. Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification.

At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions may result which require offsite protective actions. Elevated area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.

Events of this category pertain to the following subcategories:

1. Radiological Effluent Direct indication of effluent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits. Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.

2. Irradiated Fuel Event Conditions indicative of a loss of adequate shielding or damage to irradiated fuel may preclude access to vital plant areas or result in radiological releases that warrant emergency classification.

3. Area Radiation Levels Sustained general area radiation levels which may preclude access to areas requiring continuous occupancy also warrant emergency classification.

I EP-EAL Rev. 0 Page 27 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:

RUI.1 Unusual Event Reading on any Table R-1 effluent radiation monitor > column "UE" for ->60 min.

(Notes 1,2, 3)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

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

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

Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent RM-21AV-3509-1SA 1.05E+8 pCi/sec 1.05E+7 liCi/sec 1.05E+6 pCi/sec 8.93E+3 pLCi/sec Turbine Building RM-1TV-3536-1 4.60E+8 pCi/sec 4.60E+7 pCi/sec 4.60E+6 pCi/sec 1.08E+4 pCi/sec Waste Process Building Vent 5 RM-IWV-3546-1 7.74E+9 pCi/sec 7.74E+8 pCi/sec 7.75E+7 pCi/sec 1.95E+5 pCi/sec Waste Process Building Vent RM-lWV-3547-1 7.76E+9 pCi/sec 7.76E+8 pCi/sec 7.76E+7 pCi/sec 1.14E+4 pCi/sec 5A Treated Laundry & Hot Shower REM-iWL-3540 -- 1.83E+5cpm Tank Discharge --

. Waste Monitor/Waste Evaporator Condensate Tank Discharge REM-21WL-3541 ----

_...._5.13E+5 cpm Secondary Waste Sample REM-21WS-3542 .... .... 1.83E+5 cpm Tank Discharge RI M-21WS-3542 I.83+5 I Im Mode Applicability:

All Definition(s):

None IEP-EAL I Rev. 0 Page 28 of 259

ATTACHMENT 1 EAL Bases HNP Basis:

The column "UE" gaseous and liquid release values in Table R-1 represent two times the appropriate ODCM release rate limits associated with the specified monitors (ref. 1, 2).

The column "UE" liquid release values in Table R-1 represent two times the alarm setpoint of the specified monitors. The setpoints are established to ensure the ODCM release limits are not exceeded (ref. 1).

NEI 99-01 Basis:

This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways.

Escalation of the emergency classification level would be via IC RAI.

HNP Basis Reference(s):

1. Shearon Harris Nuclear Power Plant Offsite Dose Calculation Manual (ODCM) Section 3.0, Gaseous Effluents

2. EP-EALCALC-HNP-1401, HNP Radiological Effluent EAL Values Rev. 0 EP-EAL IRev. 0 1Page 29 of 5

ATTACHMENT 1 EAL Bases

3. NEI 99-01 AU1 I EP-EAL Rev. 0 1 Page 30 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:

RU1.2 Unusual Event Sample analysis for a gaseous or liquid release indicates a concentration or release rate

> 2 x ODCM limits for ->60 min. (Notes 1, 2)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

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

Mode Applicability:

All Definition(s):

None HNP Basis:

Releases in excess of two times the site Offsite Dose Calculation Manual (ODCM) (ref. 1) instantaneous limits that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the Unusual Event emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes.

NEI 99-01 Basis:

This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

EP-EAL Rev. 0 Page 31 of 259

ATTACHMENT 1 EAL Bases Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

Escalation of the emergency classification level would be via IC RA1.

HNP Basis Reference(s):

1. Shearon Harris Nuclear Power Plant Offsite Dose Calculation Manual (ODCM)

2. NEI 99-01 AU1 IEP-EAL I Rev. 0 1 Page 32 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

RAI.1 Alert Reading on any Table R-1 effluent radiation monitor > column "ALERT" for > 15 min.

(Notes 1,2, 3, 4)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

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

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

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

Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent RM-21AV-3509-1SA 1.05E÷8 p*ci/sec 1.05E+7 pCi/sec 1.05E+6 pci/sec 8.93E+3 l.tCi/sec Turbine Building RM-1TV-3536-1 4.60E+8 pCi/sec 4.60E+7 pci/sec 4.60E+6 pci/sec 1.08E÷4 pci/se Process Building Vent5 RM-1WV-3546-1 7.74E+9 4WastepCi/sec 7.74E+8 pCi/sec 7.75E+7 p*Ci/sec 1.95E+5 pCi/sec 5A RM-1WV-3547-1 7.76E+9 pCi/sec 7.76E+8 pCi/sec 7.76E+7 pCi/sec 1.14E+4 pCi/sec Treated Laundry & Hot Shower Tan DichageREM-1WL-3540 ----..... 1.83E+5 cpm Tank Discharge -- ________ _________

. Waste Monitor/Waste Evaporator Condensate Tank Discharge REM-21WL-3541 .... 5.13E+5 cpm Secondary Waste Sample REM21WS3542 1.83E+5cpm Tank Discharge ---- ----

Mode Applicability:

All EP-EAL Rev. 0 Page 33 of 259

ATTACHMENT 1 EAL Bases Definition(s):

None HNP Basis:

This EAL address gaseous radioactivity releases, that for whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed either:

• 10 mRem TEDE

• 50 mRem CDE Thyroid The column "ALERT" gaseous effluent release values in Table R-1 correspond to calculated doses of 1% (10% of the calculated SAE thresholds) of the EPA Protective Action Guidelines (TEDE or CDE Thyroid) (ref. 1).

NEI 99-01 Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Escalation of the emergency classification level would be via IC RS1.

HNP Basis Reference(s):

1. EP-EALCALC-HNP-1401, HNP Radiological Effluent EAL Values Rev. 0

2. NEI 99-01 AA1 EP-EAL Rev. 0 Page 34 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

RA1.2 Alert Dose assessment using actual meteorology indicates doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY (Notes 3, 4)

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

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

Mode Applicability:

All Definition(s):

SITE BOUNDARY - A circle of approximately 2500 ft. radius from the center of the containment building (0.47 miles).

HNP Basis:

Dose assessments are performed by computer-based methods (ref. 1)

NEI 99-01 Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and IEP-EAL I Rev. 0 T Page 35 of 259

ATTACHMENT 1 EAL Bases conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Escalation of the emergency classification level would be via IC RSI.

HNP Basis Reference(s):

1. AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment

2. NEI 99-01 AA1 I EP-EAL Rev. 0 Page 36 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

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

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

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

Mode Applicability:

All Definition(s):

SITE BOUNDARY - A circle of approximately 2500 ft. radius from the center of the containment building (0.47 miles).

HNP Basis:

Dose assessments based on liquid releases are performed per Offsite Dose Calculation Manual (ref. 1).

NEI 99-01 Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions EP-EAL Rev. 0 Page 37 of 259

ATTACHMENT 1 EAL Bases alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Escalation of the emergency classification level would be via IC RS1.

HNP Basis Reference(s):

1. Shearon Harris Nuclear Power Plant Offsite Dose Calculation Manual (ODCM)

2. NEI 99-01 AA1 I EP-EAL Rev. 0 1 Page 38 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels I Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

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

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

" Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 min. of inhalation.

(Notes 1,2)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

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

Mode Applicability:

All Definition(s):

SITE BOUNDARY - A circle of approximately 2500 ft. radius from the center of the containment building (0.47 miles).

HNP Basis:

PEP-270, Activation and Operation of the Emergency Operations Facility and PEP-330, Radiological Consequences provide guidance for emergency or post-accident radiological environmental monitoring (ref. 1, 2).

NEI 99-01 Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a EP-EAL I Rev. 0 Page 39 of 259

ATTACHMENT 1 EAL Bases radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Escalation of the emergency classification level would be via IC RS1.

HNP Basis Reference(s):

1. PEP-270, Activation and Operation of the Emergency Operations Facility

2. PEP-330, Radiological Consequences

3. NEI 99-01 AA1 IEP-EAL I Rev. 0 Page 40 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

RSI.1 Site Area Emergency Reading on any Table R-1 effluent radiation monitor > column "SAE" for > 15 min.

(Notes 1,2, 3, 4)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

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

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

Note 4: The pre-calculated effluent monitor values presented in EALs RAI.1, RS1.1 and RGI.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. If dose assessment results are available, declaration should be based on dose assessment instead of radiation monitor values.

Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent RM-21AV-3509-ISA 1.05E+8 pCi/sec 1.05E+7 ciC/sec 1.05E+6 iACi/sec 8.93E+3 pCi/sec g Turbine Building RM-1TV-3536-1 4.60E+8 LCi/sec 4.60E+7 pCi/sec 4.60E+6 pCi/sec 1.08E+4 pCi/sec Waste Process Building Vent 5 RM-1WV-3546-1 7.74E+9 pCi/sec 7.74E+8 pCi/sec 7.75E+7 pCi/sec 1.95E+5 pCi/sec Waste Process Building Vent RM-1WV-3547-1 7.76E+9 pCi/sec 7.76E+8 pCi/sec 7.76E+7 pCi/sec 1.14E+4 pCi/sec 5A Treated Laundry & Hot Shower ----...- 1.83E+5 cpm Tank Discharge

-Tak ishageREM -1WL-3540 .... _______

. Waste Monitor/Waste Evaporator REM-21WL-3541 5.13E+5 Condensate Tank Discharge 5.13E-5 cpm Secondary Waste Sample REM21WS-3542 ....... 1.832+5 cpm Tank Discharge REM--1WS-3542 ---- .... 1.83E_5____

Mode Applicability:

All EP-EAL Rev. 0 Page 41 of 259

ATTACHMENT 1 EAL Bases Definition(s):

None HNP Basis:

This EAL address gaseous radioactivity releases, that for whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed either:

• 100 mRem TEDE

• 500 mRem CDE Thyroid The column "SAE" gaseous effluent release value in Table R-1 corresponds to calculated doses of 10% of the EPA Protective Action Guidelines (TEDE or CDE Thyroid) (ref. 1).

NEI 99-01 Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Escalation of the emergency classification level would be via IC RGI.

HNP Basis Reference(s):

1. EP-EALCALC-HNP-1401, HNP Radiological Effluent EAL Values Rev. 0

2. NEI 99-01 AS1 IEP-EAL I Rev. 0 Page 42 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

RS1.2 Site Area Emergency Dose assessment using actual meteorology indicates doses > 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the SITE BOUNDARY (Notes 3, 4)

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

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

Mode Applicability:

All Definition(s):

SITE BOUNDARY - A circle of approximately 2500 ft. radius from the center of the containment building (0.47 miles).

HNP Basis:

Dose assessments are performed by computer-based methods (ref. 1)

NEI 99-01 Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

EP-EAL Rev. 0 1 Page 43 of 259

ATTACHMENT 1 EAL Bases The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Escalation of the emergency classification level would be via IC RG1.

HNP Basis Reference(s):

1. AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment

2. NEI 99-01 AS1 I EP-EAL Rev. 0 1 Page 44 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

RS1.3 Site Area Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

• Closed window dose rates> 100 mR/hr expected to continue for 2-60 min.

" Analyses of field survey samples indicate thyroid CDE > 500 mrem for 60 min. of inhalation.

(Notes 1, 2)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

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

Mode Applicability:

All Definition(s):

SITE BOUNDARY - A circle of approximately 2500 ft. radius from the center of the containment building (0.47 miles).

HNP Basis:

PEP-270, Activation and Operation of the Emergency Operations Facility and PEP-330, Radiological Consequences provide guidance for emergency or post-accident radiological environmental monitoring (ref. 1, 2).

NEI 99-OlBasis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

EP-EAL I Rev. 0 Page 45 of 259

ATTACHMENT 1 EAL Bases Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC RG1.

HNP Basis Reference(s):

1. PEP-270, Activation and Operation of the Emergency Operations Facility

2. PEP-330, Radiological Consequences

3. NEI 99-01 AS1 I EP-EAL Rev. 0 Page 46 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

RGI.1 General Emergency Reading on any Table R-1 effluent radiation monitor > column "GE" for > 15 min.

(Notes 1,2, 3, 4)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

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

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

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

Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent RM-21AV-3509-1SA 1.05E+8 MCi/sec 1.05E+7 pCi/sec 1.05E+6 pCi/sec 8.93E+3 pCi/sec

1. A Turbine Building RM-1TV-3536-l 4.60E+8 IkCi/sec 4.60E+7 pCi/sec 4.60E+6 pCi/sec 1.08E+4 pCi/sec Waste Process Building Vent 5 RM-1WV-3546-1 7.74E+9 pCi/sec 7.74E+8 pCi/sec 7.75E+7 pCi/sec 1.95E+5 pCi/sec Waste Process Building Vent RM-1WV-3547-1 7.76E+9 pci/sec 7.76E+8 pCi/sec 7.76E+7 gCi/sec 1.14E+4 pCi/sec 5A Treated Laundry & Hot Shower ----..... _________ 1.83E+5 cpm Tan DichageREM-1WL-3540 Tank Discharge --

3 Waste Monitor/Waste Evaporator REM-21WL-3541 5.13E+5 c Condensate Tank Discharge 5.13E-5 cpm Secondary Waste Sample REM-21WS-3542 1.83E+cpm Tank Discharge .. _ 1.....5 Mode Applicability:

All EP-EAL Rev. 0 Page 47 of 259

ATTACHMENT 1 EAL Bases Definition(s):

None HNP Basis:

This EAL address gaseous radioactivity releases, that for whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed either:

• 1000 mRem TEDE

• 5000 mRem CDE Thyroid The column "GE" gaseous effluent release values in Table R-1 correspond to calculated doses of 100% of the EPA Protective Action Guidelines (TEDE or CDE Thyroid) (ref. 1).

NEI 99-01 Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

HNP Basis Reference(s):

1. EP-EALCALC-HNP-1 401, HNP Radiological Effluent EAL Values Rev. 0

2. NEI 99-01 AG1 IEP-EAL I Rev. 0 Page 48 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

RG1.2 General Emergency Dose assessment using actual meteorology indicates doses > 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond the SITE BOUNDARY (Notes 3, 4)

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

Note 4: The pre-calculated effluent monitor values presented in EALs RAI.1, RSI.1 and RGI.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. Ifdose assessment results are available, declaration should be based on dose assessment instead of radiation monitor values.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - A circle of approximately 2500 ft. radius from the center of the containment building (0.47 miles).

HNP Basis:

Dose assessments are performed by computer-based methods (ref. 1)

NEI 99-01 Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was EP-EAL Rev. 0 Page 49 of 259

ATTACHMENT 1 EAL Bases established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

HNP Basis Reference(s):

1. AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment

2. NEI 99-01 AG1 IEP-EAL I Rev. 0 1 Page 50 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

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

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

• Analyses of field survey samples indicate thyroid CDE > 5,000 mrem for 60 min. of inhalation.

(Notes 1, 2)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

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

Mode Applicability:

All Definition(s):

SITE BOUNDARY - A circle of approximately 2500 ft. radius from the center of the containment building (0.47 miles).

HNP Basis:

PEP-270, Activation and Operation of the Emergency Operations Facility and PEP-330, Radiological Consequences provide guidance for emergency or post-accident radiological environmental monitoring (ref. 1, 2).

NEI 99-01 Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

EP-EAL Rev. 0 Page 51 of 259

ATTACHMENT 1 EAL Bases Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

HNP Basis Reference(s):

1. PEP-270, Activation and Operation of the Emergency Operations Facility

2. PEP-330, Radiological Consequences

3. NEI 99-01 AG1 IEP-EAL I Rev. 0 Page 52 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Unplanned loss of water level above irradiated fuel EAL:

RU2.1 Unusual Event UNPLANNED water level drop in the REFUELING PATHWAY as indicated by low water level alarm or indication AND UNPLANNED rise in corresponding area radiation levels as indicated by any Table R-2 area radiation monitors Table R-2 Refueling Pathway Area Radiation Monitors Containment

" RM-1CR-3561A-SA Containment Ventilation Isolation

• RM-1CR-3561B-SB Containment Ventilation Isolation

" RM-1CR-3561C-SA Containment Ventilation Isolation

• RM-1CR-3561D-SB Containment Ventilation Isolation Fuel Handling Building

• RM-1 FR-3564A-SA Spent Fuel Pool SW, SE, SW

" RM-1FR-3564B-SB Spent Fuel Pool SW, SE, SE

• RM-1 FR-3565A-SA Spent Fuel Pool SW, SE, SW

• RM-1FR-3565B-SB Spent Fuel Pool SW, SE, SE

• RM-1 FR-3566A-SA Spent Fuel Pool NE, NW, NE

" RM-1FR-3566B-SB Spent Fuel Pool NW, NE, NW

• RM-1FR-3567A-SA Spent Fuel Pool NW, NE, NW

• RM-1FR-3567B-SB Spent Fuel Pool NE, NW, NE Mode Applicability:

All Definition(s):

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

EP-EAL Rev. 0 Page 53 of 259

ATTACHMENT 1 EAL Bases REFUELING PATHWAY- The reactor refueling cavity, spent fuel pool and fuel transfer canal comprise the refueling pathway.

HNP Basis:

The spent fuel pool low water level alarm setpoint is actuated at a setpoint of 284 ft. (ref. 1, 2, 3). Water level restoration instructions are performed in accordance with AOPs (ref. 4, 5).

The specified radiation monitors are those expected to see increase area radiation levels as a result of a loss of REFUELING PATHWAY inventory (ref. 4, 5, 6). Increasing radiation indications on these monitors in the absence of indications of decreasing REFUELING CAVITY level are not classifiable under this EAL.

When the spent fuel pool and reactor cavity are connected, there could exist the possibility of uncovering irradiated fuel. Therefore, this EAL is applicable for conditions in which irradiated fuel is being transferred to and from the reactor vessel and spent fuel pool.

NEI 99-01 Basis:

This IC addresses a decrease in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.

A water level decrease will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available). A significant drop in the water level may also cause an increase in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may increase due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an unplanned loss of water level.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC RA2.

HNP Basis Reference(s):

1. APP-ALB-023-4-17, SPENT FP HI/LO LEVEL

2. APP-ALB-023-4-18, SFP C HI/LO LEVEL

3. APP-ALB-023-5-18, SFP D HI/LO LEVEL

4. AOP-013, Fuel Handling Accident EP-EAL Rev. 0 Page 54 of 259

ATTACHMENT 1 EAL Bases

5. AOP-031, Loss of Refueling Cavity Integrity

6. AOP-005, Radiation Monitoring System

7. NEI 99-01 AU2 I EP-EAL Rev. 0 1 Page 55 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

RA2.1 Unusual Event Uncovery of irradiated fuel in the REFUELING PATHWAY Mode Applicability:

All Definition(s):

REFUELING PATHWAY- The reactor refueling cavity, spent fuel pool and fuel transfer canal comprise the refueling pathway.

HNP Basis:

None.

NEI 99-01 Basis:

This IC addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

This EAL escalates from RU2.1 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

While an area radiation monitor could detect an increase in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.

EP-EAL Rev. 0 1 Page 56 of259

ATTACHMENT 1 EAL Bases A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC RS1.

HNP Basis Reference(s):

1. AOP-013, Fuel Handling Accident

2. AOP-031, Loss of Refueling Cavity Integrity

3. NEI 99-01 AA2 IEP-EAL I Rev. 0 Page 57 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

RA2.2 Alert Damage to irradiated fuel resulting in a release of radioactivity AND A high alarm on any of the following:

• Table R-2 refueling pathway area radiation monitors

" REM-*1 FL-3508A-SA, FHB Emergency Exhaust

• REM-*1 FL-3508B-SB, FHB Emergency Exhaust Table R-2 Refueling Pathway Area Radiation Monitors Containment

• RM-1CR-3561A-SA Containment Ventilation Isolation

• RM-1CR-3561B-SB Containment Ventilation Isolation

• RM-1CR-3561C-SA Containment Ventilation Isolation

• RM-1CR-3561D-SB Containment Ventilation Isolation Fuel Handling Building

• RM-1 FR-3564A-SA Spent Fuel Pool SW, SE, SW

• RM-1 FR-3564B-SB Spent Fuel Pool SW, SE, SE

• RM-1 FR-3565A-SA Spent Fuel Pool SW, SE, SW

• RM-1 FR-3565B-SB Spent Fuel Pool SW, SE, SE

• RM-1 FR-3566A-SA Spent Fuel Pool NE, NW, NE

• RM-1FR-3566B-SB Spent Fuel Pool NW, NE, NW

" RM-1FR-3567A-SA Spent Fuel Pool NW, NE, NW

• RM-1FR-3567B-SB Spent Fuel Pool NE, NW, NE Mode Applicability:

All I EP-EAL Rev. 0 Page 58 of 259

ATTACHMENT 1 EAL Bases Definition(s):

None HNP Basis:

The specified radiation monitors are those expected to see increase area radiation levels as a result of damage to irradiated fuel (ref. 1, 2, 3).

The high alarm setpoints for the radiation monitors are set to be indicative of significant increases in area and/or airborne radiation (ref. 4, 5).

NEI 99-01 Basis:

This IC addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

Escalation of the emergency would be based on either Recognition Category R or C ICs.

This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).

Escalation of the emergency classification level would be via IC RS1.

HNP Basis Reference(s):

1. AOP-013, Fuel Handling Accident

2. AOP-031, Loss of Refueling Cavity Integrity

3. AOP-005, Radiation Monitoring System

4. DBD-304, Radiation Monitoring System & Gross Failed Fuel Detector

5. HPP-500, Radiation Monitoring System Data Base Manual

6. NEI 99-01 AA2 I EP-EAL Rev. 0 Page 59 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

RA2.3 Alert Lowering of spent fuel pool level < 270.7 ft. (Level 2)

Mode Applicability:

All Definition(s):

None HNP Basis:

Post-Fukushima order EA-12-051 (ref.1) required the installation of 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).

The SFP level instruments consist of a three independent remote indicating channels (LI-5101A, LI-5102A and LI-5103A) each spanning approximately 25 ft. (260 ft. - 285 ft.

indicated). Level 2 corresponds to an indicated SFP level of 270.7 ft. or approximately 10 ft.

above the top of the SFP racks (ref. 2).

NEI 99-01 Basis:

This IC addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

Escalation of the emergency would be based on either Recognition Category R or C ICs.

Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

EP-EAL Rev. 0 Page 60 of 259

ATTACHMENT 1 EAL Bases Escalation of the emergency classification level would be via IC RS1.

HNP Basis Reference(s):

1. NRC EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

2. EC 89579

3. NEI 99-01 AA2 IEP-EAL I Rev. 0 1 Page 61 of 259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Spent fuel pool level at the top of the fuel racks EAL:

RS2.1 Site Area Emergency Lowering of spent fuel pool level --260.7 ft. (Level 3)

Mode Applicability:

All Definition(s):

None HNP Basis:

Post-Fukushima order EA-12-051 (ref.1) required the installation of 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).

The SFP level instruments consist of a three independent remote indicating channels (LI-5101A, LI-5102A and LI-5103A) each spanning approximately 25 ft. (260 ft. - 285 ft.

indicated). Level 3 corresponds to an indicated SFP level of 260.7 ft. which is the top of the SFP racks (ref. 2).

NEI 99-01 Basis:

This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity.

Escalation of the emergency classification level would be via IC RG1 or RG2.

IEP-EAL I Rev. 0 Page 62 of 259

ATTACHMENT 1 EAL Bases HNP Basis Reference(s):

1. NRC EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

2. EC 89579

3. NEI 99-01 AS2 IEP-EAL I Rev. 0 1 Page 63 of259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer EAL:

RG2.1 General Emergency Spent fuel pool level cannot be restored to at least 260.7 ft. (Level 3) for > 60 min.

(Note 1)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

All Definition(s):

None HNP Basis:

Post-Fukushima order EA-1 2-051 (ref. 1) required the installation of 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).

The SFP level instruments consist of a three independent remote indicating channels (LI-5101A, LI-5102A and LI-5103A) each spanning approximately 25 ft. (260 ft. - 285 ft.

indicated). Level 3 corresponds to an indicated SFP level of 260.7 ft. which is the top of the SFP racks (ref. 2).

NEI 99-01 Basis:

This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment.

It is recognized that this IC would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity.

I EP-EAL Rev. 0 1 Page 64 of 259

ATTACHMENT 1 EAL Bases HNP Basis Reference(s):

1. NRC EA-1 2-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

2. EC 89579

3. NEI 99-01 AG2 I EP-EAL Rev. 0 1 Page 65 of259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

RA3.1 Alert Dose rates > 15 mR/hr in EITHER of the following areas:

Control Room (RM-21RR-3560-SA)

OR Central Alarm Station (by survey)

Mode Applicability:

All Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

HNP Basis:

Areas that meet this threshold include the Control Room and the Central Alarm Station (CAS).

RM-21 RR-3560-SA monitors the Control room for area radiation (ref. 1, 2). The CAS is included in this EAL because of its' importance to permitting access to areas required to assure safe plant operations.

There is no permanently installed CAS area radiation monitors that may be used to assess this EAL threshold. Therefore this threshold must be assessed via local radiation survey for the CAS.

NEI 99-01 Basis:

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency EP-EAL Rev. 0 Page 66 of 259

ATTACHMENT 1 EAL Bases Coordinator should consider the cause of the increased radiation levels and determine if another IC may be applicable.

Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.

HNP Basis Reference(s):

1. HPP-500, Radiation Monitoring System Data Base Manual

2. DBD-304, Radiation Monitoring System & Gross Failed Fuel Detector

3. NEI 99-01 AA3 IEP-EAL I Rev. 0 1 Page 67 of259

ATTACHMENT 1 EAL Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

RA3.2 Alert An UNPLANNED event results in radiation levels that prohibit or impede access to any Table R-3/H-2 rooms or areas (Note 5)

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

Table R-31H-2 Safe Operation & Shutdown RoomslAreas RoomlArea Mode(s)

RAB 190 (RHR pumps) 4 RAB 216 (BIT) 1,2,3,4,5 RAB 236 (CSIP, Primary Sample Sink, AFW pumps, CCW pumps and HX, Boric Acid Transfer 1, 2, 3, 4, 5 Pumps, Mezzanine Area)

RAB 261 (RHR Heat Exchangers, Demin. Valve Gallery, VCT Valve Gallery) 1, 2, 3, 4, 5 RAB 286 (Switchgear) 3,4,5 Containment Building 3 Steam Tunnel 1, 2, 3, 4 ESW intakes 1,2,3,4,5 Mode Applicability:

All Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

IEP-EAL I Rev. 0 Page 68 of 259

ATTACHMENT 1 EAL Bases HNP Basis:

If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.

The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1).

NEI 99-01 Basis:

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Coordinator should consider the cause of the increased radiation levels and determine if another IC may be applicable.

For RA3.2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is not warranted if any of the following conditions apply:

" The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation increase occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

" The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.).

" The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

EP-EAL Rev. 0 Page 69 of 259

ATTACHMENT 1 EAL Bases o The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.

Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.

HNP Basis Reference(s):

1. Attachment 3, Safe Operation & Shutdown Rooms/Areas Tables R-3/H-2 Bases

2. NEI 99-01 AA3 I EP-EAL Rev. 0 Page 70 of 259

ATTACHMENT 1 EAL Bases Category C - Cold Shutdown I Refueling System Malfunction EAL Group: Cold Conditions (RCS temperature - 2001F); EALs in this category are applicable only in one or more cold operating modes.

Category C EALs are directly associated with cold shutdown or refueling system safety functions. Given the variability of plant configurations (e.g., systems out-of-service for maintenance, containment open, reduced AC power redundancy, time since shutdown) during these periods, the consequences of any given initiating event can vary greatly. For example, a loss of decay heat removal capability that occurs at the end of an extended outage has less significance than a similar loss occurring during the first week after shutdown. Compounding these events is the likelihood that instrumentation necessary for assessment may also be inoperable. The cold shutdown and refueling system malfunction EALs are based on performance capability to the extent possible with consideration given to RCS integrity, containment closure, and fuel clad integrity for the applicable operating modes (5 - Cold Shutdown, 6 - Refueling, D - Defueled).

The events of this category pertain to the following subcategories:

1. RCS Level Reactor Vessel or RCS water level is directly related to the status of adequate core cooling and, therefore, fuel clad integrity.

2. Loss of Emergency AC Power Loss of emergency plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite power sources for 6.9 KV safeguard buses.

3. RCS Temperature Uncontrolled or inadvertent temperature or pressure increases are indicative of a potential loss of safety functions.

4. Loss of Vital DC Power Loss of emergency plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125 VDC safeguard buses.

IEP-EAL I Rev. 0 Page 71 of 259

ATTACHMENT 1 EAL Bases

5. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.

6. Hazardous Event Affectinq Safety Systems Certain hazardous natural and technological events may result in visible damage to or degraded performance of safety systems warranting classification.

I EP-EAL Rev. 0 Page 72 of 259

ATTACHMENT 1 EAL Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory for 15 minutes or longer EAL:

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

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

HNP Basis:

RCS water level less than a required lower limit is meant to be less than the lower end of the level control band being procedurally maintained for the current condition or evolution.

With the plant in Cold Shutdown, RCS water level is normally maintained above the pressurizer low level setpoint of 17% (ref. 1, 2). However, if RCS level is being controlled below the pressurizer low level setpoint, or if level is being maintained in a designated band in the reactor vessel it is the inability to maintain level above the low end of the designated control band due to a loss of inventory resulting from a leak in the RCS that is the concern.

With the plant in Refueling mode, RCS water level is normally maintained at or above the reactor vessel flange (ref. 2, 3, 4).

NEI 99-01 Basis:

This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Refueling evolutions that decrease RCS water inventory are carefully planned and controlled.

An UNPLANNED event that results in water level decreasing below a procedurally required I EP-EAL I Rev. 0 Page 73 of 259

ATTACHMENT 1 EAL Bases limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

This EAL recognizes that the minimum required RCS level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.

The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.

HNP Basis Reference(s):

1. APP-ALB-009, Main Control Board

2. GP-001, Reactor Coolant System Fill and Vent Mode 5

3. GP-008, Draining the Reactor Coolant System

4. GP-009, Refueling Cavity Fill, Refueling and Drain of the Refueling Cavity Modes 5-6-5

5. NEI 99-01 CU1 I EP-EAL Rev. 0 1 Page 74 of 259

ATTACHMENT 1 EAL Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory for 15 minutes or longer EAL:

CU1.2 Unusual Event RCS water level cannot be monitored AND EITHER

" UNPLANNED increase in any Table C-1 sump or tank due to a loss of RCS inventory

" Visual observation of UNISOLABLE RCS leakage Table C-1 Sumps / Tanks

• Containment sumps

• PRT

• RCDT

" CCW surge tank

• RAB sumps

" RWST

• RMWST

• Recycle Holdup Tank Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

I EP-EAL I Rev. 0 1 Page 75 of 259

ATTACHMENT 1 EAL Bases HNP Basis:

In Cold Shutdown mode, the RCS will normally be intact and standard RCS level monitoring means are available. RCS level in the Refueling mode is normally monitored using the standpipe.

In this EAL, all water level indication is unavailable and the RCS inventory loss must be detected by indirect leakage indications. Level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage. If the make-up rate to the RCS unexplainably rises above the pre-established rate, a loss of RCS inventory may be occurring even if the source of the leakage cannot be immediately identified. Sumps and tanks where RCS leakage may accumulate are listed in listed in Table C-1. Visual observation of leakage from systems connected to the RCS that cannot be isolated could also be indicative of a loss of RCS inventory (ref. 1, 2).

NEI 99-01 Basis:

This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Refueling evolutions that decrease RCS water inventory are carefully planned and controlled.

An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

This EAL addresses a condition where all means to determine RPV level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.

HNP Basis Reference(s):

1. GP-001, Reactor Coolant System Fill and Vent Mode 5

2. GP-008, Draining the Reactor Coolant System

3. GP-009, Refueling Cavity Fill, Refueling and Drain of the Refueling Cavity Modes 5-6-5

4. NEI 99-01 CUl I EP-EAL Rev. 0 Page 76 of 259

ATTACHMENT 1 EAL Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory EAL:

CA1.1 Alert Loss of RCS inventory as indicated by LI-403 or RCS standpipe level < - 82 in.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

None HNP Basis:

LI-403 or RCS standpipe level of - 82" corresponds to the minimum RCS level for continued RHR pump operation (ref. 1, 2, 3).

NEI 99-01 Basis:

This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.

For this EAL, a lowering of RCS water level below 82" below the reactor vessel flange indicates that operator actions have not been successful in restoring and maintaining RCS water level. The heat-up rate of the coolant will increase as the available water inventory is reduced. A continuing decrease in water level will lead to core uncovery.

Although related, this EAL is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). An increase in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3.

If the RCS inventory water level continues to lower, then escalation to Site Area Emergency would be via IC CSI.

HNP Basis Reference(s):

1. GP-008, Draining the Reactor Coolant System

2. AOP-20, Loss of RCS Inventory or Residual Heat Removal While Shutdown EP-EAL I Rev. 0 Page 77 of 259

ATTACHMENT 1 EAL Bases

3. AOP-20, Loss of RCS Inventory or Residual Heat Removal While Shutdown - Basis Document

4. NEI 99-01 CA1 IEP-EAL I Rev. 0 1 Page 78 of 259

ATTACHMENT 1 EAL Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory EAL:

CA1.2 Alert RCS water level cannot be monitored for - 15 min. (Note 1)

AND EITHER

" UNPLANNED increase in any Table C-1 sump or tank due to a loss of RCS inventory

• Visual observation of UNISOLABLE RCS leakage Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Table C-1 Sumps I Tanks

• Containment sumps

• PRT

• RCDT

• CCW surge tank

• RAB sumps

• RWST

• RMWST

• Recycle Holdup Tank Mode Applicability:

5 - Cold Shutdown, 6- Refueling Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

EP-EAL I Rev. O Page 79 of 259

ATTACHMENT 1 EAL Bases HNP Basis:

In Cold Shutdown mode, the RCS will normally be intact and standard RPV level monitoring means are available. In the Refuel mode, the RCS is not intact and RPV level may be monitored by different means, including the ability to monitor level visually.

In this EAL, all RCS water level indication would be unavailable for greater than 15 minutes, and the RCS inventory loss must be detected by indirect leakage indications. Sump level increases must be evaluated against other potential sources of leakage. If the make-up rate to the RCS unexplainably rises above the pre-established rate, a loss of RCS inventory may be occurring even if the source of the leakage cannot be immediately identified. Sumps and tanks where RCS leakage may accumulate are listed in listed in Table C-1. Visual observation of leakage from systems connected to the RCS that cannot be isolated could also be indicative of a loss of RCS inventory (ref. 1, 2).

NEI 99-01 Basis:

This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.

For this EAL, the inability to monitor RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.

The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS1.

If the RCS inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS1.

HNP Basis Reference(s):

1. GP-001, Reactor Coolant System Fill and Vent Mode 5

2. GP-008, Draining the Reactor Coolant System

3. GP-009, Refueling Cavity Fill, Refueling and Drain of the Refueling Cavity Modes 5-6-5

4. NEI 99-01 CA1 I EP-EAL Rev. 0 1 Page 80 of 259

ATTACHMENT 1 EAL Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL:

CSl.1 Site Area Emergency With CONTAINMENT CLOSURE not established, RCS level < 70% RVLIS Full Range Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The procedurally defined actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. As applied to HNP, Containment Closure is established when containment penetration closure is established in accordance with Technical Specifications 3/4.9.4.

HNP Basis:

70% RVLIS Full Range (ref. 1, 2) corresponds to the level of six inches below the bottom ID of the RCS hot leg penetration (252.04' el.). 6% has been added to the RVLIS setpoint to account for instrument uncertainties (ref. 2).

NEI 99-01 Basis:

This IC addresses a significant and prolonged loss of RCS inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant.

These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS level cannot be restored, fuel damage is probable.

Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions. The difference in the specified RCS levels of CS1.1 and CS1.2 reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.

EP-EAL Rev. 0 Page 81 of 259

ATTACHMENT 1 EAL Bases This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via IC CG1 or RG1 HNP Basis Reference(s):

1. GP-008, Draining the Reactor Coolant System

2. EOP Setpoint Study, Revision 19, 4.0, FN K03

3. NEI 99-01 CS1 IEP-EAL I Rev. 0 Page 82 of 259

ATTACHMENT 1 EAL Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL:

CSl.2 Site Area Emergency With CONTAINMENT CLOSURE established, RCS level < 63% RVLIS Full Range Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The procedurally defined actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. As applied to HNP, Containment Closure is established when containment penetration closure is established in accordance with Technical Specifications 3/4.9.4.

HNP Basis:

63% RVLIS Full Range (ref. 1, 2) corresponds to the top of active fuel (249.01' el.). Other RCS level instruments are off-scale low when core uncovery occurs. 6% has been added to the RVLIS setpoint to account for instrument uncertainties (ref. 2).

NEI 99-01 Basis:

This IC addresses a significant and prolonged loss of RCS inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant.

These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS level cannot be restored, fuel damage is probable.

Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions. The difference in the specified RCS levels of CS1.1 and CS1.2 reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.

EP-EAL Rev. 0 Page 83 of 259

ATTACHMENT 1 EAL Bases This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via IC CG1 or RG1 HNP Basis Reference(s):

1. GP-008, Draining the Reactor Coolant System

2. EOP Setpoint Study, Revision 19, 4.0, FN K03

3. NEI 99-01 CS1 IEP-EAL I Rev. 0 Page 84 of259

ATTACHMENT 1 EAL Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL:

CSI.3 Site Area Emergency RCS water level cannot be monitored for a 30 min. (Note 1)

AND Core uncovery is indicated by any of the following:

" UNPLANNED increase in any Table C-1 sump or tank due to a loss of RCS inventory

" Visual observation of UNISOLABLE RCS leakage

• Containment radiation > 10,000 R/hr (RM-1 CR-3589-SA or RM-1 CR-3590-SB)

• Erratic source range monitor indication Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Table C-1 Sumps / Tanks

• Containment sumps

• PRT

• RCDT

• CCW surge tank

• RAB sumps

• RWST

• RMWST

• Recycle Holdup Tank Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

EP-EAL I Rev. 0 Page 85 of 259

ATTACHMENT 1 EAL Bases UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

HNP Basis:

In this EAL, all RCS water level indication would be unavailable for greater than 30 minutes, and the RCS inventory loss must be detected by indirect leakage indications. Sump level increases must be evaluated against other potential sources of leakage. If the make-up rate to the RCS unexplainably rises above the pre-established rate, a loss of RCS inventory may be occurring even if the source of the leakage cannot be immediately identified. Sumps and tanks where RCS leakage may accumulate are listed in listed in Table C-1. Visual observation of leakage from systems connected to the RCS that cannot be isolated could also be indicative of a loss of RCS inventory (ref. 1, 2).

In the Refueling Mode, as water level in the reactor vessel lowers, the dose rate above the core will increase. The dose rate due to this core shine should result in indications on installed area radiation monitors (RM-1 CR-3589-SA or RM-1 CR-3590-SB). If these radiation monitors reach and exceed 10,000 R/hr, a loss of inventory with potential to uncover the core is likely to have occurred (ref. 4).

Post-TMI accident studies indicated that the installed PWR nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations.

NEI 99-01 Basis:

This IC addresses a significant and prolonged loss of RCS inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant.

These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS level cannot be restored, fuel damage is probable.

The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes EP-EAL I Rev. 0 Page 86 of 259

ATTACHMENT 1 EAL Bases in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RCS.

This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via IC CGI or RGI HNP Basis Reference(s):

1. GP-001, Reactor Coolant System Fill and Vent Mode 5

2. GP-008, Draining the Reactor Coolant System

3. GP-009, Refueling Cavity Fill, Refueling and Drain of the Refueling Cavity Modes 5-6-5

4. AOP-031-BD, Loss of Refueling Cavity Integrity- Basis Document

5. NEI 99-01 CS1 I EP-EAL Rev. 0 Page 87 of 259

ATTACHMENT 1 EAL Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:

CGI.1 General Emergency RCS level < 63% RVLIS Full Range for Ž_30 min. (Note 1)

AND Any Containment Challenge indication, Table C-2 Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

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

Table C-2 Containment Challenge Indications

• CONTAINMENT CLOSURE not established (Note 6)

• Containment hydrogen concentration a 4%

• UNPLANNED rise in Containment pressure Mode Applicability:

5 - Cold Shutdown, 6- Refueling IEP-EAL I Rev. 0 1 Page 88 of 259

ATTACHMENT 1 EAL Bases Definition(s):

CONTAINMENT CLOSURE - The procedurally defined actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. As applied to HNP, Containment Closure is established when containment penetration closure is established in accordance with Technical Specifications 3/4.9.4.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

HNP Basis:

63% RVLIS Full Range (ref. 1, 2) corresponds to the top of active fuel (249.01' el.). Other RCS level instruments are off-scale low when core uncovery occurs. 6% has been added to the RVLIS setpoint to account for instrument uncertainties (ref. 2).

Three conditions are associated with a challenge to containment integrity:

• CONTAINMENT CLOSURE is not established.

• In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive mixture of dissolved gases in the containment. However, containment monitoring and/or sampling should be performed to verify this assumption and a General Emergency declared if it is determined that an explosive mixture exists. An explosive mixture can be formed when hydrogen gas concentration in the containment atmosphere is greater than 4% by volume in the presence of oxygen.

" Any unplanned increase in containment pressure in the Cold Shutdown or Refueling mode indicates a potential loss of containment closure capability. Unplanned containment pressure increases indicates containment closure cannot be assured and the containment cannot be relied upon as a barrier to fission product release.

NEI 99-01 Basis:

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity.

Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS level cannot be restored, fuel damage is probable.

I EP-EAL Rev. 0 Page 89 of 259

ATTACHMENT 1 EAL Bases With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operationat Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

HNP Basis Reference(s):

1. GP-008, Draining the Reactor Coolant System

2. EOP Setpoint Study, Revision 19, 4.0, FN K03

6. NEI 99-01 CG1 I EP-EAL Rev. 0 ] Page 90 of 259

ATTACHMENT 1 EAL Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:

CGI.2 General Emergency RCS level cannot be monitored for 2t 30 min. (Note 1)

AND Core uncovery is indicated by any of the following:

" UNPLANNED increase in any Table C-1 sump or tank due to a loss of RCS inventory

• Visual observation of UNISOLABLE RCS leakage

• Containment radiation > 10,000 R/hr (RM-1 CR-3589-SA or RM-1 CR-3590-SB)

• Erratic source range monitor indication AND Any Containment Challenqe indication, Table C-2 Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

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

Table C-1 Sumps I Tanks

• Containment sumps

• PRT

• RCDT

• CCW surge tank

• RAB sumps

• RWST

• RMWST

• Recycle Holdup Tank I EP-EAL Rev. 0 1 Page 91 of 259

ATTACHMENT 1 EAL Bases Table C-2 Containment Challenge Indications

• CONTAINMENT CLOSURE not established (Note 6)

• Containment hydrogen concentration > 4%

• UNPLANNED rise in Containment pressure Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The procedurally defined actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. As applied to HNP, Containment Closure is established when containment penetration closure is established in accordance with Technical Specifications 3/4.9.4.

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

HNP Basis:

In this EAL, all RCS water level indication would be unavailable for greater than 30 minutes, and the RCS inventory loss must be detected by indirect leakage indications. Sump level increases must be evaluated against other potential sources of leakage. If the make-up rate to the RCS unexplainably rises above the pre-established rate, a loss of RCS inventory may be occurring even if the source of the leakage cannot be immediately identified. Sumps and tanks where RCS leakage may accumulate are listed in listed in Table C-1. Visual observation of leakage from systems connected to the RCS that cannot be isolated could also be indicative of a loss of RCS inventory (ref. 1, 2).

In the Refueling Mode, as water level in the reactor vessel lowers, the dose rate above the core will increase. The dose rate due to this core shine should result in indications on installed area radiation monitors (RM-1 CR-3589-SA or RM-1 CR-3590-SB). If these radiation monitors reach and exceed 10,000 R/hr, a loss of inventory with potential to uncover the core is likely to have occurred (ref. 4).

Post-TMI accident studies indicated that the installed PWR nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations.

Three conditions are associated with a challenge to containment integrity:

• CONTAINMENT CLOSURE is not established.

IEP-EAL I Rev. 0 Page 92 of 259

ATTACHMENT 1 EAL Bases

• In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive mixture of dissolved gases in the containment. However, containment monitoring and/or sampling should be performed to verify this assumption and a General Emergency declared if it is determined that an explosive mixture exists. An explosive mixture can be formed when hydrogen gas concentration in the containment atmosphere is greater than 4% by volume in the presence of oxygen.

• Any unplanned increase in containment pressure in the Cold Shutdown or Refueling mode indicates a potential loss of containment closure capability. Unplanned containment pressure increases indicates containment closure cannot be assured and the containment cannot be relied upon as a barrier to fission product release.

NEI 99-01 Basis:

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity.

Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS level cannot be restored, fuel damage is probable.

With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment EP-EAL Rev. 0 1 Page 93 of 259

ATTACHMENT 1 EAL Bases and/or restore level monitoring.

The inability to monitor RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from theRCS.

This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1 449, Shutdown and Low-Power Operationat Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

HNP Basis Reference(s):

1. GP-001, Reactor Coolant System Fill and Vent Mode 5

2. GP-008, Draining the Reactor Coolant System

3. GP-009, Refueling Cavity Fill, Refueling and Drain of the Refueling Cavity Modes 5-6-5

4. AOP-031-BD, Loss of Refueling Cavity Integrity- Basis Document

5. NEI 99-01 CG1 IEP-EAL I Rev. 0 Page 94 of 259

ATTACHMENT 1 EAL Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 2 - Loss of Emergency AC Power Initiating Condition: Loss of all but one AC power source to emergency buses for 15 minutes or longer EAL:

CU2.1 Unusual Event AC power capability to emergency 6.9 KV buses 1A-SA and 1B-SB reduced to a single power source for > 15 min. (Note 1)

AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, D - Defueled Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

HNP Basis:

Power is supplied from the main generator to the switchyard through a main transformer bank. The main generator is directly connected to the main transformer bank through a 22 KV bus system and the 230 KV switchyard.

EP-EAL Rev. 0 Page 95 of 259

ATTACHMENT 1 EAL Bases The Plant Electric Power Distribution System receives power under normal operating conditions from the main generator through two unit auxiliary transformers.

For startup and shutdown, when the main generator is unavailable, power is obtained through two start-up transformers from the grid and the 230 KV switchyard. These two transformers have sufficient capacity to provide for start-up and full load operation of the Unit. They also provide two separate sources of preferred (offsite) power to the Unit.

An additional path of power supply from the grid to the Plant Electric Power Distribution System can be made available after opening the disconnect links and disconnecting the main generator from the 22 KV bus. Power can be fed from the offsite power system through the main transformer bank and 22 KV bus to the unit auxiliary transformer, leaving the main generator disconnected. (ref. 2)

Emergency buses 1A-SA and 1B-SB provide power to supply all of the safety-related loads.

The normal source of power for the emergency buses is the main generator/unit auxiliary transformer. When this source of power is not available, power is supplied from the 230 KV switchyard through the start-up transformers or, with the generator disconnect links removed, from the main and unit auxiliary transformers. When neither of these sources is available, power to the two emergency buses is supplied from diesel generators EDG A and EDG B (one diesel generator for each emergency bus). (ref. 3)

This cold condition EAL is equivalent to the hot condition EAL SAI.1.

NEI 99-01 Basis:

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased time available to restore another power source to service.

Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.

An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.

• A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).

• A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.

• A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being fed from an offsite power source.

EP-EAL Rev. 0 1 Page 96 of 259

ATTACHMENT 1 EAL Bases Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.

The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA2.

HNP Basis Reference(s):

1. FSAR Figure 8.1.3-1

2. FSAR 8.2

3. FSAR 8.3

4. EOP-ECA-0.0, Loss of all AC Power

5. NEI 99-01 CU2 IEP-EAL I Rev. 0 Page 97 of 259

ATTACHMENT 1 EAL Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 2 - Loss of Emergency AC Power Initiating Condition: Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer EAL:

CA2.1 Alert Loss of all offsite and all onsite AC power capability to 6.9 KV emergency buses 1A-SA and 1B-SB for > 15 min. (Note 1)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, D - Defueled HNP Basis:

Power is supplied from the main generator to the switchyard through a main transformer bank. The main generator is directly connected to the main transformer bank through a 22 KV bus system and the 230 KV switchyard.

The Plant Electric Power Distribution System receives power under normal operating conditions from the main generator through two unit auxiliary transformers.

For startup and shutdown, when the main generator is unavailable, power is obtained through two start-up transformers from the grid and the 230 KV switchyard. These two transformers have sufficient capacity to provide for start-up and full load operation of the Unit. They also provide two separate sources of preferred (offsite) power to the Unit.

An additional path of power supply from the grid to the Plant Electric Power Distribution System can be made available after opening the disconnect links and disconnecting the main generator from the 22 KV bus. Power can be fed from the offsite power system through the main transformer bank and 22 KV bus to the unit auxiliary transformer, leaving the main generator disconnected. (ref. 2)

Emergency buses 1A-SA and 1 B-SB provide power to supply all of the safety-related loads.

The normal source of power for the emergency buses is the main generator/unit auxiliary transformer. When this source of power is not available, power is supplied from the 230 KV switchyard through the start-up transformers or, with the generator disconnect links removed, from the main and unit auxiliary transformers. When neither of these sources is available, power to the two emergency buses is supplied from diesel generators EDG A and EDG B (one diesel generator for each emergency bus). (ref. 3)

IEP-EAL I Rev. 0 Page 98 of 259

ATTACHMENT 1 EAL Bases This cold condition EAL is equivalent to the hot condition loss of all offsite AC power EAL SS1.1.

NEI 99-01 Basis:

This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an emergency bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via IC CS1 or RS1.

HNP Basis Reference(s):

1. FSAR Figure 8.1.3-1

2. FSAR 8.2

3. FSAR 8.3

4. EOP-ECA-0.0, Loss of all AC Power

5. NEI 99-01 CA2 IEP-EAL I Rev. 0 Page 99 of 259