Text

Salem, EAL Comparison Matrix
	ML110060238
Person / Time
Site:	Salem, Hope Creek
Issue date:	08/12/2010
From:	; Public Service Enterprise Group
To:	; Office of Nuclear Reactor Regulation
References
	LR-N10-0355
	Download: ML110060238 (147)
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Attachment 7 SGS EAL Comparison Matrix

\GENERATING STATIONt&7ýSalem Generating Station EAL Comparison Matrix Draft E -8/12/10 EAL Comparison Matrix OSSI -SGS Table of Contents Section Pagqe Introduction

1 Comparison Matrix Format -------------------------------------------------------------------------------------------------------------------------------------

1 EAL Emphasis Techniques

1 Global Differences

1 Differences and Deviations

3 Category R -Abnormal Rad Levels / Rad Effluent -------------------------------------------------------

21 Category C -Cold Shutdown / Refueling System Malfunction

41 Category D -Permanently Defueled Station Malfunction

65 Category E -Events Related to Independent Spent Fuel Storage Installations

67 Category F -Fission Product Barrier Degradation

70 Category H -Hazards and Other Conditions Affecting Plant Safety -------------------------------------------

94 Category S -System Malfunction

121 Table 1 -SGS EAL Categories/Subcategories

5 Table 2 -NEI / SGS EAL Identification Cross-Reference

6 Table 3 -Summary of Deviations

13 Table 4 -Defined Terms -------------------------------------------------------------------------

14 i ofi EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS Introduction This document provides a line-by-line comparison of the Initiating Conditions (ICs), Mode Applicability and Emergency Action Levels (EALs) in NEI 99-01 Revision 5, Methodology for Development of Emergency Action Levels, and the SGS ICs, Mode Applicability and EALs. This document provides a means of assessing SGS differences and deviations from the NRC endorsed guidance given in NEI 99-01. Discussion of SGS EAL bases and lists of source document references are given in the EAL Technical Bases Document.

It is, therefore, advisable to reference the EAL Technical Bases Document for background information while using this document.Comparison Matrix Format The ICs and EALs discussed in this document are grouped according to NEI 99-01 Recognition Categories.

Within each Recognition Category, the ICs and EALs are listed in tabular format according to the order in which they are given in NEI 99-01. Generally, each row of the comparison matrix provides the following information:

NEI EAL/IC identifier

NEI EAL/IC wording* SGS EAL/IC identifier

SGS EAL/IC wording* Description of any differences or deviations EAL Emphasis Techniques Due to the width of the table columns and table formatting constraints in this document, line breaks and indentation may differ slightly from the appearance of comparable wording in the source documents.

NEI 99-01 Revision 5 (ADAMS Accession Number ML080450149) is the source document for the NEI EALs; the SGS EAL Technical Bases Document for the SGS EALs.The print and paragraph formatting conventions summarized below guide presentation of the SGS EALs. Space restrictions in the EAL table of this document sometimes override this guidance in cases when following the guidance would introduce undesirable complications in the EAL layout.Words or acronyms that are both uppercase and bold are defined terms.* EAL threshold values and table references are bold but are not uppercase.

EAL words or acronyms that are not threshold values and not defined terms may be emphasized by using uppercase print.* Bold font, uppercase and underscore are used for logic terms, and quantifiers such as any, all, both, etc.Global Differences The differences listed below generally apply throughout the set of EALs. The global differences do not decrease the effectiveness of the intent of NEI 99-01 Revision 5.1. The NEI phrase "Notification of Unusual Event" has been changed to"Unusual Event" to reduce EAL-user reading burden.2. The generic term "Emergency Director" has been replaced with the term "Emergency Coordinator" as the site specific title used at SGS and HCGS.3. NEI 99-01 IC Example EALs are implemented in separate plant EALs to improve clarity and readability.

For example, NEI lists all IC HU1 Example EALs under one IC. The corresponding SGS EALs appear as unique EALs (e.g., HU1.1 through HU1.5).4. Mode applicability identifiers (numbers/letter) modify the NEI 99-01 mode applicability names as follows: 1 -Power Operation, 2 -Startup, 3 -Hot Standby, 4 -Hot Shutdown, 5 -Cold Shutdown, 6 -Refueling, D -Defueled.

NEI 99-01 defines Defueled as follows: "All reactor fuel removed from reactor pressure vessel. (Full core off load during refueling or extended outage)." 5. NEI 99-01 uses words for phrases such as greater than, less than, greater than or equal to, etc. in the wording of ICs and example EALs. To reduce EAL-user reading burden and for consistency with plant procedures, SGS has adopted use of the symbols >, >, < and <in place of the NEI 99-01 modifiers.

6. NEI EALs that include a time interval such as "15 minutes or longer" are expressed as conditional phrases "AND [interval]

minutes have 1 of 144 EAL Comparison Matrix 0551- SGS EAL Comparison Matrix OSSI -SGS elapsed (Note 3)" to ensure the associated interval is not obscured by the EAL wording. (Some format variations are adopted to maintain proper syntax.) The parenthetical reference to a note directs the EAL-user to the appropriate NEI note concerning interpretation of the time interval.7. EAL notes are numbered to facilitate referencing in the EAL matrix.8. The NEI phrase "RPV/RCS water level" has been changed to "RCS level" for constancy with SGS EOPs and other operating procedures.

9. IC/EAL identification:

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 Recognition Categories, however, are so broad and the IC descriptions are so varied that an EAL is difficult to locate in a timely manner when the EAL-user must refer to a set of EALs with the NEI organization and identification scheme. The NEI document clearly states that the EAL/IC/Recognition Category scheme is not intended to be the plant-specific EAL scheme for any plant, and appropriate human factors principles should be applied to development of an EAL scheme that helps the EAL-user make timely and accurate classifications.

SGS endeavors to improve upon the NEI EAL organization and identification scheme to enhance usability of the plant-specific EAL set. To this end, the SGS IC/EAL scheme includes the following features: a. Division of the NEI EAL set into three 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 Operations 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.

b. Within each of the above three groups, assignment of EALs to categories/subcategories

-Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user.Subcategories are used as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds.

The SGS EAL categories/subcategories and their relationship to NEI Recognition Categories are listed in Table 1.c. Unique identification of each EAL -Four characters comprise the EAL identifier as illustrated in Figure 1.Figure 1 -EAL Identifier EAL Identifier XXX.X Category (R, H, E, C, S, F) L Sequential number within subcategory/classification Emergency classification (G, S, A, U) __ L __ Subcategory number (1 if no subcategory)

The first character is a letter associated with the category in which the EAL is located. The second character is a letter associated with the emergency classification level (G for General Emergency, S for Site Area Emergency, A for Alert, and U for Unusual Event). The third character is a number associated with one or more subcategories within a given category.

Subcategories are sequentially numbered beginning with the number "1". If a category does not have a subcategory, this character is assigned the number "1 ". The fourth character is a number preceded by a period for each EAL within a subcategory.

2 of 144 EAL Comparison Matrix OSSI -SGS EALs are sequentially numbered within the emergency classification level of a subcategory beginning with the number "1 ".The EAL identifier is designed to fulfill the following objectives:

o Uniqueness

-The EAL identifier ensures that there can be no confusion over which EAL is driving the need for emergency classification.

o Speed in locating the EAL of concern -When the EALs are displayed in a matrix format, knowledge of the EAL identifier alone can lead the EAL-user to the location of the EAL within the classification matrix. The identifier conveys the category, subcategory and classification level. This assists ERO responders (who may not be in the same facility as the Emergency Coordinator) to find the EAL of concern in a timely manner without the need for a word description of the classification threshold.

o Possible classification upgrade -The category/subcategory/identifier scheme helps the EAL-user find higher emergency classification EALs that may become active if plant conditions worsen.Note that the NEI 99-01 identifier only identifies the IC, not the specific example EAL threshold.

The NEI scheme, therefore, does not fulfill the above objectives which are desirable in facilitating timely and accurate emergency classification.

Table 2 lists the SGS ICs and EALs that correspond to the NEI ICs/Example EALs when the above EAL/IC organization and identification scheme is implemented.

Differences and Deviations In accordance NRC Regulatory Issue Summary (RIS) 2003-18 "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels" Supplements 1 and 2, a difference is an EAL change in which the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the SGS EAL. A deviation is an EAL change in which 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 SGS proposed EAL.Administrative changes that do not actually change the textual content are neither differences nor deviations.

Likewise, any format change that does not alter the wording of the IC or EAL is considered neither a difference nor a deviation.

The following are examples of differences:

Choosing the applicable EAL based upon plant type (i.e., BWR vs.PWR).* Using a numbering scheme other than that provided in NEI 99-01 that does not change the intent of the overall scheme.* Where the NEI 99-01 guidance specifically provides an option to not include an EAL if equipment for the EAL does not exist at SGS (e.g., automatic real-time dose assessment capability).

Pulling information from the bases section up to the actual EAL that does not change the intent of the EAL.* Choosing to state ALL Operating Modes are applicable instead of stating N/A, or listing each mode individually under the Abnormal Rad Level/Rad Effluent and Hazard and Other Conditions Affecting Plant Safety sections." Using synonymous wording (e.g., greater than or equal to vs. at or above, less than or equal vs. at or below, greater than or less than vs. above or below, etc.)* Adding SGS equipment/instrument identification and/or noun names to EALs." Changing the format of the EALs to conform to the SGS EAL convention (e.g., numbering individual EALs, re-ordering individual EALs within an IC that does not affect the logic, etc.).* Combining like ICs that are exactly the same but have different operating modes as long as the intent of each IC is maintained and the overall progression of the EAL scheme is not affected.3 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Matrix OSSI -SGS* Any change to the IC and/or EAL, and/or basis wording, as stated in NEI 99-01, that does not alter the intent of the IC and/or EAL, i.e., the IC and/or EAL continues to: o Classify at the correct classification level.o Logically integrate with other EALs in the EAL scheme.o Ensure that the resulting EAL scheme is complete (i.e., classifies all potential emergency conditions).

The following are examples of deviations:

Use of altered mode applicability.

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 99-01 definitions.

The intent is for all NEI 99-01 users to have a standard set of defined terms as defined in NEI 99-01.Differences due to plant types are permissible (BWR or PWR).Verbatim compliance to the wording in NEI 99-01 is not necessary as long as the intent of the defined word is maintained.

Use of the wording provided in NEI 99-01 is encouraged since the intent is for all users to have a standard set of defined terms as defined in NEI 99-01.* Any change to the IC and/or EAL, and/or basis wording as stated in NEI 99-01 that does alter the intent of the IC and/or EAL, i.e., the IC and/or EAL: o Does not classify at the classification level consistent with NEI 99-01.o Is not logically integrated with other EALs in the EAL scheme.o Results in an incomplete EAL scheme (i.e., does not classify all potential emergency conditions).

The "Difference/Deviation Justification" columns in the remaining sections of this document identify each difference between the NEI 99-01 IC/EAL wording and the SGS IC/EAL wording. An explanation that justifies the reason for each difference is then provided.

If the difference is determined to be a deviation, a statement is made to that affect and explanation is given that states why classification may be different from the NEI 99-01 IC/EAL and the reason for its acceptability.

In all cases, however, the differences and deviations do not decrease the effectiveness of the intent of NEI 99-01 Revision 5. A summary list of SGS EAL deviations from NEI 99-01 is given in Table 3.4 of 144 EAL Comparison Matrix OSSI -SGS Table 1 -SGS EAL Categories/Subcategories SGS EALs NEI Category Subcategory Recognition Category Group: Any Operating Mode: R -Abnormal Rad Release / Rad Effluent 1 -Offsite Rad Conditions Abnormal Rad Levels/Radiological 2 -Onsite Rad Conditions/Fuel Pool Effluent Events 3 -CR/CAS Rad E -ISFSI Spent Fuel Transit Events Related to Independent Spent Fuel Storage Installations H -Hazards & Other Conditions Affecting 1 -Natural & Destructive Phenomena Hazards and Other Conditions Affecting Plant Safety 2 -Fire or Explosion Plant Safety 3 -Hazardous Gas 4 -Security 5 -Control Room Evacuation 6 -EC Judgment Group: Hot Conditions:

S -System Malfunction 1 -Loss of AC Power System Malfunction 2 -Loss of DC Power 3 -ATWT / Criticality 4 -Inability to Reach or Maintain Shutdown Conditions 5 -Instrumentation 6 -Communications 7 -Fuel Clad Degradation 8 -RCS Leakage F -Fission Product Barrier Degradation None Fission Product Barrier Degradation Group: Cold Conditions:

C -Cold Shutdown / Refuel System 1 -Loss of AC Power Cold Shutdown./

Refueling System Malfunction 2 -Loss of DC Power Malfunction 3 -RCS Level 4 -RCS Temperature 5 -Communications 6 -Inadvertent Criticality 5 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS Table 2 -NEI / SGS EAL Identification Cross-Reference NEI Salem Generating Station Example Category and Subcategory EAL EAL RU1 1 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RU1.1 RU1.2 RU1 2 N/A N/A RU1 3 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RU1.3 RU1 4 N/A N/A RU1 5 N/A N/A RU2 1 R -Abnormal Rad Release / Rad Effluent, 2 -Onsite Rad Conditions

& Fuel RU2.1 Pool Events RU2 2 R -Abnormal Rad Release / Rad Effluent, 2 -Onsite Rad Conditions

& Fuel RU2.2 Pool Events RA1 1 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RA1.1 RA1.2 RA1 2 N/A N/A RA1 3 R -Abnormal Rad Release I Rad Effluent, 1 -Offsite Rad Conditions RA1.3 RA1 4 N/A N/A RA1 5 N/A N/A RA2 1 R -Abnormal Rad Release / Rad Effluent, 2 -Onsite Rad Conditions

& Fuel RA2.2 Pool Events 6 of 144 EAL Comparison Matrix 0531 -SGS EAL Comparison Matrix OSSI -SGS NEI Salem Generating Station IC Example Category and Subcategory EAL EAL RA2 2 R -Abnormal Rad Release/ Rad Effluent, 2 -Onsite Rad Conditions

& Fuel RA2.1 Pool Events RA3 1 R -Abnormal Rad Release / Rad Effluent, 2 -CR/CAS Rad RA3.1 RS1 1 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RS1.1 RS1 2 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RS1.2 RS1 3 N/A N/A RS1 4 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RS1.3 RG1 1 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RG1.1 RG1 2 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RG1.2 RG1 3 N/A N/A RG1 4 R -Abnormal Rad Release / Rad Effluent, 1 -Offsite Rad Conditions RG1.3 CUl 1, 2 C -Cold SD/ Refuel System Malfunction, 3 -RCS Level CU3.1 CU2 1 C -Cold SD/ Refuel System Malfunction, 3 -RCS Level CU3.2 CU2 2 C -Cold SD/ Refuel System Malfunction, 3 -RCS Level CU3.3 CU3 1 C -Cold SD/ Refuel System Malfunction, 1 -Loss of AC Power CU1.1 CU4 1 C -Cold SD/ Refuel System Malfunction, 4 -RCS Temperature CU4.1 CU4 2 C -Cold SD/ Refuel System Malfunction, 4 -RCS Temperature CU4.2 CU6 1, 2 C -Cold SD/ Refuel System Malfunction, 5 -Communications CU5.1 CU7 1 C -Cold SD/ Refuel System Malfunction, 2 -Loss of DC Power CU2.1 7 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Matrix OSSI -SGS NEI Salem Generating Station Example Category and Subcategory EAL EAL CU8 1 C -Cold SD/ Refuel System Malfunction, 6 -Inadvertent Criticality CU6.1 CU8 2 N/A N/A CA1 1 C -Cold SD/ Refuel System Malfunction, 3 -RCS Level CA3.1 CA1 2 C -Cold SD! Refuel System Malfunction, 3 -RCS Level CA3.2 CA3 1 C -Cold SD! Refuel System Malfunction, 1 -Loss of AC Power CA1.1 CA4 1, 2 C -Cold SD! Refuel System Malfunction, 4 -RCS Temperature CA4.1 CS1 1,2 N/A N/A CS1 3 C -Cold SD/ Refuel System Malfunction, 3 -RCS Level CS3.2 CG1 1 N/A N/A CG1 2 C -Cold SD! Refuel System Malfunction, 3 -RCS Level CG3.2 D-AU1 N/A N/A D-AU2 D-SU1 D-HU1 D-HU2 D-HU3 D-AA1 D-AA2 D-HA1 D-HA2 EU1 1 E- ISFSI EU1.1 8 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS NEI Salem Generating Station IC Example Category and Subcategory EAL EAL FU1 1 F -Fission Product Barriers 2 or 3 points FA1 1 F -Fission Product Barriers 4 or 5 points FS1 1 F -Fission Product Barriers 6 -11 points FG1 1 F- Fission Product Barriers 12 or 13 points HU1 1 H -Hazards, 1 -Natural & Destructive Phenomena HUM.HU1 2 H -Hazards, 1 -Natural & Destructive Phenomena HU1.2 HU1 3 H -Hazards, 1 -Natural & Destructive Phenomena HU1.4 HU1 4 H -Hazards, 1 -Natural & Destructive Phenomena HU1.3 HU1 5 H -Hazards, 1 -Natural & Destructive Phenomena HU1.5 HU2 1 H -Hazards, 2 -Fire or Explosion HU2.1 HU2 2 H -Hazards, 2 -Fire or Explosion HU2.2 HU3 1 H -Hazards, 3 -Toxic, Corrosive, Asphyxiant

& Flammable Gas HU3.1 HU3 2 H -Hazards, 3 -Toxic, Corrosive, Asphyxiant

& Flammable Gas HU3.2 HU4 1,2, 3 H -Hazards, 4 -Security HU4.1 HU5 1 H -Hazards, 6 -EC Judgment HU6.1 HA1 1 H -Hazards, 1 -Natural & Destructive Phenomena HA1.1 HA1 2 H -Hazards, 1 -Natural & Destructive Phenomena HA1.2 HA1 3 H -Hazards, 1 -Natural & Destructive Phenomena HA1.4 9 of 144 EAL Comparison Matrix 0551 -SGS EAL Comparison Matrix OSSI -SGS NEI Salem Generating Station IC Example Category and Subcategory EAL IC EAL HA1 4 H -Hazards, 1 -Natural & Destructive Phenomena HA1.3 HA1 5 H -Hazards, 1 -Natural & Destructive Phenomena HA1.6 HAI 6 N/A N/A HA2 1 H -Hazards, 2 -Fire or Explosion HA2.1 HA2.2 HA3 1 H -Hazards, 3 -Toxic, Corrosive, Asphyxiant

& Flammable Gas HA3.1 HA4 1, 2 H -Hazards, 4 -Security HA4.1 HA5 1 H -Hazards, 5 -Control Room Evacuation HA5.1 HA6 1 H -Hazards, 6- EC Judgment HA6.1 HS2 1 H -Hazards, 5 -Control Room Evacuation HS5.1 HS3 1 H -Hazards, 6 -EC Judgment HS6.1 HS4 1 H -Hazards, 4 -Security HS4.1 HG1 1, 2 H -Hazards, 4 -Security HG4.1 HG2 1 H -Hazards, 6 -EC Judgment HG6.1 SUl 1 S -System Malfunction, 1 -Loss of AC Power SU1.1 SU2 1 S -System Malfunction, 3 -Inability to Reach or Maintain Shutdown SU3.1 Conditions SU3 1 S -System Malfunction, 5 -Instrumentation SU5.1 SU4 1 S -System Malfunction, 7 -Fuel Clad Degradation SU7.1 10 of 144 EAL Comparison Matrix OSSI -SGS NEI Salem Generating Station IC Example Category and Subcategory EAL EAL SU4 2 S -System Malfunction, 7 -Fuel Clad Degradation SU7.2 SU5 1,2 S- System Malfunction, 8- RCS Leakage SU8.1 SU6 1,2 S -System Malfunction, 6 -Communications SU6.1 SU8 1 (BWR) N/A N/A SU8 1 (PWR) S -System Malfunction, 3 -ATWT / Criticality SU3.1 SA2 1 S -System Malfunction, 3 -ATWT / Criticality SA3.1 SA4 1 S -System Malfunction, 5 -Instrumentation SA5.1 SA5 1 S -System Malfunction, 1 -Loss of AC Power SA1.1 SS1 1 S -System Malfunction, 1 -Loss of AC Power SS1.1 SS2 1 S -System Malfunction, 3 -ATWT / Criticality SS3.1 SS3 1 S -System Malfunction, 2 -Loss of DC Power SS2.1 SS6 1 S -System Malfunction, 5 -Instrumentation SS5.1 SG1 1 S -System Malfunction, 1 -Loss of AC Power SG1.1 SG2 1 S -System Malfunction, 3 -ATWT / Criticality SG3.1 11 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Matrix OSSI -SGS NEI 99-01 SGS Barrier Threshold EAL FC Loss 1 FB1-L FC Loss 2 FB4-L FC Loss 3 FB2-L FC Loss 6 FB3-L FC Loss 8 FB5-L FB1-P FC P-Loss 1 FB2-P FB32-P FC P-Loss 3 FB3-P FC P-Loss 4 FB4-P FC P-Loss 8 FB5-P RCS Loss 2 RB32-L RCS Loss 4 RB3-L RCS Loss 6 RB1-L RCS Loss 8 RB4-L RB1-P RCS P-Loss 1 RB2-P RB2-P RCS P-Loss 2 RB3-P RCS P-Loss 8 RB4-P CNTMT Loss 2 C1-CB2-L CB3-L CNTMT Loss 4 CB4-L CB4-L CNTMT Loss 5 CB5-L CNTMT Loss 8 CB6-L CNTMT P-Loss 1 CB1-P CB6-P CNTMT P-Loss 2 CR7-P CB8-P CR3-P CNTMT P-Loss 3 CR4-P CB4-P CNTMT P-Loss 6 CR5-P CNTMT P-Loss 7 CB2-P CNTMT P-Loss 8 CB9-P 12 of 144 EAL Comparison Matrix OSSI -SGS Table 3 -Summary of Deviations NEI SGS NEIAL Description IC Example EAL EAL HU2 1 HU2.1 The generic bases for HU2 example EAL #1 has been revised to clarify when the 15 minute classification time begins (what constitutes a credible notification/report of a fire). For events where only a single fire or smoke detector has alarmed, the 15 minute clock starts once on/near-scene visual confirmation is received.13 of 144 EAL Comparison Matrix OSSI -SGS Table 4 -Defined Terms NEI Term and Definition SGS Term and Definition Difference/Deviation Justification AFFECTING SAFE SHUTDOWN:

Event in None The NEI term and definition have been deleted because they progress has adversely affected functions that are no longer used in NEI 99-01 and is not used in the are necessary to bring the plant to and Salem EALs.maintain it in the applicable HOT or COLD SHUTDOWN condition.

Plant condition applicability is determined by Technical Specification LCOs in effect.Example 1: Event causes damage that results in entry into an LCO that requires the plant to be placed in HOT SHUTDOWN.

HOT SHUTDOWN is achievable, but COLD SHUTDOWN is not. This event is not"AFFECTING SAFE SHUTDOWN." Example 2: Event causes damage that results in entry into an LCO that requires the plant to be placed in COLD SHUTDOWN.

HOT SHUTDOWN is achievable, but COLD SHUTDOWN is not. This event is"AFFECTING SAFE SHUTDOWN." BOMB: Refers to an explosive device BOMB: Refers to an explosive device suspected None suspected of having sufficient force to of having sufficient force to damage plant systems damage plant systems or structures.

or structures.

CIVIL DISTURBANCE:

A group of persons CIVIL DISTURBANCE:

A group of persons None violently protesting station operations or violently protesting station operations or activities activities at the site. at the site.CONFINEMENT BOUNDARY:

The barrier(s)

CONFINEMENT BOUNDARY:

is the barrier(s)

The term "is" has been added to the beginning of the SGS between areas containing radioactive between areas containing radioactive substances definition for clarity.substances and the environment, and the environment and includes the multi- The phrase "and includes the multi-purpose canister (MPC)purpose canister (MPC) and, for the purposes of and, for the purposes of this EAL, the associated cask 14 of 144 EAL Comparison Matrix OSSI -SGS NEI Term and Definition SGS Term and Definition Difference/Deviation Justification this EAL, the associated cask shielding.

shielding" was added to better define the term "barrier(s) used in the definition.

CONTAINMENT CLOSURE: The site specific CONTAINMENT CLOSURE: Is the Salem The NEI phrase "...site specific..." has been replaced with procedurally defined actions taken to secure procedurally defined action taken to secure the sentence "CONTAINMENT CLOSURE status is checked containment (primary or secondary for BWR) containment and its associated structures, and verified using S1(S2).OP-AB.CONT-0001(Q)" to specify and its associated structures, systems, and systems, and components as a functional barrier the document in which the procedurally defined actions can components as a functional barrier to fission to fission product release under existing plant be found.product release under existing plant conditions.

CONTAINMENT CLOSURE status is condtios.

heced nd eriied sin S152)OP-B.CNT-The term "Is" has been added to the beginning of the SGS conditions0 checked and verified using SI(S2).OP-AB.CONT-definition for clarity.0001(Q)EXPLOSION:

A rapid, violent, unconfined EXPLOSION:

A rapid, violent, unconfined None combustion, or catastrophic failure of combustion, or catastrophic failure of pressurized/energized equipment that imparts pressurized/energized equipment that imparts energy of sufficient force to potentially energy of sufficient force to potentially damage damage permanent structures, systems, or permanent structures, systems, or components.

components.

EXTORTION:

An attempt to cause an action None The NEI term and definition have been deleted because they at the station by threat of force. are no longer used in NEI 99-01 and is not used in the Salem EALs.FAULTED: (PWRs) in a steam generator, the FAULTED: (PWRs) in a steam generator, the None existence of secondary side leakage that existence of secondary side leakage that results in results in an uncontrolled drop in steam an uncontrolled drop in steam generator pressure generator pressure or the steam generator or the steam generator being completely being completely depressurized.

depressurized.

FIRE: Combustion characterized by heat and FIRE: Combustion characterized by heat and light. None light. Sources of smoke such as slipping drive Sources of smoke such as slipping drive belts or belts or overheated electrical equipment do overheated electrical equipment do not constitute not constitute FIRES. Observation of flame is FIRES. Observation of flame is preferred but is preferred but is NOT required if large NOT required if large quantities of smoke and quantities of smoke and heat are observed, heat are observed.HOSTAGE: A person(s) held as leverage HOSTAGE: A person(s) held as leverage against None against the station to ensure that demands the station to ensure that demands will be met by 15 of 144 EAL Comparison Matrix OSSI -SGS NEI Term and Definition SGS Term and Definition Difference/Deviation Justification will be met by the station. the station.HOSTILE ACTION: An act toward a NPP or HOSTILE ACTION: An act toward Salem or Hope The NEI terms "NPP" and "licensee" have been replaced its personnel that includes the use of violent Creek or its personnel that includes the use of with "Salem or Hope Creek" and "PSEG" to identify the force to destroy equipment, take HOSTAGES, violent force to destroy equipment, take specific entities to which the terms apply.and/or intimidate the licensee to achieve an HOSTAGES, and/or intimidate PSEG to achieve The NEI phrase "owner controlled area" has been changed end. This includes attack by air, land, or water an end. This includes attack by air, land, or water to "OCA" for simplification.

OCA is the approved acronym for using guns, explosives, PROJECTILEs, using guns, explosives, PROJECTILEs, vehicles, owner controlled area.vehicles, or other devices used to deliver or other devices used to deliver destructive force.destructive force. Other acts that satisfy the Other acts that satisfy the overall intent may be overall intent may be included.

HOSTILE included.

HOSTILE ACTION should not be ACTION should not be construed to include construed to include acts of civil disobedience or acts of civil disobedience or felonious acts felonious acts that are not part of a concerted that are not part of a concerted attack on the attack on Salem or Hope Creek. Non-terrorism-NPP. Non-terrorism-based EALs should be based EALs should be used to address such used to address such activities (i.e., this may activities (i.e., this may include violent acts include violent acts between individuals in the between individuals in the OCA).owner controlled area).HOSTILE FORCE: One or more individuals HOSTILE FORCE: One or more individuals who None who are engaged in a determined assault, are engaged in a determined assault, overtly or by overtly or by stealth and deception, equipped stealth and deception, equipped with suitable with suitable weapons capable of killing, weapons capable of killing, maiming, or causing maiming, or causing destruction.

destruction.

IMMINENT:

Mitigation actions have been IMMINENT:

Mitigation actions have been The NEI sentence "Where IMMINENT timeframes are ineffective, additional actions are not ineffective, additional actions are not expected to specified, they shall apply" has been replaced with the expected to be successful, and trended be successful, and trended information indicates phrase "...within approximately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (unless a different information indicates that the event or that the event or condition will occur within time is specified)" to provide a reasonable estimate of the condition will occur. Where IMMINENT approximately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (unless a different time is duration over which trended information should be timeframes are specified, they shall apply. specified).

forecasted.

This is a clarification of the NEI 99-01 definition and is consistent with previous training provided to Emergency Coordinators at Salem.to maintain the same specific time frame used in previously approved NUMARC EALs which is consistent with NE199-01, Rev. 4 definition on page 5-F-1 and is consistent with the previous training provided to Emergency Coordinators at 16 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS NEI Term and Definition SGS Term and Definition Difference/Deviation Justification Salem.INTRUSION:

A person(s) present in a specified area without authorization.

Discovery of a BOMB in a specified area is indication of INTRUSION into that area by a HOSTILE FORCE.None The NEI term and definition have been deleted because they are no longer used in NEI 99-01 and is not used in the Salem EALs.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.None NORMAL PLANT OPERATIONS:

Activities at NORMAL PLANT OPERATIONS:

Activities at the None the plant site associated with routine testing, plant site associated with routine testing, maintenance, or equipment operations, in maintenance, or equipment operations, in accordance with normal operating or accordance with normal operating or administrative procedures.

Entry into administrative procedures.

Entry into abnormal or abnormal or emergency operating emergency operating procedures, or deviation procedures, or deviation from normal security from normal security or radiological controls or radiological controls posture, is a departure posture, is a departure from NORMAL PLANT from NORMAL PLANT OPERATIONS.

OPERATIONS.

PROJECTILE:

An object directed toward a PROJECTILE:

An object that impacts Salem The NEI phrase "An object directed toward..." has been NPP that could cause concern for its and/or Hope Creek that could cause concern for changed to "An object that impacts..." because continued operability, reliability, or personnel continued operability, reliability, or personnel PROJECTILES can be the result of an event that was not safety. safety. "directed" at the station but still "impacted the station. For Example, if a ship, plane, vehicle, etc. were to explode near the station a PROJECTILE could impact the stations but it was not "directed" at the station.The NEI "NPP" is "Salem and/or Hope Creek" stations.The NEI phrase "...for its continued operability..." has been changed to "...for continued operability..." to make the sentence flow better.17 of 144 EAL Comparison Matrix OSSI- SOS EAL Comparison Matrix OSSI -SGS PROTECTED AREA: Typically the site specific area which normally encompasses all controlled areas within the security PROTECTED AREA fence.PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center.The NEI "site specific area" at SGS is defined by the phrase"A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems." The NEI phrase "...encompasses all controlled areas within the.. .fence" has been deleted because the above description of "site specific area" provides a more detailed definition that plant operators can better relate to.The sentence "Access to the PA requires proper security clearance and is controlled at the Security Center" is added clarification the plant operators can better relate to.RUPTURED: (PWRs) in a steam generator, RUPTURED:

in a steam generator, existence of None existence of primary-to-secondary leakage of primary-to-secondary leakage of a magnitude a magnitude sufficient to require or cause a sufficient to require or cause a reactor trip and reactor trip and safety injection, safety injection.

SABOTAGE:

Deliberate damage, mis- SABOTAGE:

Deliberate damage, mis-alignment, None alignment, or mis-operation of plant or mis-operation of plant equipment with the intent equipment with the intent to render the to render the equipment inoperable.

Equipment equipment inoperable.

Equipment found found tampered with or damaged due to malicious tampered with or damaged due to malicious mischief may not meet the definition of mischief may not meet the definition of SABOTAGE until this determination is made by SABOTAGE until this determination is made security supervision.

by security supervision.

SECURITY CONDITION:

Any Security Event SECURITY CONDITION:

ANY Security Event as None as listed in the approved security contingency listed in the approved security contingency plan plan that constitutes a threat/compromise to that constitutes a threat/compromise to site site security, threat/risk to site personnel, or a security, threat/risk to site personnel, or a potential potential degradation to the level of safety of degradation to the level of safety of the plant. A the plant. A SECURITY CONDITION does not SECURITY CONDITION does not involve a involve a HOSTILE ACTION. HOSTILE ACTION.SIGNIFICANT TRANSIENT:

An SIGNIFICANT TRANSIENT:

An UNPLANNED The NEI phrase "...event involving one or more of the UNPLANNED event involving one or more of event based on EC judgment, but includes as a following..." has been changed to "...event based on EC 18 of 144 EAL Comparison Matrix OSSI -SGS the following:

(1) automatic turbine runback minimum any one of the following:

(1) automatic judgment, but includes as a minimum any one of the greater than 25% thermal reactor power, (2) turbine runback greater than 25% thermal reactor following..." to allow for EC judgment in determining if a electrical load rejection greater than 25% full power, (2) electrical load rejection greater than SIGNIFICANT TRANSIENT has occurred.

At times a electrical load, (3) Reactor Trip, (4) Safety 25% full electrical load, (3) Reactor Trip, or (4) number of minor events that occur at the same time could Injection Activation, or (5) thermal power Safety Injection Activation.

result in conditions equal to a SIGNIFICANT TRANSIENT.

oscillations greater than 10%. The NEI phrase "(5) thermal power oscillations greater than 10%' has been deleted because PWRs are not susceptible to thermal power oscillations greater than 10%.STRIKE ACTION: A work stoppage within the None The NEI term and definition have been deleted because they PROTECTED AREA by a body of workers to are no longer used in NEI 99-01 and is not used in the enforce compliance with demands made on Salem EALs.(site specific).

The STRIKE ACTION must threaten to interrupt NORMAL PLANT OPERATIONS.

UNISOLABLE:

A breach or leak that cannot UNISOLABLE:

A breach or leak that cannot be The phrase "from the Control Room" has been added to the be promptly isolated.

promptly isolated from the Control Room. SGS definition to emphasize the meaning of "promptly." In accordance with NEI basis discussion of example EALs using the term "UNISOLABLE," prompt isolation attempts include automatic isolation and manual action in the Control Room to close isolation valves.UNPLANNED:

A parameter change or an UNPLANNED:

A parameter change or an event None event that is not the result of an intended that is not the result of an intended evolution and evolution and requires corrective or mitigative requires corrective or mitigative actions.actions.VALID: An indication, report, or condition, is VALID: An indication, report, or condition, is None considered to be VALID when it is verified by considered to be VALID when it is verified by (1)(1) an instrument channel check, (2) an instrument channel check, (2) indications on indications on related or redundant indicators, related or redundant indicators, or (3) by direct or (3) by direct observation by plant observation by plant personnel, such that doubt personnel, such that doubt related to the related to the indicator's operability, the indicator's operability, the condition's condition's existence, or the report's accuracy is existence, or the report's accuracy is removed. Implicit in this definition is the need for removed. Implicit in this definition is the need timely assessment.

for timely assessment.

19 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS VISIBLE DAMAGE: Damage to equipment or VISIBLE DAMAGE: Damage to equipment or None structure that is readily observable without structure that is readily observable without measurements, testing, or analysis.

Damage measurements, testing, or analysis.

Damage is is sufficient to cause concern regarding the sufficient to cause concern regarding the continued operability or reliability of the continued operability or reliability of the affected affected structure, system, or component.

structure, system, or component.

Example Example damage includes:

deformation due damage includes:

deformation due to heat or to heat or impact, denting, penetration, impact, denting, penetration, rupture, cracking, rupture, cracking, and paint blistering.

Surface and paint blistering.

Surface blemishes (e.g., paint blemishes (e.g., paint chipping, scratches) chipping, scratches) should not be included.should not be included.VITAL AREAS: Typically any site specific VITAL AREAS: Typically any site specific areas, None areas, normally within the PROTECTED normally within the PROTECTED AREA, that AREA, that contains equipment, systems, contains equipment, systems, components, or components, or material, the failure, material, the failure, destruction, or release of destruction, or release of which could directly which could directly or indirectly endanger the or indirectly endanger the public health and public health and safety by exposure to radiation.

safety by exposure to radiation.

20 of 144 EAL Comparison Matrix OSSi-SGS EAL Comparison Matrix OSSI -SGS Category R Abnormal Rad Levels / Rad Effluent 21 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording and Mode SGS SGS IC Wording and Mode Difference/Deviation Justification Applicability IC#(s) Applicability AU1 Any release of gaseous or liquid RU1 Any release of gaseous or liquid Deleted reference to RETS. ODCM limits provide the SGS radioactivity to the environment radioactivity to the environment site-specific Radiological Effluent Technical Specifications.

greater than 2 times the greater than 2 times the ODCM for 60 Radiological Effluent Technical minutes or longer Specifications/ODCM for 60 MODE: All minutes or longer.MODE: All NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #1 VALID reading on ANY of the RU1.1 VALID gaseous monitor reading > Gaseous release is emphasized in this EAL to be consistent following radiation monitors Table R-1 column "UE" with the NEI basis, which states "Some sites may find it greater than the reading shown AND advantageous to address gaseous and liquid releases with for 60 minutes or longer: separate initiating conditions and EALs." (site specific monitor list and _> 60 minutes have elapsed (Note 2) The NEI phrase "VALID reading on ANY of the following threshold values) Note 2: The Emergency Coordinator radiation monitors greater than the reading shown ..." has Note: The Emergency Director should NOT wait until the been replaced with "VALID gaseous monitor reading > Table should not wait until the applicable time has elapsed, R-1 column "UE"..." applicable time has elapsed, but but should declare the event .The SGS radiation monitors that detect radioactivity should declare the event as soon as soon as it is determined effluent release to the environment are listed in Table as it is determined that the that the release duration has R-1.release duration has exceeded, exceeded, or will likely or will likely exceed, the exceed, the applicable time. In ciUE, Alert, SAE and GE thresholds for all SGS applicable time. In the absence of the absence of data to the continuously monitored gaseous release pathways are data to the contrary, assume that contrary, assume that the listed in Table R-1 to consolidate the information in a the release duration has release duration has single location and, thereby, simplify identification of exceeded the applicable time if exceeded the applicable time the thresholds by the EAL user.an ongoing release is detected if an ongoing release is The values shown in Table R-1 column "UE", and the release start time is detected and the release start consistent with the NEI bases, represent two times the unknown. time is unknown. ODCM release limits for both liquid and gaseous release. The alarm setpoints for both liquid and gaseous effluent monitors are conservatively set to 22 of 144 EAL Comparison Matrix OSSI -SGS NEI Ex. NEI Example EAL Wording SGS ] SGS EAL Wording Difference/Deviation Justification

[EAL # ~___________EAL

_________________________________

ensure the ODCM release limits are not exceeded.An asterisk note "For high radiation conditions on Letdown Line Monitor 1R31A (2R31), refer to EAL SU7.1" has been added to Table R-1. A Letdown Line radiation monitor alarm is an abnormal radiological condition and can be reasonably associated with Category R EALs. It is placed in the System Malfunction category to conform to NEI 99-01 guidance, however. The note helps direct the EAL user to the EAL applicable to abnormal letdown line radiation.

+ 4 4 4 2 VALID reading on any effluent monitor reading greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.RU1.2 ANY VALID liquid monitor reading >Table R-1 column "UE" AND_> 60 minutes have elapsed (Note 2)Note 2: 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 release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.Liquid release is emphasized in this EAL to be consistent with the NEI basis, which states "Some sites may find it advantageous to address gaseous and liquid releases with separate initiating conditions and EALs." The NEI phrase "VALID reading on any effluent monitor reading greater than 2 times the alarm setpoint established by a current radioactivity discharge permit ..." has been replaced with "ANY VALID liquid monitor reading > Table R-I column "UE"...." The SGS radiation monitors that detect radioactivity effluent release to the environment are listed in Table R-1. UE, Alert, SAE and GE thresholds for all SGS continuously monitored release pathways are listed in Table R-1 to consolidate the information in a single location and, thereby, simplify identification of the thresholds by the EAL user.The values shown in Table R-1 column "UE", consistent with the NEI bases, represent two times the ODCM release limits for both liquid and gaseous release. The alarm setpoints for both liquid and gaseous effluent monitors are conservatively set to ensure the ODCM release limits are not exceeded.3 Confirmed sample analyses for RU1.3 Confirmed sample analyses for The NEI phrase "greater than 2 times (site specific RETS gaseous or liquid releases gaseous or liquid releases indicate values)" has been changed to "> Table R-2 column "UE"..." indicates concentrations or concentrations or release rates > The values shown in Table R-2 column "ULE", consistent with release rates greater than 2 times Table R-2 column "UE" the NEI bases, represent 2 times ODCM 3/4.11.1/2 (site specific RETS values) for 60 23 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS NEI Ex. SGS EAL # NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification minutes or longer. AND concentrations.

Note: The Emergency Director _> 60 minutes have elapsed (Note 2)should not wait until the applicable time has elapsed, but Note 2: The Emergency Coordinator applcabl tim ha elasedbutshould NOT wait until the should declare the event as soon should ti lathe as it is determined that the applicable time has elapsed, release duration has exceeded, but should declare the event or will likely exceed, the as soon as it is determined applicable time. In the absence of that the release duration has data to the contrary, assume that exceeded, or will likely the release duration has exceed, the applicable time. In exceeded the applicable time if the absence of data to the an ongoing release is detected contrary, assume that the and the release start time is release duration has unknown, exceeded the applicable time if an ongoing release is detected and the release start time is unknown.4 VALID reading on perimeter N/A N/A Deleted NEI Example EAL #4 because the plant is not radiation monitoring system equipped with a perimeter radiation monitoring system. This greater than 0.10 mR/hr above threshold is properly addressed by the radiation monitors normal* background sustained for listed in Table R-1 and dose assessment capabilities.

60 minutes or longer [for sites having telemetered perimeter monitors]* Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.5 VALID indication on automatic N/A N/A Deleted NEI Example EAL #5 because the plant is not real-time dose assessment equipped with real-time dose assessment.

This threshold is capability greater than (site- properly addressed by the radiation monitors listed in Table specific value) for 60 minutes or R-1 and dose assessment capabilities.

longer [for sites having such 24 of 144 EAL Comparison Matrix 0551 -SGS EAL Comparison Matrix OSSI -SGS NEI Ex NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification EAL # A#capability]

Table R-1 Effluent Monitor Classification Thresholds*

Release Point Monitor GE SAE ALERT UE Plant Vent 1 R41D + 2R41D o Effluent Noble O__RR o) Efun NoblenOR 8.48E+09 pCi/sec 8.48E+08 pCi/sec 4.84E+07 pCi/sec 4.84E+05 pCi/sec Gas SPDS combined Unit 1 + Unit 2 release rate Containment Fan Coil 1(2)R13A/B 1.64E+05 cpm 1.64E+03 cpm Process Liquid 1R18 U1= 5.50E+05 cpm Radwaste N/A:g Disposal See EAL RA1.3= Process 2R18 U2= 9.90E+05 cpm" Steam 1R19A-D U1-= 6.40E+05 cpm U1= 6.40E+03 cpm Generator Blowdown Process 2R1 9A-D U2= 8.30E+05 cpm U2= 8.30E+03 cpm Non-Rad Liquid 2R37 ---- 3.60E+05 cpm 3.60E+03 cpm Waste* For high radiation conditions on Letdown Line Monitor 1R31A (2R31), refer to EAL SU7.1 25 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Matrix OSSI -SGS Table R-2 Effluent Sample Classification Thresholds Release Point Sample ALERT UE NG 6.40E-01 pCi/cc 6.40E-03 pCi/cc Plant Vent 0 1-131 5.60E-05 pCi/cc 5.60E-07 pCi/cc Unmonitored Isotopic 200 x ODCM 3/4.11.2 2 x ODCM 3/4.11.2 Containment Fan Coil Isotopic 200 x ODCM 3/4.11.1 2 x ODCM 3/4.11.1 g Liquid Radwaste Disposal Isotopic 200 x ODCM 3/4.11.1 2 x ODCM 3/4.11.1 H Steam Generator Blowdown Isotopic 200 x ODCM 3/4.11.1 2 x ODCM 3/4.11.1-j Chemical Waste Basin Isotopic 200 x ODCM 3/4,11.1 2 x ODCM 3/4.11.1 Unmonitored Isotopic 200 x ODCM 3/4.11.1 2 x ODCM 3/4.11.1 26 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Malfix osst -SGS NEI IC# NEI IC Wording and Mode SGS SGS IC Wording and Mode Difference/Deviation Justification Applicability IC#(s) Applicability AU2 Unplanned rise in plant radiation RU2 UNPLANNED rise in plant radiation None levels levels MODE: All MODE: All NEI Ex. SGS EA E NEI Example EAL Wording EAL SGS EAL Wording Difference/Deviation Justification EAL # EAL #a. UNPLANNED water level RU2.1 UNPLANNED water level drop in the The NEI phrase "...a reactor refueling pathway as indicated by drop in a reactor refueling refueling cavity, refueling canal or (site specific level or indication)..." has been changed to "the pathway as indicated by (site spent fuel pool (SFP) as indicated by refueling cavity, refueling canal or spent fuel pool (SFP) as specific level or indication).

ANY of the following:

indicated by ANY of the following:

..." for clarification.

AND -Confirmed SFP low level alarm The listed low water level indications and alarm are the site-b. VALID Area Radiation (OHA-C35 SFP LVL LO) specific thresholds and refer to the spent fuel pool and Monitor reading rise on (site -RVLIS -Refueling Mode refueling cavity as explained in the basis for the EAL.-specific list). The "site-specific" monitors are those located on the 130' ele.* Visual observation (local or of either the Containment or FHB because radiation levels in remote) these areas are likely to be affected by the loss of inventory AND from the refueling cavity, spent fuel pool and fuel transfer canal.VALID area radiation monitor reading rise on ANY of the following:

1(2)R5 Fuel Handling Bldg* 1(2)R9 Fuel Storage Area* 1(2)R32A Fuel Handling Crane Fuel Handling Bldg (local monitor)* 1(2)R2 Containment

Temporary ARM 2 UNPLANNED VALID Area RU2.2 UNPLANNED VALID area radiation The term "indicate a..." has been deleted for proper English.Radiation Monitor readings or monitor readings or survey results rise 27 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS survey results indicate a rise by by a factor of 1,000 over normal levels The NEI asterisks and note have been changed to Note 7.a factor of 1000 over normal* (Note 7) Numbering this information facilitates referencing in the EAL levels. Note 7: Normal levels can be matrix.*Normal levels can be considered as the considered as the highest The NEI term "twenty-four" has been replaced with Arabic highest reading in the past twenty-four reading in the past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months numerals for clarification.

hours excluding the current peak value. e c u i g t e c r e tp a excluding the current peak value 28 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording lC#(s) SGS IC Wording Difference/Deviation Justification AA1 Any release of gaseous or liquid RA1 Any release of gaseous or liquid Deleted reference to RETS. ODCM limits provide the SGS radioactivity to the environment radioactivity to the environment site-specific Radiological Effluent Technical Specifications.

greater than 200 times the greater than 200 times the ODCM for Radiological Effluent Technical 15 minutes or longer Specifications/ODCM for 15 minutes or longer. MODE: All MODE: All NEI Ex. NEI Example EAL Wording EALSGS SGS EAL Wording Difference/Deviation Justification 1 VALID reading on ANY of the RA1.1 VALID gaseous monitor reading > Gaseous release is emphasized in this EAL to be consistent following radiation monitors Table R-1 column "ALERT" with the NEI basis, which states "'Some sites may find it greater than the reading shown AND advantageous to address gaseous and liquid releases with for 15 minutes or longer: separate initiating conditions and EALs." (site specific monitor list and _ 15 minutes have elapsed (Note 2) The NEI phrase "VALID reading on ANY of the following threshold values) Note 2: The Emergency Coordinator radiation monitors greater than the reading shown ..." has Note: The Emergency Director should NOT wait until the been replaced with "VALID gaseous monitor reading > Table should not wait until the applicable time has elapsed, R-1 column "ALERT"..." applicable time has elapsed, but but should declare the event 0 The SGS radiation monitors that detect radioactivity should declare the event as soon as soon as it is determined effluent release to the environment are listed in Table R-as it is determined that the that the release duration has 1.release duration has exceeded, exceeded, or will likely or will likely exceed, the exceed, the applicable time. In ciUE, Alert, SAE and GE thresholds for all SGS applicable time. In the absence of the absence of data to the continuously monitored gaseous release pathways are data to the contrary, assume that contrary, assume that the listed in Table R-1 to consolidate the information in a the release duration has release duration has single location and, thereby, simplify identification of the exceeded the applicable time if exceeded the applicable time thresholds by the EAL-user.an ongoing release is detected if an ongoing release is The values shown in Table R-1 column "Alert", and the release start time is detected and the release start consistent with the NEI bases, represent two hundred unknown. time is unknown. times the ODCM release limits for both liquid and gaseous release. The alarm setpoints for both liquid and gaseous effluent monitors are conservatively set to 29 of 144 EAL Comparison Matrix OSSI -SGS ensure the ODCM release limits are not exceeded.2 VALID reading on any effluent RA1.2 ANY VALID liquid monitor reading > The NEI phrase "VALID reading on any effluent monitor monitor reading greater than 200 Table R-1 column "ALERT" reading greater than 200 times the alarm setpoint established times the alarm setpoint by a current radioactivity discharge permit ..." has been established by a current AND replaced with "ANY VALID liquid monitor reading > Table R-1 radioactivity discharge permit for _ 15 minutes have elapsed (Note 2) column "ALERT" ..." 15 minutes or longer. Note 2: The Emergency Coordinator Liquid release is emphasized in this EAL to be consistent with Note: The Emergency Director should NOT wait until the the NEI basis, which states "Some sites may find it should not wait until the applicable time has elapsed, advantageous to address gaseous and liquid releases with applicable time has elapsed, but but should declare the event separate initiating conditions and EALs." should declare the event as soon as soon as it is determined The SGS radiation monitors that detect radioactivity effluent as it is determined that the that the release duration has release to the environment are listed in Table R-1. UE, Alert, release duration has exceeded, exceeded, or will likely SAE and GE thresholds for all SGS continuously monitored or will likely exceed, the exceed, the applicable time. In release pathways are listed in Table R-1 to consolidate the applicable time. In the absence of the absence of data to the information in a single location and, thereby, simplify data to the contrary, assume that contrary, assume that the identification of the thresholds by the EAL user.the release duration has release duration has exceeded the applicable time if exceeded the applicable time The values shown in Table R-1 column "Alert", consistent with an ongoing release is detected if an ongoing release is the NEI bases, represent two hundred times the ODCM and the release start time is detected and the release start release limits for both liquid and gaseous release. The alarm unknown. time is unknown. setpoints for both liquid and gaseous effluent monitors are conservatively set to ensure the ODCM release limits are not exceeded.3 Confirmed sample analyses for RA1.3 Confirmed sample analyses for The NEI phrase "greater than 200 times (site specific RETS gaseous or liquid releases gaseous or liquid releases indicate values)" has been changed to "> Table R-2 column indicates concentrations or concentrations or release rates > "ALERT"..." release rates greater than 200 Table R-2 column "ALERT" The values shown in Table R-2 column "ALERT", consistent times (site specific RETS values) AND with the NEI bases, represent 200 times ODCM 3/4.11.1/2 for 15 minutes or longer. concentrations.

Note: The Emergency Director > 15 minutes have elapsed (Note 2)should not wait until the Note 2: The Emergency Coordinator applicable time has elapsed, but should NOT wait until the should declare the event as soon applicable time has elapsed, as it is determined that the but should declare the event release duration has exceeded, as soon as it is determined or will likely exceed, the that the release duration has applicable time. In the absence of exceeded, or will likely data to the contrary, assume that 30 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS the release duration has exceed, the applicable time. In exceeded the applicable time if the absence of data to the an ongoing release is detected contrary, assume that the and the release start time is release duration has unknown. exceeded the applicable time if an ongoing release is detected and the release start time is unknown.4 VALID reading on perimeter radiation monitoring system reading greater than 10.0 mR/hr above normal* background for 15 minutes or longer. [for sites having telemetered perimeter monitors]* Normal can be considered as the highest reading in the past twenty-four hours excluding the current peak value.N/A N/A Deleted NEI Example EAL #4 because the plant is not equipped with a perimeter radiation monitoring system. This threshold is properly addressed by the radiation monitors listed in Table R-1 and dose assessment capabilities.

VALID indication on automatic N/A N/A Deleted NEI Example EALs #5 because the plant is not real-time dose assessment equipped with and real-time dose assessment.

This threshold capability indicating greater than is properly addressed by the radiation monitors listed in Table (site specific value) for 15 R-1 and dose assessment capabilities.

minutes or longer. [for sites having such capability]

31 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification AA2 Damage to irradiated fuel or RA2 Damage to irradiated fuel or loss of None loss of water level that has water level that has or will resulted in resulted or will result in the the uncovering of irradiated fuel outside uncovering of irradiated fuel the Reactor Vessel outside the reactor vessel. MODE: All MODE: All NEI Ex.SGS NEI Ex. NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification 1 A water level drop in the reactor RA2.2 A water level drop in the refueling None refueling cavity, spent fuel pool cavity, spent fuel pool or refueling or fuel transfer canal that will canal that will result in irradiated fuel result in irradiated fuel becoming becoming uncovered uncovered.

2 A VALID alarm or (site specific RA2.1 Damage to irradiated fuel or loss of Reordered the wording of the EAL to clarify that the increased elevated reading) on ANY of the water level (uncovering irradiated fuel radiation levels are the result of damage or uncovering of following due to damage to outside the Reactor Vessel) that irradiated fuel.irradiated fuel or loss of water causes a VALID high alarm on ANY of Incorporated the IC wording to clarify that the EAL threshold is level. the following radiation monitors:

based on uncovering irradiated fuel outside the Reactor (site specific radiation monitors)

Fuel Handlinq Bldgq Vessel." 1(2)R5 Fuel Handling Bldg The NEI phrase "VALID alarm" has been changed to "VALID high alarm" because it is the high alarm signal associated with* 1(2)R9 Fuel Storage Area the listed radiation monitors that warns of elevated radiation" 1(2)R32A Fuel Handling Crane levels anticipated if spent fuel were to become uncovered.

Fuel Handling Bldg (local monitor) The listed radiation monitors represent the site-specific" 1(2)R41A Plant Vent equivalents.

Containment

1(2)R2 Containment 32 of 144 EAL Comparison Matrix OSSI -SGS" 1(2)R1 1 A Containment Air -Particulate

1(2)R1 2A Containment Vent -Noble Gas* 1(2)R1 2B Containment Vent -Iodine 33 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s) SSI odn AA3 Rise in radiation levels within the RA3 Rise in radiation levels within the None facility that impedes operation of facility that impedes operation of systems required to maintain systems required to maintain plant plant safety functions.

safety functions MODE: All MODE: All NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #1 Dose rate greater than 15 mRlhr RA3.1 Dose rates > 15 mR/hr in EITHER of The phrase "Control Room (1(2)R1A)...Central Alarm in ANY of the following areas the following:

Station..." has been added to the plant EAL to clarify the requiring continuous occupancy meaning of areas requiring continuous occupancy.

These to maintain plant safety

Control Room (1(2)RIA) areas are specifically identified in the NEI IC AA3 basis functions:

Central Alarm Station discussion.

The SGS Rad Waste Control Room is not required to be continuously occupied in order to maintain plant safety (site specific area list) functions.

ARM 1(2)RIA monitors area radiation level in the Control Room. The Central Alarm Station does not have permanently installed radiation monitoring.

34 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s) SSI odn AS1 Off-site dose resulting from an RS1 Offsite dose resulting from an actual or None actual or IMMINENT release of imminent release of gaseous gaseous radioactivity greater radioactivity greater than 100 m Rem than 100 mrem TEDE or 500 TEDE or 500 mRem thyroid CDE for mrem Thyroid CDE for the actual the actual or projected duration of the or projected duration of the release release. MODE: All MODE: All NEl Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #1 VALID reading on ANY of the RS1.1 VALID gaseous monitor reading > The NEI phrase "VALID reading on ANY of the following following radiation monitors Table R-1 column "SAE" radiation monitors greater than the reading shown ..." has greater than the reading shown AND been replaced with "VALID gaseous monitor reading > Table for 15 minutes or longer: R-1 column "SAE"..." (site-specific list) Dose assessment results are NOT .The SGS radiation monitors that detect radioactivity available effluent release to the environment are listed in Table R-The Emergency Director should not wait until the applicable time AND 1.has elapsed, but should declare > 15 minutes have elapsed (Note 1)

UE, Alert, SAE and GE thresholds for all SGS the event as soon as it is continuously monitored gaseous release pathways are determined that the condition will Note 1: If dose assessment results listed in Table R-1 to consolidate the information in a likely exceed the applicable time. are available, declaration single location and, thereby, simplify identification of the If dose assessment results are should be based on dose thresholds by the EAL-user.available, declaration should be assessment (EAL RS1.2)based on dose assessment instead of gaseous monitor

The values shown in Table R-1 column "SAE" instead of radiation monitor values. Do NOT delay consistent with the NEI bases, represent 10% of the values. Do not delay declaration declaration awaiting dose EPA PAG for gaseous release.awaiting dose assessment assessment results. The condition "AND Dose assessment results are NOT results. The Emergency Coordinator available" has been added to the plant EAL to emphasize the should NOT wait until the importance dose assessment results and use of this EAL.applicable time has elapsed, The first and second sentences of the note have been but should declare the event reversed and "(EAL RS1.2)" has been added to the note to 35 of 144 EAL Comparison Matrix OSSI -SGS as soon as it is determined that the condition will likely exceed the applicable time.emphasize the importance of dose assessment results.I + F i 2 Dose assessment using actual meteorology indicates doses greater than 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the site boundary.RS1.2 Dose assessment using actual meteorology indicates TEDE 4-day dose > 4.OE+02 mRem or Thyroid CDE dose > 2.OE+03 mRem at or beyond the MINIMUM EXCLUSION AREA (MEA)The NEI phrase "doses greater than 100 mrem TEDE or 500 mrem thyroid CDE" has been changed to "TEDE 4-day dose >4.OE+02 mRem or Thyroid CDE dose > 2.OE+03 mRem" because the TEDE 4-day dose (output of PSEG dose assessment model -MIDAS) assumes a 4 hr release duration.

To obtain the approximate dose for a projected release condition of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the TEDE 4-day dose value would need to be divided by 4. A TEDE 4-Day Dose > 4.OE+02 mRem correspond directly to a TEDE dose rate value of 100 m Rem/hr and exceeds 10% of the EPA Protective Actions Guides (PAGs). The Thyroid-CDE Dose > 2.OE+03 mRem correspond directly to an CDE dose rate value of 500 mRem/hr and exceeds 10% of the EPA Protective Actions Guides (PAGs) which was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.The NEI phrase "site boundary" has been replaced with"MINIMUM EXCLUSION AREA (MEA)." The MEA is the boundary used in the MIDAS dose assessment program that most closely approximates the site boundary.

For Salem the MEA is 0.79 miles.3 VALID perimeter radiation N/A N/A Deleted NEI Example EAL #3 because the plant is not monitoring system reading equipped with a perimeter radiation monitoring system. This greater than 100 mR/hr for 15 threshold is properly addressed by the radiation monitors minutes or longer. [for sites listed in Table R-1 and dose assessment capabilities.

having telemetered perimeter monitors]4 Field survey results indicate RS1.3 Field survey results indicate closed Split the example into two logical conditions separated by the closed window dose rates window dose rates > 100 mRem/hr "OR" logical connector for usability.

greater than 100 mR/hr expected expected to continue for _> 1 hr at or The NEI abbreviation "R" has been replaced with the plant to continue for 60 minutes or beyond the PROTECTED AREA term "Rem" to agree with units of measure given in the EPA longer; or analyses of field BOUNDARY PAGs.survey samples indicate thyroid CDE greater than 500 mrem for OR The NEI phrase "one hour" has been abbreviated "1 hr" to 36 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix 031- SGS one hour of inhalation, at or beyond the site boundary.Analyses of field survey samples indicate 1-131 concentration

> 3.85E-07 jtCi/cc at or beyond the PROTECTED AREA BOUNDARY reduce EAL-user reading burden.The NEI phrase "thyroid CDE greater than 500 mrem for one hour of inhalation" has been changed to "1-131 concentration

>3.85E-07 giCi/cc" because the Iodine-131 field survey sample concentration and count rate threshold is based on 1-131 dose conversion factors (DCFs) from EPA-400. The thresholds are based on a Thyroid-CDE Dose Rate of 500 mRem/hr for I-131.The NEI phrase "site boundary" has been changed to "the PROTECTED AREA BOUNDARY" because it is an easily determined location to obtain a field survey dose rate reading or to obtain a field sample. The Salem/Hope Creek site is situated on Artificial Island, bordered by the Delaware River on one side and marshy wetlands on the other sides. The area between the Protected Area and the site boundary (defined by the Minimum Exclusionary Boundary) is primarily wetlands and the river, both of which would be inaccessible to offsite field survey teams. Onsite survey teams dispatched inside the Protected Area would likely be the first to detect adverse radiological conditions at or beyond the site boundary.NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IO#(s)AG1 Off-site dose resulting from an RG1 Offsite dose resulting from an Deleted the words "...using actual meteorology." The use of actual actual or IMMINENT release of actual or imminent release of meteorology is only applicable to example EAL #2. Example EAL #1 gaseous radioactivity greater gaseous radioactivity greater than is based on annual average meteorology.

This is consistent with IC than 1000 mrem TEDE or 5000 1,000 mRem TEDE or 5,000 AS1.mrem Thyroid CDE for the mRem thyroid CDE for the actual actual or projected duration of or projected duration of the the release using actual release meteorology.

MODE: All MODE: All NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification 37 of 144 EAL Comparison Matrix OSSI -SGS EAL # EAL #VALID reading on ANY of the RG1.1 VALID gaseous monitor reading > The NEI phrase "VALID reading on ANY of the following radiation following radiation monitors Table R-1 column "GE" monitors greater than the reading shown -.." has been replaced with greater than the reading shown AND "VALID gaseous monitor reading > Table R-1 column "GE" ..." for 15 minutes or longer:

The SGS radiation monitors that detect radioactivity effluent (site specific monitor list and Dose assessment results are NOT release to the environment are listed in Table R-1.threshold values) available t UE, Alert, SAE and GE thresholds for all SGS continuously The Emergency Director should AND monitored gaseous release pathways are listed in Table R-1 not wait until the applicable time >- 15 minutes have elapsed (Note to consolidate the information in a single location and, has elapsed, but should declare 1) thereby, simplify identification of the thresholds by the EAL-the event as soon as it is user.determined that the condition Note 1: If dose assessment will likely exceed the applicable results are available,

The values shown in Table R-1 column "GE", consistent time. If dose assessment results declaration should be with the NEI bases, represent 100% of the EPA PAG for are available, declaration should based on dose gaseous release.be based on dose assessment assessment (EAL RG1.2) The condition "AND Dose assessment results are NOT available" instead of radiation monitor instead of gaseous has been added to the plant EAL to emphasize the importance dose values. Do not delay declaration monitor values. Do NOT assessment results and use of this EAL.awaiting dose assessment delay declaration awaiting The first and second sentences of the note have been reversed and results. dose assessment results.'"(EAL RG1.2)" has been added to the note to emphasize the The Emergency importance of dose assessment results.Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.2 Dose assessment using actual RG1.2 Dose assessment using actual The NEI phrase "doses greater than 1000 mrem TEDE or 5000 meteorology indicates doses meteorology indicates TEDE 4-day mrem thyroid CDE" has been changed to "TEDE 4-day dose greater than 1000 m rem TEDE dose > 4.OE+03 mRem or Thyroid 4.OE+03 mRem or Thyroid CDE dose > 2.OE+04 mRem" because or 5000 mremn thyroid CDE at or CDE dose > 2.OE+O4 mRem at or the dose assessment output (from MIDAS) on the SSCL is reported beyond the site boundary.

beyond the MINIMUM at varying distances from the plant as a TEDE 4-Day dose. This EXCLUSION AREA (MEA) TEDE 4-day dose assumes a 4 hr release duration.

To obtain the 38 of 144 EAL Comparison Matrix OSSI -SGS approximate dose for a projected release condition of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the TEDE 4-day dose value would need to be divided by 4.A TEDE 4-Day Dose > 4.OE+03 mRem correspond directly to a TEDE dose rate value of 1000 mRem/hr and exceeds the EPA Protective Actions Guides (PAGs). The Thyroid-CDE Dose >2.OE+04 mRem correspond directly to an CDE dose rate value of 5000 mRem/hr and exceeds the EPA Protective Actions Guides (PAGs) which was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.The NEI phrase "site boundary" has been replaced with "MINIMUM EXCLUSION AREA (MEA)." The MEA is the boundary used in the MIDAS dose assessment program that most closely approximates the site are boundary.

For Salem the MEA is 0.79 miles.3 VA[iD-perimeter radiation N/A N/A Deleted NEI Example EAL #3 because the plant is not equipped monitoring system reading with a perimeter radiation monitoring system. This threshold is greater than 1000 mR/hr for 15 properly addressed by the radiation monitors listed in Table R-1 and minutes or longer. [for sites dose assessment capabilities.

having telemetered perimeter monitors]4 Field survey results indicate RG1.3 Field survey results indicate closed Split the example into two logical conditions separated by the "OR" closed window dose rates window dose rates > 1000 logical connector for usability.

greater than 1000 mR/hr mRem/hr expected to continue for The NEI abbreviation "R" has been replaced with the plant expected to continue for 60 2> 1 hr at or beyond the abbreviation "Rem" to agree with units of measure given in the EPA minutes or longer; or analyses of PROTECTED AREA BOUNDARY PAGs.field survey samples indicate thyroid ODE greater than 5000 OR The NEI phrase "thyroid CDE greater than 5000 mrem for one hour mrem for one hour of inhalation, Analyses of field survey samples of inhalation" has been changed to "1-131 concentration

> 3.85E-06 at or beyond site boundary.

indicate 1-131 concentration>

[.Cilcc or HP 260 probe reading > 4.50E+03 CCPM" because the 3.85E-06 ýtCi/cc at or beyond the Iodine-1 31 field survey sample concentration and count rate PROTECTED AREA BOUNDARY threshold is based on 1-131 dose conversion factors (DCFs) from EPA-400. The thresholds are based on a Thyroid-CDE Dose Rate of 5000 mRem/hr for 1-131.The NEI phrase "site boundary" has been changed to "the PROTECTED AREA BOUNDARY" because it is an easily determined location to obtain a field survey dose rate reading or to 39 of 144 EAL Comparison Matrix 0551- SGS EAL Comparison Matrix obtain~~~~~~~~~S

-fil ape TeSlmHpeCekst i iutdo obtain a field sample. The Salem/Hope Creek site is situated on Artificial Island, bordered by the Delaware River on one side and marshy wetlands on the other sides. The area between the Protected Area and the site boundary (defined by the Minimum Exclusionary Boundary) is primarily wetlands and the river, both of which would be inaccessible to offsite field survey teams- Onsite survey teams dispatched inside the Protected Area would likely be the first to detect adverse radiological conditions at or beyond the site boundary.40 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS Category C Cold Shutdown / Refueling System Malfunction 41 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification CUl RCS Leakage CU3 Unplanned loss of RCS The IC has been changed from "RCS Leakage" to "Unplanned loss of MODE: Cold Shutdown inventory RCS inventory" to align with NEI generic IC CU2. The example EALs MODE: 5 -Cold Shutdown of NEI CU1 manifest RCS leakage through loss of RCS inventory conditions.

The intent of the two ICs is identical.

This allows the SGS-related EAL to be numbered with the other loss of inventory based EALs CU2.2 and CU2.3 which are derived from generic IC CU2.NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL# EAL S EAL #1 RCS leakage results in the N/A N/A The BWR portion of the NEI EAL has not been implemented because inability to maintain or restore SGS is a PWR.RPV level greater than (site specific low level RPS actuation setpoint) for 15 minutes or longer. [BWR]Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.42 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS I RCS leakage results in the inability to maintain or restore level within (site specific pressurizer or RCS/RPV level target band) for 15 minutes or longer. [PWR]CU3.1 RCS leakage results in the inability to maintain or restore RCS level to EITHER: " Pressurizer Level > 17%(cold calibration value)* Within the target band established by procedure (when the level band is established below the pressurizer)

AND_ 15 minutes have elapsed (Note 3)Note 3: 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 will likely exceed the applicable time.Reformatted for readability.

The site-specific Pressurizer low level actuation setpoint (17%) is the specified SGS level.The phrase "established by procedure (when the level band is established below the pressurizer)" has been added to the SGS EAL for clarification.

SGS operating procedures specify the appropriate RCS level range. The target band is not applicable if level is being maintained in the pressurizer.

Reference to the NEI note is included in the EAL wording "(Note 3)." Numbering the note facilitates referencing in the EAL matrix.43 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification CU2 UNPLANNED loss of RCS/RPV CU3 UNPLANNED loss of RCS The NEI acronym "RCS/RPV" has been replaced with "RCS" to use inventory inventory terminology commonly accepted at PWRs.MODE: Refueling MODE: 6 -Refueling NEI Ex. SGS EI NEI Example EAL Wording EAL SGS EAL Wording Difference/Deviation Justification EAL # EAL #UNPLANNED RCS/RPV level CU3.3 UNPLANNED RCS level drop The NEI acronym "RCS/RPV" has been replaced with "RCS" to use drop as indicated by either of the below EITHER of the following:

terminology commonly accepted at PWRs.following:

104 ft (Reactor Vessel Reformatted for readability." RCS/RPV water level flange) 104 ft is the elevation corresponding to the Reactor Vessel flange.drop below the RPV flange for 15 minutes or e RCS level band (when the Reference to the NEI note is included in the EAL wording "(Note 3)." longer when the RCS level band is Numbering the note facilitates referencing in the EAL matrix.RCS/RPV level band is established below the established above the Reactor Vessel flange)RPV flange. AND" RCS/RPV water level _> 15 minutes have elapsed drop below the RCS (Note 3)level band for 15 minutes or longer when Note 3: The Emergency the RCS/RPV level band Coordinator should NOT is established below the wait until the applicable RPV flange. time has elapsed, but Note: The Emergency Director should declare the event should not wait until the as soon as it is determined that the applicable time has condition will likely elapsed, but should exceed the applicable declare the event as soon as it is determined time.that the condition will likely exceed the applicable time.44 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS 2 RCS/RPV level cannot be CU3.2 RCS level CANNOT be The NEI acronym "RCS/RPV" has been replaced with "RCS" to use monitored with a loss of monitored with a loss of RCS terminology commonly accepted at PWRs.RCS/RPV inventory as indicated inventory as indicated by ANY The NEI phrase "unexplained level rise in (site specific sump or by an unexplained level rise in unexplained RCS leakage tank)" has been changed to "ANY unexplained RCS leakage (site specific sump or tank). indication, Table C-1 indication, Table C-1" to reduce EAL-user reading burden and thereby promote timely and accurate emergency classifications.

Table C-1 lists the site-specific sumps and tank level conditions that could be indicative of a loss of inventory from the RCS.Table C-1 RCS Leakage Indications

Rise in Containment sump pump run frequency* Aux Building sump level rise" PRT level rise" RWST level rise* RCDT level rise* Rise in RCS make-up rate* Observation of RCS leakage that is UNISOLABLE 45 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s)CU3 AC power capability to CU1 AC power capability to vital "Vital buses" is equivalent to the NEI phrase "emergency buses." emergency busses reduced to a buses reduced to a single power The term "station blackout" was replaced with "complete loss of AC single power source for 15 source for 15 minutes or longer power to vital buses" as this describes the intended condition minutes or longer such that any such that ANY additional single leading to the Alert threshold in CAl.1. Station Blackout is not an additional single failure would failure would result in complete operationally defined term for loss of all AC to vital buses.result in station blackout loss of AC power to vital buses MODE: Cold Shutdown, MODE:5 -Cold Shutdown, 6 -Refueling Refueling NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #1 a. AC power capability to (site CU1.1 Loss of 4KV Vital Bus Power 4KV vital buses are the SGS emergency buses.specific emergency busses) Sources (Offsite and Onsite) The NEI phrase "AC power capability to (site specific emergency reduced to a single power which results in the availability of busses) reduced to a single power source" has been changed to source for 15 minutes or only one 4KV Vital Bus Power "Loss of 4KV Vital Bus Power Sources (Offsite and Onsite) which longer Source (Offsite or Onsite) results in the availability of only one 4KV Vital Bus Power Source AND AND (Offsite or Onsite)" to reflect the specific SGS vital power b. Any additional single power _ 15 minutes have elapsed configuration.

source failure will result in (Note 3) The AND logic used in NEI 99-01 is improper as the second station blackout.

condition is not a separate condition of equal weight but rather a Note 3: The Emergency qualifier of the first. The threshold statement has been reworded to Note: The Emergency Director Coordinator should NOT properly reflect the intent.should not wait until the wait until the applicable Station Blackout is not an operationally defined term for loss of all applicable time has time has elapsed, but elapsed, but should should declare the event AC to vital buses.declare the event as as soon as it is soon as it is determined determined that the that the condition will condition will likely likely exceed the exceed the applicable applicable time. time.46 of 144 EAL Comparison Matrix OSSI -SGS 47 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification CU4 UNPLANNED loss of decay heat CU4 UNPLANNED loss of decay heat The NEI acronym "RPV" has been changed to "Reactor Vessel" to removal capability with irradiated removal capability with irradiated use terminology commonly accepted at PWRs.fuel in the RPV fuel in the Reactor Vessel MODE: Cold Shutdown, MODE: 4 -Cold Shutdown, 5 -Refueling Refueling NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL #EAL #1 UNPLANNED event results in CU4.1 An UNPLANNED Loss of Decay The NEI phrase "UNPLANNED event results in" has been changed RCS temperature exceeding the Heat Removal functions to "An UNPLANNED Loss of Decay Heat Removal functions AND" Technical Specification cold for clarification.

According to the NEI IC and basis discussion, the shutdown temperature limit. AND event of interest involves the loss of decay heat removal capability.

RCS Temperature has risen to> 200'F is the SGS Technical Specification cold shutdown 200OF temperature limit and has been added for clarification.

The NEI phrase "... exceeding the Technical Specification cold shutdown temperature limit" has been replaced with " has risen to >2001F' for simplification.

200'F is universally understood to be the SGS Technical Specification cold shutdown temperature limit.2 Loss of all RCS temperature and CU4.2 An UNPLANNED Loss of Decay The NEI acronym "RCS/RPV" has been replaced with "RCS" to use RCS/RPV level indication for 15 Heat Removal functions terminology commonly accepted at PWRs.minutes or longer. AND The phrase ""An UNPLANNED Loss of Decay Heat Removal Note: The Emergency Director functions AND" has been added for clarification.

According to the should not wait until the Loss of BOTH of the following:

NEI IC and basis discussion, the event of interest involves the loss applicable time has o All RCS Temperature of decay heat removal capability.

elapsed, but should indication Reformatted the NEI EAL to improve readability.

declare the event as soon as it is determined o All RCS level indication that the condition will AND likely exceed the applicable time. _ 15 minutes have elapsed (Note 3)48 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS Note 3: 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 will likely exceed the applicable time.49 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification CU6 Loss of all On-site or Off-site CU5 Loss of all onsite or offsite None communications capabilities communications capabilities MODE: Cold Shutdown, MODE: 5 -Cold Shutdown, 6 -Refueling, Defueled Refueling, D -Defueled NEI Ex. NEI Example EAL Wording SGSSGS EAL Wording Difference/Deviation Justification EAL# EAL #1 Loss of all of the following on-site CU5.1 Loss of all Table C-4 Onsite CU5.1 implements Example EALs #1 and #2. These were communication methods affecting communication methods affecting combined for improved usability.

the ability to perform routine the ability to perform routine The NEI example EALs specify site-specific lists of onsite and operations:

operations offsite communications methods. The SGS EAL lists these (site specific list of OR methods in Table C-4 for simplification.

communications methods) Loss of all Table C-4 Offsite 2 Loss of all of the following off-site communication methods affecting communication methods affecting the ability to perform offsite the ability to perform offsite notifications notifications: (site specific list of communications methods)50 of 144 EAL Comparison Matrix 0531- SGS EAL Comparison Matrix OSSI -SGS Table C-4 Communications Systems System Onsite Offsite Direct Inward Dial System (DID) X X Station Page System (Gaitronics)

X Station Radio System X..........

.....................

I...........................................

..............

..... .......................................................

...........

-.........................................

.......--

........................

I ...... .......... , ....................

-.................................

........Nuclear Emergency Telephone System X (NETS).... ..............

..................

..........

... .........................

-..................

...........................................

.. ............

................... , ........ ..........

..... .................................

-.. ......................

............

.... ... .. ...............

Centrex Phone System (ESSX) X..............

.... ........................

........................

.................................

....X.... ..... ..............................................

............

.....................

NRC (ENS) X 51 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification CU7 Loss of required DC power for CU2 Loss of required DC power for None 15 minutes or longer 15 minutes or longer MODE: Cold Shutdown, MODE: 5 -Cold Shutdown, 6 -Refueling Refueling NEI Ex. NEI Example EAL Wording SGSSGS EAL Wording Difference/Deviation Justification EAL #r EAL #Less than (site specific bus CU2.1 < 114 VDC bus voltage 114 VDC for the 125 VDC vital buses and 25 VDC for the 28 VDC voltage indication) on required indications on All 125 VDC vital vital buses are the site-specific bus voltages.

The minimum voltages (site specific Vital DC busses) buses for > 15 minutes (Note 3) for the 125 VDC vital buses vary from 112.3 VDC to 113.9 VDC and for 15 minutes or longer, have been rounded to 114 VDC for all buses for readability on Nor 15 Emerger. OR Control Room instrumentation.

The minimum voltages for the 28 Note: The Emergency Director should not wait < 25 VDC bus voltage VDC vital buses vary from 24.8 VDC to 25 VDC and have been until the applicable time indications on both 28 VDC vital rounded to 25 VDC for both buses for readability on Control Room has elapsed, but should buses for _ 15 minutes (Note 3) instrumentation.

declare the event as AND loss of control of Safety 125 VDC vital buses 1 A(2A), 1 B(2B) and 1 C(2C) and 28 VDC vital soon as it is determined Related Equipment from the buses 1A(2A) and 1B(2B) are the site-specific vital DC buses. The 28 that the condition will Control Room has been VDC system is required to operate pushbutton controls in the Control likely exceed the confirmed Room. It thus provides control power for remote operation of applicable time. Note 3: The Emergency switchgear, annunciators, vital instrument buses, communications to Coordinator should NOT auxiliary control system relay cabinets for manual control of ESF wait until the applicable equipment, non-safety related equipment, and RP4 Status Board time has elapsed, but indications.

should declare the event The NEI term "required" has been replaced with "All" (for 125 VDC as soon as it is vital buses) and "both" for 28 VDC vital buses. All vital DC buses can determined that the be cross connected so that required DC power can be provided with condition will likely no more than one bus. Since the minimum required DC buses is one exceed the applicable bus, the EAL threshold is met when the minimum bus voltage on all time. DC buses occurs for 15 minutes or longer. [SGS to review and edit this justification].N

_.Nr, Rev ' -PauPWillg[

Reference to the NEI note is included in the EAL wording "(Note 3)." Numbering the note facilitates referencing in the EAL matrix.52 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s)CU8 Inadvertent criticality CU6 Inadvertent criticality None MODE: Cold Shutdown, MODE: 5 -Cold Shutdown, 6 -Refueling Refueling NEI Ex. SGS EAL# NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification 1 UNPLANNED sustained positive N/A N/A NEI BWR Example EAL #1 has not been implemented because it period observed on nuclear applies only to BWR plants. SGS is a PWR.instrumentation. (BWR)1 UNPLANNED sustained positive CU6.1 UNPLANNED sustained positive None startup rate observed on nuclear startup rate observed on nuclear instrumentation. (PWR) instrumentation 53 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording lC#(s) SGS IC Wording Difference/Deviation Justification CA1 Loss of RCS/RPV inventory CA3 Loss of RCS inventory The NEI acronym "RCS/RPV" has been replaced with "RCS" to use MODE: Cold Shutdown, MODE: 5 -Cold Shutdown, 6 -terminology commonly accepted at PWRs.Refueling Refueling NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL# EAL # EAL #Loss of RCS/RPV inventory as CA3.1 RCS level < 97.5 ft The NEI acronym "RCS/RPV" has been replaced with "RCS" to use indicated by level less than (site terminology commonly accepted at PWRs.specific level). The NEI phrase "Loss of RCS/RPV inventory as indicated by..." has[Low-Low ECCS actuation been deleted because it is obvious from the threshold level that setpoint/Level 2 (BWR)] inventory in the RCS has been lost. This change has been made to[Bottom ID of the RCS loop reduce EAL-user reading burden and thereby promote timely and (PWR)] accurate emergency classifications.

SGS is a PWR and is not equipped with the Low-Low ECCS Actuation setpoint/Level 2.The centerline level of the RCS loop hot leg is at approximately 97 ft and the inside diameter of the hot leg penetration is 29 in. The bottom ID would be 97 ft -29/2 in. or 95 ft 9.5 in. Although NEI specifies a level for this threshold that is equal to the bottom of the RCS loop hot leg penetration, the SGS level indication capability does not support detection of a threshold level that low. RVLIS is capable of monitoring level to 97.3 ft so a setpoint of 97.5 ft has been selected.

Local indication is also available to monitor this level.2 RCS/RPV level cannot be CA3.2 RCS level CANNOT be The NEI acronym "RCS/RPV" has been replaced with "RCS" to use monitored for 15 minutes or monitored for > 15 minutes with terminology commonly accepted at PWRs.longer with a loss of RCS/RPV a loss of RCS inventory as Table C-1 lists the site-specific sumps and tank level conditions that inventory as indicated by an indicated by ANY unexplained could be indicative of a loss of inventory from the RCS.unexplained level rise in (site RCS leakage indication, Table specific sump or tank). C-1 (Note 3)Note:The Emergency Director Note 3: The Emergency should not wait until the Coordinator should 54 of 144 EAL Comparison Matrix OSSI -SGS applicable time has NOT wait until the elapsed, but should applicable time has declare the event as soon elapsed, but should as it is determined that the declare the event as condition will likely exceed soon as it is determined the applicable time. that the condition will likely exceed the applicable time.Table C-1 RCS Leakage Indications

Rise in Containment sump pump run frequency* Aux Building sump level rise" PRT level rise" RWST level rise* RCDT level rise* Rise in RCS make-up rate* Observation of RCS leakage that is UNISOLABLE 55 of 144 EAL Comparison Matrix 0SSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification CA3 Loss of all Off-site and all On- CA1 Loss of all offsite and all onsite "Vital buses" is equivalent to the NEI phrase "emergency buses." Site AC power to emergency AC power to vital buses for 15 busses for 15 minutes or longer. minutes or longer MODE: Cold Shutdown, MODE: 5 -Cold Shutdown, 6 -Refueling, Defueled Refueling, D -Defueled NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #1 Loss of all Off-Site and all On- CA1.1 Loss of all Power (Onsite and The NEI phrase "Loss of all off-site and all on-site AC power" has Site AC Power to (site specific Offsite) to all 4KV Vital Buses been changed to "Loss of all Power (Onsite and Offsite)" for emergency busses) for 15 AND simplification.

minutes or longer. 4KV vital buses are the SGS emergency buses.Note: The Emergency Director > 15 minutes have elapsed should not wait until the (Note 3)applicable time has Note 3: The Emergency elapsed, but should Coordinator should NOT declare the event as wait until the applicable soon as it is determined time has elapsed, but that the condition will should declare the event likely exceed the as soon as it is applicable time. determined that the condition will likely exceed the applicable time.56 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s)CA4 Inability to maintain plant in cold CA4 Inability to maintain plant in cold None shutdown.

shutdown MODE: Cold Shutdown, MODE: 5 -Cold Shutdown, 6 -Refueling Refueling NEI Ex. SGS EAL # NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification 1 An UNPLANNED event results CA4.1 An UNPLANNED event results NEI Example EALs #1 and #2 have been implemented in one EAL in RCS temperature greater than in RCS temperature

> 200OF for for simplification and to help ensure proper escalation from EALs (site specific Technical

> Table C-3 duration CU4.1 and CU4.2.Specification cold shutdown , temperature limit) for greater OR The NEI phrase "... greater than (site specific Technical Specification cold shutdown temperature limit)... " has been replaced with ">than the specified duration on An UNPLANNED event results 2001F." 200°F is the SGS Technical Specification cold shutdown table. in RCS pressure increase > 10 temperature limit.psi due to a loss of RCS cooling (this portion of the EAL does NEI example table has been represented in Table C-3. SGS is a An UNPLANNED event results NOT apply in Solid Plant PWR; therefore all PWR requirements (reduced inventory) have in RCS pressure increase conditions) been implemented.

greater than 10 psi due to a loss A ten-psi RCS pressure increase is readable in the Control Room on of RCS cooling. (PWR-This EAL 1(2)PI-403, SPDS Point UI(2)PT0403S, and P250 Computer Point does not apply in Solid Plant P0499A. PI-403 has a range of 0 -600 psig. One-half of the conditions.)

minimum 20 psi scale division is 10 psi.57 of 144 EAL Comparison Matrix NEI Example Table: OSSI -SGS Table: RCS Reheat Duration Thresholds RCS Containment Closure Duration Intact (but not RCS Reduced Inventory N/A 60 minutes.tPWR])Not intact or RCS Established 20 minutes-Reduced Inventory Not Established 0 minutes (PWRJ" If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.

SGS Table: Table C-3 RCS Heatup Duration Thresholds RCS Integrity CONTAINMENT CLOSURE Duration Threshold Intact AND NOT in reduced inventory NOT Applicable 60 minutes **status NOT Intact OR Established 20 minutes **RCS is in a reduced inventory status NOT Established 0 minutes** IF a Decay Heat Removal System is placed in operation within the duration threshold and RCS Temperature is lowering, THEN this EAL is NOT Applicable 58 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Matrix OSSI -SGS NEI IC#CS1 NEI IC Wording SGS IC#(s)SGS IC Wording Difference/Deviation Justification Loss of RCS/RPV inventory affecting core decay heat removal capability.

MODE: Cold Shutdown, Refueling CS3 Loss of RCS inventory affecting core decay heat removal capability MODE: 5 -Cold Shutdown, 6 -Refueling The NEI acronym "RCS/RPV" has been replaced with "RCS" to use terminology commonly accepted at PWRs.U _________

U L NEI Ex. NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification

1. With CONTAINMENT N/A N/A The centerline level of the RCS loop hot leg is at approximately 97 ft CLOSURE not established, and six inches below the bottom ID would be 97 ft -29/2 in. -6 in. or RCS/RPV level less than (site 95 ft 3.5 in. The SGS level indication capability does not support specific level), detection of a threshold level that low; thus, RCS level cannot be[6" below the bottom ID of the monitored and only Example EAL #3 can be implemented for this IC.RCS loop (PWR)t This is consistent with the generic bases which recognizes that this EAL would not be implemented by those plants without adequate[6" below the low-low ECCS RCS level monitoring capability.

actuation setpoint (BWR)]2 2. With CONTAINMENT N/A N/A TOAF is at 92 ft 9.5 in. elevation.

The SGS level indication capability CLOSURE established, does not support detection of a threshold level that low; thus, RCS RCS/RPV level less than (site level cannot be monitored and only Example EAL #3 can be specific level for TOAF). implemented for this IC. This is consistent with the generic bases which recognizes that this EAL would not be implemented by those plants without adequate RCS level monitoring capability.

3 RCS/RPV level cannot be CS3.2 RCS level CANNOT be The NEI acronym "RCS/RPV" has been replaced with "RCS" to use monitored for 30 minutes or monitored for >_ 30 minutes with terminology commonly accepted at PWRs.longer with a loss of RCS/RPV a loss of RCS inventory as Radiation monitors R44A, R10B and R2 detect Containment dose inventory as indicated by ANY of indicated by ANY of the rate. PSEG Calculation

ES-50-015 documents the basis for using the following:

following (Note 3): these monitors to indicate the possibility of core uncovery.(Site specific radiation e R44A > 5 R/hr The NEI phrase "UNPLANNED level rise in (site specific sump or monitor) reading greater 0 RiOB >3500mRlhr tank)" has been changed to "ANY unexplained RCS leakage than (site specific value). *R10B>35m/hrindication, Table C-1" to reduce EAL-user reading burden and 59 of 144 EAL Comparison Matrix 0551- SGS EAL Comparison Matrix OSSI -SGS* Erratic Source Range Monitor Indication.

UNPLANNED level rise in (site specific sump or tank).Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time." R2 > 104 mR/hr" Erratic Source Range Monitor indication" ANY unexplained RCS leakage indication, Table C-1 Note 3: 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 will likely exceed the applicable time.thereby promote timely and accurate emergency classifications.

Table C-1 lists the site-specific sumps and tank level conditions that could be indicative of a loss of inventory from the RCS.Reference to the NEI note is included in the EAL wording "(Note 3)." Numbering the note facilitates referencing in the EAL matrix.60 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Matrix OSSI -SGS Table C-1 RCS Leakage Indications

Rise in Containment sump pump run frequency o Aux Building sump level rise* PRT level rise* RWST level rise* RCDT level rise o Rise in RCS make-up rate 0 Observation of RCS leakage that is UNISOLABLE 61 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification CG1 Loss of RCS/RPV inventory CG3 Loss of RCS inventory affecting The NEI acronym "RCS/RPV" has been replaced with "RCS" to use affecting fuel clad integrity with fuel clad integrity with terminology commonly accepted at PWRs.containment challenged Containment challenged MODE: Cold Shutdown, MODE: 5 -Cold Shutdown, 6 -Refueling Refueling NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #1 a. RCS/RPV level less than (site N/A N/A TOAF is at 92 ft 9.5 in. elevation.

The SGS level indication specific level for TOAF) for 30 capability does not support detection of a threshold level that low;minutes or longer, thus, RCS level cannot be monitored and only Example EAL #2 can be implemented for this IC. This is consistent with the generic AND bases which recognizes that this EAL would not be implemented

b. ANY containment challenge by those plants without adequate RCS level monitoring capability.

indication (see Table): Table: Containment Challenge Indications

CONTAINMENT CLOSURE not established." (Site specific explosive mixture) inside containment.

UNPLANNED rise in containment pressure" Secondary containment radiation monitor reading above (site specific value).[BWR only]Note: The Emergency Director should not wait until the applicable time has elapsed, but should 62 of 144 EAL Comparison Matrix OSSI -SGS declare the event as soon as it is determined that the condition will likely exceed the applicable time.2 a. RCS/RPV level cannot be monitored with core uncovery indicated by ANY of the following for 30 minutes or longer." (Site specific radiation monitor) reading greater than (site specific setpoint).

Erratic source range monitor indication

UNPLANNED level rise in (site specific sump or tank).* [Other site specific indications]

AND b. ANY containment challenge indication (see Table): Table: Containment Challenge Indications" CONTAINMENT CLOSURE not established.

(Site specific explosive mixture) inside containment.

UNPLANNED rise in containment pressure* Secondary containment radiation monitor reading above (site specific value).[BWR only]CG3.2 RCS level CANNOT be monitored for ? 30 minutes with core uncovery indicated by ANY of the following (Note 3): " R44A > 5 R/hr" R10B > 3500 mR/hr* R2 > 104 mR/hr* Erratic Source Range Monitor indication

ANY unexplained RCS leakage indication, Table C-1 AND ANY Containment Challenge indication, Table C-2 Note 3: 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 will likely exceed the applicable time.The NEI acronym "RCS/RPV" has been replaced with "RCS" to use terminology commonly accepted at PWRs.Radiation monitors R44A, R10B and R2 detect Containment dose rate. PSEG Calculation

ES-50-015 documents the basis for using these monitors to indicate the possibility of core uncovery.The NEI phrase "UNPLANNED level rise in (site specific sump or tank)" has been changed to "ANY unexplained RCS leakage indication, Table C-1" to reduce EAL-user reading burden and thereby promote timely and accurate emergency classifications.

Table C-1 lists the site-specific sumps and tank level conditions that could be indicative of a loss of inventory from the RCS.Table C-2 lists the Containment Challenge indications.

Reference to the NEI note is included in the EAL wording "(Note 3)." Numbering the note facilitates referencing in the EAL matrix.> 4% hydrogen is the site-specific explosive mixture inside Containment.

The NEI phrase "Secondary Containment radiation monitors above{site-specific}

value (BWR only)" has been deleted because SGS is a PWR.r 63 of 144 EAL Comparison Matrix OSSI -SGS Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the I applicable time.64 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS Table C-1 RCS Leakage Indications

Rise in Containment sump pump run frequency* Aux Building sump level rise* PRT level rise* RWST level rise* RCDT level rise* Rise in RCS make-up rate* Observation of RCS leakage that is UNISOLABLE Table C-2 Containment Challenge Indications

CONTAINMENT CLOSURE NOT established

Indications of > 4% H 2 inside Containment

.UNPLANNED rise in Containment pressure 65 of 144 EAL Comparison Matrix OSSI -SGS Category D Permanently Defueled Station Malfunction 66 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s) SSI odn D-AU1 Recognition Category D N/A N/A NEI Recognition Category D ICs and EALs are applicable only to D-AU2 Permanently Defueled Station permanently defueled stations.

SGS is not a defueled station.D-SU1 Malfunction D-HU1 D-HU2 D-HU3 D-AA1 D-AA2 D-HA1 D-HA2 67 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Matrix OSSI -SGS Category E Events Related to Independent Spent Fuel Storage Installations 68 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification E-HU1 Damage to a loaded cask EU1 Damage to a loaded cask None CONFINEMENT BOUNDARY CONFINEMENT BOUNDARY MODE: N/A MODE: Mode Not Applicable NEI Ex. NEI Example EAL Wording SAS SGS EAL Wording Difference/Deviation Justification Damage to a loaded cask EUI.1 Damage to a Multi Purpose This EAL is only applicable for a Salem spent fuel cask that is in CONFINEMENT BOUNDARY.

Canister (MIPG) transit to the ISFSI. After the spent fuel cask is in place at the.CONFIsErMET ISFSI, any further conditions that could adversely impact the ISFSI CONFINEMENT or an individual cask from either Salem or Hope Creek would be BOUNDARY as indicated by assessed and classified as needed by the Hope Creek Shift on-contact radiation readings Manager (SM) per Hope Creek EAL EU1.1.> 600 mR/hr (gamma +neutron) on the surface of the The NEI phrase "loaded CONFINEMENT BOUNDARY" has been speutron)ont fuel csk, fa e the changed to "Damage to a Multi Purpose Canister (MPC)spent fuel cask, excluding the CONFINEMENT BOUNDARY as indicated by on-contact radiation air vents, OR > 60 mR/hr readings _> 600 mR/hr (gamma + neutron) on the surface of the (gamma + neutron) on the spent fuel cask, excluding the air vents, OR > 60 mR/hr (gamma +top of the spent fuel cask neutron) on the top of the spent fuel cask while in transit to the while in transit to the ISFSI ISFSI." As provided in the Holtec HI-STORM 100 System Certificate of Compliance (CoC), Appendix A (Technical Specifications), Section 5.7.4 contains radiation values for the cask that should not be exceeded.

Under Amendment

5, the highest allowable radiation level on contact with the HI-STORM 100 cask body is 300 mR/hr on the side of the cask and 30 mR/hr on the top of the cask. Keeping in line with NEI guidance that a UE is warranted for radiation conditions at a level of twice the Technical Specification value, 600 mR/hr and 60 mR/hr are being used as the EAL threshold radiation levels.69 of 144 EAL Comparison Matrix OSSI -SGS The threshold values are sufficiently above nominal radiation levels of the CONFINEMENT BOUNDARY that radiation levels above this EAL threshold would indicate significant damage to the CONFINEMENT BOUNDARY.No releases of radioactive material requiring offsite response or monitoring are expected because the seal-welded spent fuel canister (part of the CONFINEMENT BOUNDARY) is designed to remain intact under all normal, off-normal, and credible accident conditions of onsite transport and storage at the ISFSI, according to Holtec licensing documents.

Postulated problems associated with the dry cask storage system include those caused by natural phenomena or accidents caused by human error/equipment malfunctions which affect the storage system. Generally speaking, the limiting impacts to the system include loss of shielding capability and loss of fuel canister integrity.

The loss of shielding would result in higher direct radiation to the environment, while the loss of fuel canister integrity results in a release of radioactive materials from the Multi-Purpose Canister (MPC) within the cask to the environment.

However, the particular dry storage system used at the PSEG Nuclear ISFSI is a robust seal-welded,, canister-based system that is designed to remain leak-tight under all normal, off-normal and postulated accident conditions.

Therefore, effluent release from the storage system is not a credible condition.

In addition, because the amount of radioactive material inside the dry storage system is fixed, the source term never increases over time and, in fact, decreases over time due to radioactive decay.The effect on cask shielding effectiveness under off-normal and accident conditions is evaluated in Chapter 11 of the HI-STORM FSAR. Only one event resulted in a slight loss of the cask shielding effectiveness that was caused by the postulated accident conditions evaluated for a fire. A very small percentage of the cask exterior concrete was estimated to be degraded, which did not result in any significant projected increase in dose rates. No release of radioactive material from the.MPC is projected for any off-normal or accident event.:;, 70 of 144:.. -:.... ... ,J)

EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS Category F Fission Product Barrier Degradation 71 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification FU1 ANY Loss or ANY Potential Loss None ANY loss or ANY potential loss See discussion of point system in Table 4.of Containment of Containment MODE: Power Operation, Hot MODE: 1 -Power Operations, 2 -Standby, Startup, Hot Shutdown Startup, 3 -Hot Standby, 4 -Hot Shutdown NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL# EAL # EAL #1 ANY Loss or ANY Potential Loss None ANY loss or ANY potential loss See discussion of point system in Table 4.of Containment of Containment SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification FA1 ANY Loss or ANY Potential Loss None ANY loss or ANY potential loss See discussion of point system in Table 4.of EITHER Fuel Clad OR RCS of either Fuel Clad or RCS MODE: Power Operation, Hot MODE: 1 -Power Operations, 2 -Standby, Startup, Hot Shutdown Startup, 3 -Hot Standby, 4 -Hot Shutdown NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL# EAL # EAL #1 ANY Loss or ANY Potential Loss None ANY loss or ANY potential loss See discussion of point system in Table 4.of EITHER Fuel Clad OR RCS of either Fuel Clad or RCS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s)FS1 Loss or Potential Loss of ANY None Loss or potential loss of ANY two See discussion of point system in Table 4.72 of 144 EAL Comparison Matrix OSSI -SGS Two Barriers barriers MODE: Power Operation, Hot MODE: 1 -Power Operations, 2 -Standby, Startup, Hot Shutdown Startup, 3 -Hot Standby, 4 -Hot Shutdown NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification 1 Loss or Potential Loss of ANY None Loss or potential loss of ANY two The condition "OR Potential loss of 2 barriers with the loss of the 3rd Two Barriers barriers barrier" has been added for clarification.

OR See discussion of point system in Table 4.Potential loss of 2 barriers with the loss of the 3rd barrier NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(S)FG1 Loss of ANY Two Barriers AND None Loss of ANY two barriers AND See discussion of point system in Table 4.Loss or Potential Loss of Third loss or potential loss of third Barrier barrier MODE: Power Operation, Hot MODE: 1 -Power Operations, 2 -Standby, Startup, Hot Shutdown Startup, 3 -Hot Standby, 4 -Hot Shutdown NEAL E NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification 1 Loss of ANY Two Barriers AND FG1 .1 Loss of ANY two barriers See discussion of point system in Table 4.Loss or Potential Loss of Third Barrier AND Loss or potential loss of third barrier 73 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS Table 4 -Classification of Fission Product Barriers with the Point System A point system is used to determine the Emergency Classification Level based on the Fission Product Barrier Table. Each Fission Product Barrier Loss and Potential Loss threshold is assigned a point value as noted below.Points Barrier Degradation Fuel Clad Loss RCS Loss Fuel Clad Potential Loss RCS Potential Loss 3 Containment Loss 2 Containment Potential Loss Classification instructions:

1. Review all columns of the Fission Product Barrier Table and identify which need further review.2. For each of the three barriers, determine the EAL with the highest point value. No more than one EAL should be selected for each barrier.3. Add the point values for the three barriers.4. Classify based on the point value sum as follows: If the sum ECG is: Classify as: EAL Att#UNUSUAL ANY loss or ANY potential EVENT loss of Containment I ANY loss or ANY potential 4, 5 ALERT loss of either Fuel Clad or 2 RCS Loss or potential loss of ANY SITE AREA two barriers 3 6-11 EMERGENCY OR Potential loss of 2 barriers with the loss of the 3rd 74 of 144 EAL Comparison Matrix OSSI -SGS barrier Loss of ANY two barriers 12,13 GENERAL AND 4 EMERGENCY Loss or potential loss of third barrier 5. Implement the appropriate ECG Attachment.

6. Continue to review the Fission Product Barrier Table for changes that could result in emergency escalation or de-escalation 75 of 144 EAL Comparison Matrix OSSI -SGS Salem -Fission Product Barrier Table Fuel Clad Barrier RCS Barrier Containment Barrier Potential Loss (4 pts) Loss (5 pts) Potential Loss (4 pts) Loss (5 pts) Potential Loss (2 pt) Loss (3 pts)CFSTs FB1-P FBI-L RB1-P CBI-P CFST Core Cooling CFST Core Cooling CFST Thermal Shock CFST Containment PURPLE path exists RED path exists RED path exists RED path exists FB2-P RB2-P CB2-P CFST Heat Sink RED CFST Heat Sink RED none CFST Core Cooling none path exists due to actual path exists due to actual RED path exists loss of secondary heat loss of secondary heat AND sink and heat sink is sink and heat sink is Restoration procedure required required EOP-FRCC-1 NOT effective within 15 minutes Core Exit TCs FB3-P FB2-L CB3-P 5 or more CETs > 700°F 5 or more CETs > 5 or more CETs >1200°F 1200'F AND Restoration procedure EOP-FRCC-1 NOT effective within 15 minutes CB4-P none none All of the following:

none* 5 or more CETs >700F* RVLIS < Table F-1 thresholds

Restoration procedure EOP-FRCC-1 NOT effective within 15 minutes 76 of 144 EAL Comparison Matrix OSSI -SGS Salem -Fission Product Barrier Table Fuel Clad Barrier RCS Barrier Containment Barrier Potential Loss (4 pts) Loss (5 pts) Potential Loss (4 pts) Loss (5 pts) Potential Loss (2 pt) Loss (3 pts)Radiation FB3-L RB1-L CB5-P Containment radiation ANY of the following Containment radiation monitor 1(2)R44A or Containment radiation monitor 1(2)R44A or 1(2)R44B reading monitor readings:

1(2)R44B reading >none > 282 R/hr none

1(2)R2>1000 2000 R/hr none mR/hr" 1(2)R44A > 10 R/hr* 1(2)R44B > 10 R/hr Inventory FB4-P RB3-P RB2-L CB6-P CB1-L RVLIS < Table F-1 One Centrifugal Subcooling

< 0°F (as a Containment pressure > A Containment pressure thresholds Charging Pump result of RCS leakage) 47 psig and rising rise followed by a rapid CANNOT maintain PZR unexplained drop in... F RV-.......level

> 17% as a result Containment pressure...... of RCS leakage CB7-P CB2-L IF % I Indications of > 4% H 2 Containment pressure inside Containment or sump level response NOT consistent with LOCA conditions

.............................................................................

RB3-L CB8-P CB3-L SGTR requiring ECCS Containment pressure>

RUPTURED SG that is (SI) Actuation 15 psig also FAULTED outside of Containment none AND CB4-L EITHER of the following:

Primary-to-secondary leakrate > 25 gpm* NO Containment AND Spray Train in service UNISOLABLE steam AND release from affected< 5 CFCUs running SG to the environment in low speed" One Containment Spray Train in service AND< 3 CFCUs running in low speed 77 of 144 EAL Comparison Matrix OSSI -SGS Salem -Fission Product Barrier Table Fuel Clad Barrier RCS Barrier Containment Barrier Potential Loss (4 pts) Loss (5 pts) Potential Loss (4 pts) Loss (5 pts) Potential Loss (2 pt) Loss (3 pts)Other FB4-L none none CB5-L Coolant activity Failure of all valves in> 300 pCi/gm dose Note 8: A direct downstream release is a pathway from the Containment to ANY one line to close equivalent 1-131 any environment outside the Containment when Containment or AND none system isolation is required due to: a safety injection signal, " Direct downstream Containment pressure greater than 4 psig, or a VALID pathway to the containment ventilation isolation signal and the pathway cannot be environment exists after isolated from the Control Room. Containment isolation signal (Note 8)Judgment FB5-P FB5-L RB4-P RB4-L CB9-P CB6-L ANY condition in the ANY condition in the ANY condition in the ANY condition in the ANY condition in the ANY condition in the opinion of the opinion of the opinion of the opinion of the opinion of the opinion of the Emergency Coordinator Emergency Coordinator Emergency Coordinator Emergency Coordinator Emergency Coordinator Emergency Coordinator that indicates potential that indicates loss of the that indicates potential that indicates loss of the that indicates potential that indicates loss of the loss of the Fuel Clad Fuel Clad barrier loss of the RCS barrier RCS barrier loss of the Containment Containment barrier barrier barrier 78 of 144 EAL Comparison Matrix OSSI -SGS Fuel Clad Fission Product Barrier Degradation Thresholds NEI SGS NEI NEI IC Wording FPB SGS FPB Wording Difference/Deviation Justification FPB# FPB #(s)FC Loss Critical Safety Function FB1-L CFST Core Cooling RED path The abbreviation "CFST" means Critical Safety Function Status Tree 1 Status exists and has been added for brevity and to improve clarity.A. Core-Cooling Red Entry The NEI phrase "Core-Cooling Red" has been changed to "Core Conditions Met. Cooling RED" (hyphen removed).The NEI phrase "Entry Conditions Met" has been changed to "path exists" for consistency with terminology used by SGS operators when using the EOPs.FC Loss Primary Coolant Activity FB4-L Coolant activity > 300 pCi/gm The site specific value of 300 pCi/gm Dose Equivalent Iodine-1 31 2 Level Dose Equivalent 1-131 (DEl-1 31) is based on calculation by Nuclear Fuels Group file title A. Coolant activity greater than DS1.6-0098 "Verification of Emergency Action Levels for Event (site specific value). Classification" date 1/26/95 and corresponds to approximately 2.8%fuel clad damage.FC Loss Core Exit Thermocouple FB2-L 5 or more CETs > 1200°F The EAL threshold of 5 or more CETs > 1200°F is equivalent to 3 Readings CFST Core Cooling RED.A. Core exit thermocouples reading greater than (site specific degree F).FC Loss Reactor Vessel Water Level N/A 4 Not Applicable FC Loss Not Applicable N/A Not Applicable FC Loss Containment Radiation FB3-L Containment radiation monitor Per calculation by Nuclear Fuels Group file title DS1.6-0098 6 Monitoring 1(2)R44A or 1(2)R44B reading > "Verification of Emergency Action Levels for Event Classification" A. Containment radiation 300 R/hr date 1/26/95, a reading of 282 R/hr (rounded to 300 R/hr for monitor reading greater than readability) on Containment High Range monitor 1(2)R44A or (site specific value). 1(2)R44B is indicative of fuel clad damage equivalent to the dispersal of reactor coolant with 300 pCi/gm dispersed into the Containment atmosphere.

79 of 144 EAL Comparison Matrix OSSI -SGS NEI SGS FPB NEI IC Wording FPB SGS FPB Wording Difference/Deviation Justification FPB# FPB #(s)FC Loss Other Site-Specific N/A None 7 Indications A. (Site-specific ) as applicable FC Loss Emergency Director FB5-L ANY condition in the opinion of None 8 Judgment the Emergency Coordinator that A. Any condition in the opinion indicates loss of the Fuel Clad of the Emergency Director barrier that indicates Loss of the Fuel Clad Barrier.FC Critical Safety Function FB1-P CFST Core Cooling PURPLE The abbreviation "CFST" means Critical Safety Function Status Tree P-Loss 1 Status path exists and has been added for brevity and to improve clarity.A. Core Cooling-Orange Entry "PURPLE" is the SGS equivalent of the NEI "Orange" CFST color.Conditions Met. The NEI phrase "Entry Conditions Met" has been changed to "path OR exists" for consistency with terminology used by SGS operators B. Heat Sink-Red Entry when using the EOPs.80 of 144 EAL Comparison Matrix OSSI -SGS NEI SGS NPI NEI IC Wording FPB SGS FPB Wording Difference/Deviation Justification FPB# FPB #(s)Conditions Met. FB2-P CFST Heat Sink RED path The abbreviation "CFST" means Critical Safety Function Status Tree exists due to actual loss of and has been added for brevity and to improve clarity.secondary heat sink and heat The NEI phrase "Entry Conditions Met" has been changed to "path sink is required exists" for consistency with terminology used by SGS operators when using the EOPs.The phrase "due to actual loss of secondary heat sink and heat sink is required" has been added to avoid unnecessary classification when the EOP network intentionally places the operator in a Heat Sink-Red condition.

1-EOP-FRHS-1, Response to Loss of Secondary Heat Sink, Step 1 specifically directs the operator to exit this flowchart if total AFW flow less than 22E04 lb/hr due to operator actions. During the performance of certain procedures, it is possible that the SG level is below the narrow range and the total feed flow is throttled to less than the minimum AFW flow requirement.

If the feed flow is reduced due to operator action to minimize feed flow and the capability of providing the minimum feed flow is available (i.e., pumps and valves in the Feedwater System are capable of being used if necessary), the functional restoration flowchart is not to be performed.

The phrase "and heat sink is required" implements the NEI 99-01 basis statement.

FC Primary Coolant Activity N/A P-Loss 2 Level Not Applicable FC Core Exit Thermocouple FB3-P 5 or more CETs > 700°F The EAL threshold of 5 or more CETs > 700'F is used in CFST P-Loss 3 Readings Core Cooling PURPLE path and represents a loss of subcooling.

A.. Core exit thermocouples reading greater than (site specific degree F).81 of 144 EAL Comparison Matrix OSSI -SGS NEI SGS NEI NEI IC Wording FPB SGS FPB Wording Difference/Deviation Justification FPB#f FPB #(s)FC Reactor Vessel Water Level FB4-P RVLIS < Table F-1 thresholds The NEI phrase "RCS/RPV" has been replaced with "RVLIS" to use P-Loss 4 A. RCS/RPV level less than terminology consistent with the CFSTs. TOAF is indicated by (site specific level for TOAF). RVLIS.The SGS-specific RCS/RPV level thresholds given in Table F-1 reflect the wording used for this condition in the SGS CFST Core Cooling PURPLE path.FC Not Applicable N/A P-Loss 5 Not Applicable FC Containment Radiation N/A P-Loss 6 Monitoring Not Applicable FC Other Site-Specific N/A None P-Loss Indications 7 A. (Site-specific) as applicable FC Emergency Director FB5-P ANY condition in the opinion of None P-Loss Judgment the Emergency Coordinator that 8 -Any condition in the opinion indicates potential loss of the of the Emergency Director Fuel Clad barrier that indicates Potential Loss of the Fuel Clad Barrier.82 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Matrix 0SSI -SGS Table F-I RVLIS Thresholds RVLIS RCPs Full Range 39% None 44% 4 30% 3 Dynamic Range 20% 2 13% 1 83 of 144 EAL Comparison Matrix OSSI -SGS RCS Fission Product Barrier Degradation Thresholds NEI SGS NEI IC Wording FPB SGS FPB Wording Difference/Deviation Justification FPB# FPB #(s)RCS Critical Safety Function Status N/A Loss 1 Not Applicable RCS RCS Leak Rate RB2-L Subcooling

_ 0°F (as a result of The NEI phrase "RCS leak rate..." has been replaced with "(as a Loss 2 A. RCS leak rate greater than RCS leakage) result of RCS leakage)" for simplification.

available makeup capacity as The NEI phrase "...greater than available makeup capacity as indicated by a loss of RCS indicated by a loss of..." has been deleted. As inferred in the NEI subcooling.

basis for this RCS barrier loss, it is evident from the context of the subcooling threshold that the RCS leakage exceeds the capacity of available makeup. If subcooling is lost (i.e., less than or equal to O0F), it is clear that its cause has been insufficient makeup capacity.The phrase is therefore unnecessary.

RCS Not Applicable N/A Loss 3 Not Applicable RCS SG Tube Rupture RB3-L SGTR requiring ECCS (SI) The NEI phrase "RUPTURED SG" has been replaced with "SGTR" Loss 4 A. RUPTURED SG results in an Actuation for simplification.

ECCS (SI) actuation.

The phrase "results in an ECCS (SI) actuation" has been changed to "requiring ECCS (SI) Actuation" for simplification.

RCS Not Applicable N/A N/A None Loss Not Applicable 5 84 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS NEI FPB#RCS Loss 6 NEI IC Wording SGS FPB #(s)SGS FPB Wording Difference/Deviation Justification Containment Radiation Monitoring A. Containment radiation monitor reading greater than (site specific value).RB1 -L ANY of the following Containment radiation monitor readings: " 1(2)R2> 1000 mR/hr" 1(2)R44A > 10 R/hr* 1(2)R44B > 10 R/hr The phrase "Any of the following" introduces this RCS Loss because there are more than two Containment radiation monitors capable of indicating the threshold setpoint.Per calculation by Nuclear Fuels Group file title DS1.6-0098"Verification of Emergency Action Levels for Event Classification" date 1/26/95, a reading of approximately 1 R/hr on Containment Rad Monitor 1(2R2), Containment High Range monitors 1(2)R44A and 1(2)R44B is indicative of the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with Technical Specifications concentrations into the Containment atmosphere.

130' Containment Area Rad Monitor 1(2)R2 has an instrument scale range of 0.1 mR/hr to 10 R/hr and, therefore, offers the preferred method of assessing this RCS barrier Loss.Containment High Range 1(2)R44 monitors have log scales with major increments in R/hr and are extremely inaccurate at this low value. Due to such readability limitations, the threshold value for these monitors has been increased to 10 R/hr, which is the first readable demarcation on the instrument scales.RCS Other Site-Specific Indications N/A None Loss 7 A. (Site-specific) as applicable RCS Emergency Director Judgment RB4-L ANY condition in the opinion of None Loss A. Any condition in the opinion the Emergency Coordinator that 8 of the Emergency Director indicates loss of the RCS barrier that indicates Loss of the RCS Barrier.85 of 144 EAL Comparison Matrix OSSI -SGS NEI ISGS NEI NEI IC Wording FPB SGS FPB Wording Difference/Deviation Justification FPB# FPB #(s)RCS P-Loss 1 Critical Safety Function Status A. RCS Integrity-Red Entry Conditions Met.OR B. Heat Sink-Red Entry Conditions Met.RB1-P CFST Thermal Shock RED path exists The abbreviation "CFST" means Critical Safety Function Status Tree and has been added for brevity and to improve clarity.The phrase "Thermal Shock" is the equivalent of the NEI phrase"RCS Integrity." The NEI phrase "Entry Conditions Met" has been changed to "path exists" for consistency with terminology used by SGS operators when using the EOPs. 4 RB2-P CFST Heat Sink RED entry conditions met due to actual loss of secondary heat sink and heat sink is required The abbreviation "CFST" means Critical Safety Function Status Tree and has been added for brevity and to improve clarity.The NEI phrase "Entry Conditions Met" has been changed to "path exists" for consistency with terminology used by SGS operators when using the EOPs.The phrase "due to actual loss of secondary heat sink and heat sink is required" has been added to avoid unnecessary classification when the EOP network intentionally places the operator in a Heat Sink-Red condition.

1-EOP-FRHS-1, Response to Loss of Secondary Heat Sink, Step 1 specifically directs the operator to exit this flowchart if total AFW flow less than 22E04 lb/hr due to operator actions. During the performance of certain procedures, it is possible that the SG level is below the narrow range and the total feed flow is throttled to less than the minimum AFW flow requirement.

If the feed flow is reduced due to operator action to minimize feed flow and the capability of providing the minimum feed flow is available (i.e., pumps and valves in the Feedwater System are capable of being used if necessary), the functional restoration flowchart is not to be performed.

The phrase "and heat sink is required" implements the NEI 99-01 basis statement.

86 of 144 EAL Comparison Matrix OSSI -SGS NEi SGS FPB# NEI IC Wording FPB #(s) SGS FPB Wording Difference/Deviation Justification RCS RCS Leak Rate RB3-P One Centrifugal Charging Pump The NEI phrase "RCS leak rate indicated greater than.. .with P-Loss 2 A. RCS leak rate indicated CANNOT maintain PZR level > Letdown isolated" has been changed to "One Centrifugal Charging greater than (site specific 17% as a result of RCS leakage Pump CANNOT maintain PZR level > 17% as a result of RCS capacity of one charging leakage." Significant leakage from the RCS requires implementation pump in the normal charging of OP-AB.RC-0001(Q), Reactor Coolant System Leak. Actions mode) with Letdown isolated.

required by this procedure specify the use of one Centrifugal Charging Pump, discharging to the charging header, and Letdown reduced to a minimum. If RCS leakage results in an inability to maintain the specified Pressurizer (PZR) level with a normal charging lineup and minimum Letdown flow using one Centrifugal Charging Pump, an RCS inventory loss is occurring that would require initiation of Reactor Trip and Safety Injection (SI) and entry into EOP-TRIP-1, Reactor Trip or Safety Injection.

This RCS Potential Loss assumes that any event that would result in significant RCS mass loss will require at least an Alert emergency classification.

When PZR level drops to 17%, Letdown isolates and pressurizer heaters are deenergized.

RCS Not Applicable N/A P-Loss 3 Not Applicable RCS SG Tube Rupture N/A P-Loss 4 Not Applicable RCS Not Applicable N/A P-Loss 5 Not Applicable RCS Containment Radiation N/A P-Loss 6 Monitoring Not Applicable RCS Other Site-Specific Indications N/A None P-Loss 7 A. (Site-specific) as applicable 87 of 144 EAL Comparison Matrix OSSI -SGS NEI NEI IC Wording SGS SGS FPB Wording Difference/Deviation Justification FPB# FPB #(s)RCS P-Loss 8 Emergency Director Judgment RB4-P A. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.ANY condition in the opinion of the Emergency Coordinator that indicates potential loss of the RCS barrier None 88 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Matrix OSSI -SGS Containment Fission Product Barrier Degradation Thresholds NEI SGS FPB# NEI IC Wording FPB SGS FPB Wording Difference/Deviation Justification FPB#_ #(s)CNTMT Critical Safety Function Status N/A Loss Not Applicable 1 CNTMT Containment Pressure CB1-L A Containment pressure rise The NEI threshold has been divided into two SGS thresholds to Loss A. A containment pressure rise followed by a rapid unexplained improve clarity.2 followed by a rapid drop in Containment pressure unexplained drop in containment pressure.OR CB2-L Containment pressure or sump The NEI threshold has been divided into two SGS thresholds to level response NOT consistent improve clarity.B. Containment pressure or wt OAcniin sump level response not consistent with LOCA conditions.

CNTMT Core Exit Thermocouple N/A Loss Readings 3 Not applicable CNTMT SG Secondary Side Release CB3-L RUPTURED SG that is also The NEI threshold has been divided into two SGS thresholds to Loss with P-to-S Leakage FAULTED outside of improve clarity.4 A. RUPTURED SG is also Containment The term "that" has been added to improve readability.

FAULTED outside of containment.

OR 89 of 144 EAL Comparison Matrix 0551 -SOS EAL Comparison Matrix OSSI -SGS NEI SGS FPB# NEI IC Wording FPB SGS FPB Wording Difference/Deviation Justification

(s)B. a. Primary-to-Secondary CB4-L Primary-to-secondary leakrate > The NEI threshold has been divided into two SGS thresholds to leakrate greater than 10 25 gpm improve clarity.gpm.AND AND UNISOLABLE steam release b. UISOLBLE teamfrom affected SO to the release from affected SG eroment to the environment.

CNTMT Containment Isolation Failure CB5-L Failure of ALL valves in ANY Note 8 has been added to the SGS threshold for clarification.

Loss or Bypass one line to close 5 A. a. Failure of all valves in AND any one line to close. Direct downstream pathway to AND the environment exists after b. Direct downstream Containment isolation signal pathway to the (Note 8)environment exists after Note 8: A direct release is a containment isolation pathway from the signal. Containment to any environment outside the Containment when Containment or system isolation is required due to: a safety injection signal, Containment pressure greater than 4 psig, or a VALID Containment ventilation isolation signal and the pathway cannot be isolated from the Control Room.90 of 144 EAL Comparison Matrix OSSI -SGS NEI SGS FPB# NEI IC Wording FPB SGS FPB Wording Difference/Deviation Justification

(s)CNTMT Containment Radiation N/A Loss Monitoring 6 Not Applicable CNTMT Other Site-Specific Indications N/A None Loss A. (Site-specific ) as applicable 7 CNTMT Emergency Director Judgment CB6-L ANY condition in the opinion of None Loss A. Any condition in the opinion of the Emergency Coordinator that 8 the Emergency Director that indicates loss of the Containment indicates Loss of the barrier Containment Barrier.CNTMT Critical Safety Function Status CB1-P CFST Containment RED path The abbreviation "CFST" means Critical Safety Function Status P-Loss exists Tree and has been added for brevity and to improve clarity.A. Containment-Red Entry 1 Conditions Met. The NEI phrase "Entry Conditions Met" has been changed to "path exists" for consistency with terminology used by SGS operators when using the EOPs.CNTMT Containment Pressure CB6-P Containment pressure > 47 psig The NEI threshold has been divided into three SGS thresholds to P-Loss A. Containment pressure greater and rising improve clarity.2 than (site specific value) and The Containment pressure setpoint (47 psig is the Containment rising, internal design pressure) ensures that Containment leakage does OR not exceed design basis limits and is consistent with the setpoint B. Explosive mixture exists value used in CFST Containment RED.inside containment.

91 of 144 EAL Comparison Matrix 0551- SGS EAL Comparison Matrix OSSI -SGS NEI SGS FPB# NEI IC Wording FPB SGS FPB Wording Difference/Deviation Justification-

(s)OR CB7-P Indications of > 4% H 2 inside The NEI threshold has been divided into three SGS thresholds to C. a. Pressure greater than Containment improve clarity.containment Containment hydrogen concentration of 4% is the minimum depressurization concentration associated with an explosive mixture.actuation setpoint.actn The threshold has been reworded to agree with the explosive AND mixture Containment Challenge condition of EAL CG3.1.b. Less than one full train of depressurization CB8-P Containment pressure > 15 psig The NEI threshold has been divided into three SGS thresholds to equipment operating.

AND improve clarity.The word "Containment" has been added to the plant threshold for EITHER of the following:

clarification." NO Containment Spray Train The Containment pressure setpoint (15 psig) is the Containment in service depressurization actuation setpoint.AND The combination of Containment spray subsystems and<5 CFCUs running in low Containment Fan Coil Units that constitute one full train of speed depressurization equipment has been specified for clarification." One Containment Spray Train in service AND< 3 CFCUs running in low speed CNTMT Core Exit Thermocouple CB3-P 5 or more CETs > 1200OF The NEI threshold has been divided into two SGS thresholds to P-Loss Readings AND improve clarity.3 A. a. Core exit thermocouples Restoration procedure 1(2)-EOP- "CETs" is the SGS equivalent of NEI "Core exit thermocouples." in excess of (site specific)

FRCC-1 NOT effective within 15 EOP-FRCC-1, Response to Inadequate Core Cooling, is the SGS 0 F. minutes functional restoration procedure associated with this condition.

AND b. Restoration procedures not effective within 15 92 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS NEI SGS FPB# NEI IC Wording FPB SGS FPB Wording Difference/Deviation Justification

(s)minutes. CB4-P ALL of the following:

The NEI threshold has been divided into two SGS thresholds to O 5 or more CETs > 700°F improve clarity.B. a Core exit thermocouples "CETs" is the SGS equivalent of NEI "Core exit thermocouples." in excess of (site-specific)

RVLIS < Table F-1 F. thresholds 700'F is the SGS specific temperature corresponding to Core Cooling Critical Safety Function Status Tree (CFST) RED or AND o Restoration procedurePU LE b. Reactor vessel level EOP-FRCC-1 NOT effective PURPLE.below (site specific level), within 15 minutes The SGS-specific Reactor Vessel level thresholds corresponding to AND core uncovery are given in Table F-1 and reflect the wording used for this condition in the SGS CFST Core Cooling PURPLE path.c. Restoration procedures EOP-FRCC-1, Response to Inadequate Core Cooling, is the SGS-_not-effective within 15 functional restoration procedure associated with this condition.

minutes.CNTMT SG Secondary Side Release N/A P-Loss with P-to-S Leakage 4 Not applicable CNTMT Containment Isolation Failure N/A P-Loss or Bypass 5 Not Applicable CNTMT Containment Radiation CB5-P Containment radiation monitor Per calculation by Nuclear Fuels Group file title DS1 .6-0098 P-Loss Monitoring 1(2)R44A or 1(2)R44B reading > "Verification of Emergency Action Levels for Event Classification" 6 A. Containment radiation monitor 2000 R/hr date 1/26/95, a reading of 2000 R/hr on Containment High Range reading greater than (site monitor 1(2)R44A or 1(2)R44B is indicative of 20% fuel clad specific value), damage.93 of 144 EAL Comparison Matrix OSSI -SGS NEI SGS FPB# NEI IC Wording FPB SGS FPB Wording Difference/Deviation Justification

(s)CNTMT Other Site-Specific Indications CB2-P CFST Core Cooling RED path This "other" Containment Barrier potential loss has been added for P-Loss A. (Site-specific) as applicable exists clarification.

Containment Barrier potential losses CB3-P and CB4P 7 AND prescribe the conditions indicative of a CFST Core Cooling RED path and restoration procedures not effective.

Restoration procedure EOP-FRCC-1 NOT effective within 15 minutes CNTMT Emergency Director Judgment CB9-P ANY condition in the opinion of None P-Loss A. Any condition in the opinion of the Emergency Coordinator that 8 the Emergency Director that indicates potential loss of the indicates Potential Loss of the Containment barrier Containment Barrier.94 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix 0SSI -SGS Category H Hazards and Other Conditions Affecting Plant Safety 95 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification HU1 Natural or destructive phenomena HU1 Natural or destructive phenomena affecting None affecting the PROTECTED AREA the PROTECTED AREA MODE: All MODE: All NEI Ex. SGS EAL # NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification I Seismic event identified by ANY 2 HUI.1 Seismic event identified by ANY two of the The phrase "by Control Room Operators" has been added of the following:

following:

for clarification.

The NEI basis defines a felt earthquake as one having been "recognized as an earthquake based on* Seismic event confirmed

° Earthquake felt in plant by Control a consensus of control room operators on duty at the by (site specific indication Room Operators time." or method)) .SMA-3 Event Indicator (flag) white SMA-3 flag is the SGS specific method of confirming a felt* Earthquake felt in plant

National Earthquake Information earthquake." National Earthquake Center (NEIC) (Note 4) The NEI phrase "National Earthquake Center" has been Center Note 4: The NEIC can be contacted by changed to "National Earthquake Information Center calling (303) 273-8500.

Select (NEIC)" to reflect the proper title of this organization.

option #1 and inform the analyst Note 4 provides guidance for contacting the NEIC and you wish to confirm recent seismic obtaining confirmation of seismic activity at the SGS/SGS activity in the vicinity of site.Salem/Hope Creek Generating Station. Provide the analyst with the following coordinates:

390 27'46" (39.4650) north latitude, 750 32'08" (75.5370) west longitude.

2 Tornado striking within HU1.2 Tornado TOUCHING DOWN within the The NEI term "striking" has been changed to "TOUCHING PROTECTED AREA boundary or PROTECTED AREA DOWN" for clarification and consistency with the NEI high winds greater than (site OR basis definition of "striking." specific mph). AThe design wind velocities are 108 mph (including a gust Average Wind Speeds > 95 MPH from factor of approximately 1.3) at 30 feet above ground for Seismic Category I structures.

However, wind speed 96 of 144 EAL Comparison Matrix OSSI -SOS EAL Comparison Matrix OSSI -SGS indication is limited to 100 mph in the Control Room so the wind speed threshold has been capped at 95 mph to provide margin to the upper limit of the indicated range.The phrase "Average Wind Speeds... .from ANY elevation of the Met Tower" has been added to clarify the sources from which wind speed information may be obtained.

The SPIDS display provides wind speed readings on a 15-minute average.3 Internal flooding that has the potential to affect safety related equipment required by Technical Specifications for the current operating mode in ANY of the following areas: (site specific area list)HU1.4 Internal Flooding that has the potential to affect safe shutdown systems or components required by Technical Specifications for the current operating mode in ANY Table H-1 plant structure The SGS (site-specific) areas of the plant are listed in Table H-1.Turbine failure resulting in casing HU1.3 Main Turbine rotating component failures The NEI phrase "Turbine" has been changed to "Main penetration or damage to turbine resulting in EITHER of the following:

Turbine" for clarification.

or generator seals

Main Turbine casing penetration The NEI term "failure" has been expanded to "Main Turbine rotating component failures" for consistency with o Main Turbine or Generator Seal the NEI basis that discusses the concerns associated with Damage main turbine rotor failures.(Site specific occurrences HU1.5 River level > 99.5' River level greater than 99.5' (+10.5' MSL) is indication of affecting the PROTECTED AREA) OR impending site flood conditions.

River level < 80.0' (-9.0'MSL) is indication of approaching River level < 80.0' loss of the Ultimate Heat Sink.97 of 144 EAL Comparison Matrix 055!- SGS EAL Comparison Matrix OSSI -SGS Table H-1 Plant Structures Containing Safe Shutdown Systems or Components

Auxiliary Building* Service Water Intake Structure" Control Point Area" Inner/Outer Penetration Areas* Containment

Fuel Handling Building" Service Building* RWST, PWST, and AFWST Area 98 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s)HU2 FIRE within the PROTECTED HU2 FIRE within the PROTECTED None AREA not extinguished within 15 AREA not extinguished within 15 minutes of detection or minutes of detection or EXPLOSION within the EXPLOSION within the PROTECTED AREA. PROTECTED AREA MODE: All MODE: All NEI Ex. NESxmlGASWrig EL ~ SG A odn ENEI Example EAL Wording SGS EAL Wording Difference/Deviation Justification EAL # EAL #FIRE not extinguished within 15 HU2.1 FIRE NOT extinguished within 15 The NEI phrase "control room notification or verification of a control minutes of control room minutes of EITHER of the room FIRE alarm" has been reformatted with minor wording changes notification or verification of a following:

for clarification control room FIRE alarm in ANY of the following areas:

Control Room The NEI bases has been modified to better define when the 15-notification/report of a FIRE minute EAL Assessment clock starts for (1) cases that include the receipt of nearby independent fire alarms and (2) cases that involve (Site-specific area list) 9 Verified FIRE detection only a single alarm where on-scene fire confirmation would be the system alarm/actuation threshold used to start the 15-minute EAL assessment clock. This is Note: The Emergency Director AND a potential deviation from NEI 99-01 Revision 5.should not wait until the applible notie hast FE ie lThe phrase "...the Turbine Building or ANY Table H-I..." has been a p p lic a b le tim e h a s F IR E is lo c a te d in th e T u rb in ea d e f o c o s t n y wi h h e N I b is h t i d c t s t e A elapsed, but should Building or ANY Table H-I plant added for consistency with the NEI basis that indicates the EAL declare the event as soon structure (Note 3) applies to fires in vital areas or areas immediately adjacent to vital as it is determined that the areas or other significant buildings or areas. Table H-1 lists plant Note 3: The Emergency structures containing safe shutdown systems or components.

These duration has exceeded, or will likely exceed, the Coordinator should NOT are vital areas and areas immediately adjacent to vital areas and applicable time. wait until the applicable other significant buildings and areas.time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.99 of 144 EAL Comparison Matrix OSSI -SGS 2 EXPLOSION within the HU2.2 EXPLOSION within the None PROTECTED AREA. PROTECTED AREA Table H-1 Plant Structures Containing Safe Shutdown Systems or Components

Auxiliary Building* Service Water Intake Structure* Control Point Area* Inner/Outer Penetration Areas* Containment

Fuel Handling Building" Service Building* RWST, PWST, and AFWST Area 100 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s) SSI odn HU3 Release of toxic, corrosive, HU3 Release of toxic, corrosive, None asphyxiant, or flammable gases asphyxiant or flammable gases deemed detrimental to NORMAL deemed detrimental to NORMAL PLANT OPERATIONS PLANT OPERATIONS MODE: All MODE: All NEIExapleEALWoring SGS NEI Example EAL Wording EA# SGS EAL Wording Difference/Deviation Justification Toxic, corrosive, asphyxiant or HU3.1 Release of toxic, corrosive, The phrase "(excluding small or incidental releases)" has been flammable gases in amounts that asphyxiant or flammable gas in added to the SGS EAL for clarification consistent with the EAL basis have or could adversely affect amounts (excluding small or .The NEI basis for this EAL states: "This would preclude small or NORMAL PLANT OPERATIONS incidental releases) that have or incidental releases, or releases that do not impact structures needed could adversely affect NORMAL for plant operation." PLANT OPERATIONS Report by Local, County or State HU3.2 Notification by Local, County, or The NEI term "Report" has been replaced with "Notification" for Officials for evacuation or State Officials for evacuation or consistency with use of the term "Notification" in EALs HU4.1 and sheltering of site personnel based sheltering of site personnel HA4.1.on an offsite event based on an off-site gas release The NEI phrase "offsite event" has been replaced with "off-site gas event that includes toxic, release event that includes toxic, corrosive, asphyxiant, or corrosive, asphyxiant, or flammable gas" to clarify the type of events intended to be classified flammable gas under this EAL by the NEI IC wording and NEI basis discussion.

101 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification HU4 Confirmed SECURITY HU4 Confirmed SECURITY None CONDITION or threat which CONDITION or threat which indicates a potential degradation indicates a potential degradation in the level of safety of the plant in the level of safety of the plant MODE: All MODE: All NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #1 A SECURITY CONDITION that HU4.1 A SECURITY CONDITION that The NEI Example EALs have been combined in one plant EAL.does NOT involve a HOSTILE does NOT involve a HOSTILE. .doesNOTinvlvea HSTIE dos NT ivole aHOSILE The "Security Shift Supervision" is the Security Operations ACTION as reported by the (site ACTION as reported by the Serity sifSeri specific security shift supervision)

Security Operations Supervisor Supervisor or designee.or designee (Note 8) The NEI phrase "A credible.. .security threat notification" has been 2 A credible site specific security changed to "Receipt of a CREDIBLE/ACTUAL THREAT...

-threat notification (determined by security in accordance with SY-AA-1 01-132, "Threat 3 A validated notification from NRC Receipt of a Assessment")" for clarification.

Threats are evaluated by security ovalidad infotiation ofr anR CREDIBLE/ACTUAL THREAT per Threat Assessment, SY-AA-101-132.

providing information of an to Salem or Hope Creek station Changed the NEI phrase "site specific" to "Salem or Hope Creek aircraft threat -(determined by security in station" to clarify the intent of the EAL as described in the NEI accordance with SY-AA-1 01- basis.132, "Threat Assessment") (Note 8) Added the phrase "Salem/Hope Creek" to the third threshold to clarify the intent of the EAL as described in the NEI basis and for OR consistency with the use of "site-specific" in the second NEI A VALIDATED notification from Example EAL.NRC providing information of a Added Note 8 to provide guidance to implement immediate security Salem/Hope Creek AIRCRAFT based response actions prior to declaring the security based threat (Note 8) emergency and to obtain critical information of the nature of the NOTE 9: Shift Manager (SM) security event.should implement the Prompt Actions of NC.EP-EP.ZZ-0102, EC Response, Attachment 10, prior to classification of a 102 of 144 EAL Comparison Matrix OSSI -SGS security emergency.

Key Information to obtain from Security Supervision upon SM notification of a security event: " Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION* If a HOSTILE ACTION, is location the OCA or PA?103 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification HU5 Other conditions exist which in the HU6 Other conditions exist which in The NEI abbreviation "NOUE" has been changed to "UNUSUAL judgment of the Emergency the judgment of the Emergency EVENT" for consistency with other EAL terminology associated with Director warrant declaration of a Coordinator warrant declaration the titles of emergency classification levels.NOUE of an UNUSUAL EVENT MODE: All MODE: All NEI Ex. NEI Example EAL Wording SGSSGS EAL Wording Difference/Deviation Justification EAL # EAL #Other conditions exist which in the HU6.1 Other conditions exist which in None judgment of the Emergency the judgment of the Emergency Director indicate that events are Coordinator indicate that events in progress or have occurred are in progress or have occurred which indicate a potential which indicate a potential degradation of the level of safety degradation of the level of safety of the plant or indicate a security of the plant or indicate a security threat to facility protection has threat to facility protection has been initiated.

No releases of been initiated.

NO releases of radioactive material requiring off- radioactive material requiring off-site response or monitoring are site response or monitoring are expected unless further expected unless further degradation of safety systems degradation of safety systems occurs. occurs 104 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording s) SGS IC Wording Difference/Deviation Justification IC#(s) SSI odn HA1 Natural or destructive phenomena HA1 Natural or destructive None affecting VITAL AREAS phenomena affecting vital areas MODE: All MODE: All NEI Ex. SGS W E NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification 1 a. Seismic event greater than Operating Basis Earthquake (OBE) as indicated by (site specific seismic instrumentation) reading (site specific OBE limit).AND b. Earthquake confirmed by ANY of the following:

Earthquake felt in plant* National Earthquake Center* Control Room indication of degraded performance of systems required for the safe shutdown of the plant.HA1.1 Actuation of the Hope Creek OBE Seismic Switch (> 0.1g)has occurred as verified by the Hope Creek Shift Manager AND Earthquake confirmed by ANY of the following: " Earthquake felt in plant by Control Room Operators" National Earthquake Information Center (NEIC)(Note 4)" Control Room indication of DEGRADED PERFORMANCE of safe shutdown systems Note 4: The NEIC can be contacted by calling (303) 273-8500.

Select option #1 and inform the analyst you wish to confirm recent seismic activity in the vicinity of Salem/Hope Creek The SGS seismic instrumentation does not provide real-time indication of exceeding the OBE seismic threshold.

SGS must rely on notification from Hope Creek which has real-time indications of the OBE seismic trigger being actuated.

See HCGS EAL HA1.1.The phrase "by Control Room Operators" has been added for clarification.

The NEI basis for IC HU1 defines a felt earthquake as one having been "recognized as an earthquake based on a consensus of control room operators on duty at the time." The NEI phrase "National Earthquake Center" has been changed to "National Earthquake Information Center (NEIC)" to reflect the proper title of this agency.The NEI phrase "systems required for safe shutdown of the plant" has been changed to "safe shutdown systems." Note 4 provides guidance for contacting the NEIC and obtaining confirmation of seismic activity at the SGS/SGS site.105 of 144 EAL Comparison Matrix OSSI -SGS Generating Station.Provide the analyst with the following coordinates:

390 27' 46" (39.4650) north latitude, 750 32' 08" (75.537-)west longitude.

2 Tornado striking or high winds HA1.2 Tornado TOUCHING DOWN The NEI term "striking" has been changed to "TOUCHING DOWN" greater than (site specific mph) within the PROTECTED AREA for clarification and consistency with the NEI basis definition of resulting in VISIBLE DAMAGE to OR "striking." ANY of the following structures The design wind velocities are 108 mph (including a gust factor of componentainingsafet ORc olroo M froe AinY Spelev n of te approximately 1.3) at 30 feet above ground for Seismic Category I components OR control room MPH from ANY elevation of the structures.

However, wind speed indication is limited to 100 mph in indication of degraded performance Met Tower the Control Room so the wind speed threshold has been capped at of those safety systems: AND 95 mph to provide margin to the upper limit of the indicated range.(site specific structure list) Resulting in EITHER of the The phrase "Average Wind Speeds.. .from ANY elevation of the following:

Met Tower" has been added to clarify the sources from which wind speed information may be obtained.

The SPDS display provides D Control Room indication of wind speed readings on a 15-minute average.DEGRADED PERFORMANCE of a Table H-1 contains the site specific structure list.Safety System The NEI phrase "those safety systems" has been changed to "a" VISIBLE DAMAGE to ANY Safety System" because it is clear from the introductory phrase of the plant structures in "Resulting in..." that the degraded performance applies only to a Table H-1 safety system affected by the tornado or high winds.3 Internal flooding in ANY of the HA1.4 Internal Flooding in ANY Table The SGS (site-specific) areas of the plant are listed in Table H-1.following areas resulting in an H-1 plant structure The NEl phrase "resulting in" has been changed to "AND The electrical shock hazard that TeNIprs rsligi"hsbe hne o"N h prectcludshc hac tohoperate oAND Flooding is of a magnitude that results in EITHER of the following" precludes access to operate or f rcaii ai n monitor safety equipment OR The Flooding is of a magnitude control room indication of degraded that results in EITHER of the The NEI phrase "an electrical shock hazard" has been changed to performance of those safety following: "An Industrial Safety Hazard (Electrical Shock, High Temp, etc.)" systems: for clarification and consistency with the NEI basis that explicitly (site specific area list) Indication of DEGRADED cites electrical shock as only one of many possible industrial safety SaPERFORMANCE of a hazards that could preclude personnel access to operate or Safety System within a mntreupet Table H-1 Structure.

106 of 144 EAL Comparison Matrix OSSI -SGS An Industrial Safety Hazard The NEI phrase "those safety systems" has been changed to (Electrical Shock, High "Safety System equipment" because it is clear from the Temp, etc.) resulting in introductory phrase "The Flooding is of a magnitude that results access restrictions to in..." that the degraded performance applies only to safety system operate or monitor Safety equipment affected by flooding.System equipment.

4 Turbine failure-generated HA1.3 Turbine failure-generated Added "...ANY Table H-1 plant structures" to be consistent with PROJECTILES resulting in VISIBLE PROJECTILES resulting in the generic NEI 99-01 bases that the EAL is intended to address DAMAGE to or penetration of ANY EITHER of the following:

visible damage to structures/equipment "containing functions and of the following structures containing systems required for safe shutdown." Table H-1 is titled "Plant safety systems or components OR ° VISIBLE DAMAGE to or Structures Containing Safe Shutdown Systems or Components." control room indication of degraded penetration of ANY Table performance of those safety H-1 plant structures The NEI phrase "those safety systems" has been changed to "safe shutdown systems" to be consistent with the NEI bases intent. It is systems:

Control Room indication of clear from the introductory phrase "...resulting in EITHER..." that (sitespecific structure list) DEGRADED the safety systems of concern are those affected by the projectiles.

PERFORMANCE of safe shutdown systems 5 Vehicle crash resulting in VISIBLE HA1.6 Vehicle Crash or PROJECTILE The phrase "or PROJECTILE Impact" has been added to the DAMAGE to ANY of the following Impact with or within ANY Table vehicle crash threshold as a "site specific occurrence" allowed by structures containing safety systems H-1 Structure NEI Example EAL #6. Projectiles could be generated from events or components OR control room such as a boat explosion in the river, a compressed gas cylinder indication of degraded performance AND ejected during a vehicle crash, objects jettisoned from aircraft, a of those safety systems: The Vehicle Crash or tornado touching down outside the protected area, etc.PROJECTILE Impact results in Table H-1 contains the site specific structure list.(site specific structure list) of the following:

The NEI phrase "those safety systems" has been changed to "a 9 Control Room indication of Safety System" to be consistent with the NEI bases intent. It is DEGRADED clear from the introductory phrase "...results in EITHER..." that the 6 (Site specific occurrences) resulting PERFORMANCE of a safety systems of concern are those affected by the vehicle crash in VISIBLE DAMAGE to ANY of the Safety System within or projectile.

following structures containing Table H-I Structure safety systems or components OR 9 VISIBLE DAMAGE to ANY control room indication of degraded of the plant structures in performance of those safety Table H-1 systems: (site specific structure list)107 of 144 EAL Comparison Matrix 0551- SGS EAL Comparison Matrix OSSI -SGS Table H-1 Plant Structures Containing Safe Shutdown Systems or Components

Auxiliary Building" Service Water Intake Structure" Control Point Area" Inner/Outer Penetration Areas" Containment

Fuel Handling Building" Service Building" RWST, PWST, and AFWST Area 108 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification HA2 FIRE or EXPLOSION affecting HA2 FIRE or EXPLOSION in a VITAL The phrase "in a VITAL AREA" has been added to the SGS IC the operability of plant safety AREA affecting the operability of because safety systems required to establish or maintain safe systems required to establish or plant safety systems required to shutdown are located in vital areas.maintain safe shutdown establish or maintain safe MODE: All shutdown MODE: All NEI Ex. NESxmlGASWrig EL ~ SG A odn EAL # NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification 1 FIRE or EXPLOSION resulting HA2.1 FIRE in ANY Table H-1 plant The NEI EAL wording has been changed to agree with the IC in VISIBLE DAMAGE to ANY of structure affecting the operability wording which expresses concern for the operability of safety the following structures of plant safety systems required to systems instead of visible damage or degraded performance.

containing safety systems or establish or maintain safe The duration of a fire has been increased to 15 minutes or more for components OR control room shutdown consistency with EAL HU2.1 in which a fire extinguished within 15 performance of those safety AND minutes is not detrimental and does not require emergency perfrmane o thoe saetyclassification.

systems: _> 15 minutes have elapsed (Note (site specific structure list) 3) Vital Areas of concern during a fire or explosion are listed in Table Note 3: The Emergency H-1 plant structures.

Coordinator should NOT wait until Note 3 has been added for consistency with other EALs that specify the applicable time has elapsed, a timing duration.but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.HA2.2 EXPLOSION in ANY Table H-1 The example EAL has been broken into two separate EALs plant structure affecting the addressing fire and explosions consistent with the HU2,1 and HU2.2 operability of plant safety systems thresholds.

required to establish or maintain The NEI EAL wording has been changed to agree with the IC safe shutdown wording which expresses concern for the operability of safety systems instead of visible damage or degraded performance.

109 of 144 EAL Comparison Matrix OSSI -SGS Vital Areas of concern during a fire or explosion are listed in Table H-1 plant structures.

Table H-1 Plant Structures Containing Safe Shutdown Systems or Components

Auxiliary Building* Service Water Intake Structure* Control Point Area* Inner/Outer Penetration Areas" Containment

Fuel Handling Building" Service Building* RWST, PWST, and AFWST Area 110 of 144 EAL Comparison Matrix OSSI- SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s)HA3 Access to a vital area is HA3 Access to a VITAL AREA is None prohibited due to toxic, corrosive, prohibited due to toxic, corrosive, asphyxiant or flammable gases asphyxiant or flammable gases which jeopardize operation of which jeopardize operation of operable equipment required to operable equipment required to maintain safe operations or maintain safe operations or safely safely shutdown the reactor shut down the reactor MODE: All MODE: All NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #Access to a VITAL AREA is HA3.1 Access to ANY Table H-1 plant Table H-1 provides the site-specific list of structures containing prohibited due to toxic, corrosive, structure is prohibited due to equipment necessary for safe shutdown.asphyxiant or flammable gases toxic, corrosive, asphyxiant, or The NEI phrase "a VITAL AREA" has been replaced with "ANY which jeopardize operation of flammable gases which Table H-1 plant structure" for consistency with other Hazards EALs.systems required to maintain safe jeopardize operation of systems operations or safely shutdown the required to maintain safe reactor. operations or safely shut down Note: If the equipment in the the reactor (Note 5)stated area was already Note 5: If the equipment in the inoperable, or out of service, stated area was already before the event occurred, then inoperable, or out of this EAL should not be declared service, before the event as it will have no adverse impact occurred, then this EAL on the ability of the plant to safely should NOT be declared operate or safely shutdown as it will have NO beyond that already allowed by adverse impact on the Technical Specifications at the ability of the plant to time of the event. safely operate or safely shut down beyond that already allowed by Technical Specifications 111 of 144 EAL Comparison Matrix OSSI -SGS I I I I at the time of the event.112 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s)HA4 HOSTILE ACTION within the OWNER HA4 HOSTILE ACTION within the OWNER None CONTROLLED AREA or airborne attack CONTROLLED AREA or airborne attack threat threat MODE: All NEI Ex. SGS EA NEI Example EAL Wording EAL SGS EAL Wording Difference/Deviation Justification EAL # EAL #1 A HOSTILE ACTION is occurring or has HA4.1 A HOSTILE ACTION is occurring or has Example EALs #1 and #2 have been combined into occurred within the OWNER occurred within the OCA as reported by a single EAL for usability.

CONTROLED AREA as reported by the the Security Operations Supervisor or The "Security Shift Supervision" is the Security (site specific security shift supervision), designee (Note 8) Operations Supervisor or designee.2 A validated notification from NRC of an OR The NEI phrase "of the site" has been changed to airliner attack threat within 30 minutes of A VALIDATED notification from NRC of a "away from Salem/Hope Creek" to clarify the intent the site AIRLINER attack threat < 30 minutes of the EAL as described in the NEI basis.away from Salem/Hope Creek (Note 8) Added Note 8 to provide guidance to implement NOTE 9: Shift Manager (SM) should immediate security based response actions prior to implement the Prompt Actions of NC.EP- declaring the security based emergency and to EP.ZZ-0102, EC Response, Attachment obtain critical information of the nature of the 10, prior to classification of a security security event.emergency.

Key Information to obtain from Security Supervision upon SM notification of a security event: " Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION" If a HOSTILE ACTION, is location the OCA or PA?113 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification HA5 Control room evacuation has HA5 Control Room evacuation has been None been initiated initiated MODE: All MODE: All NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #1 (Site-specific procedure)

HA5.1 Control Room evacuation has been Reference to plant procedures has been eliminated.

The requires control room evacuation, initiated intent of the EAL is that an evacuation of the Control Room has begun for any reason. This change is addressed in NEI/NRC FAQ #28.114 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification HA6 Other conditions exist which in the HA6 Other conditions exist which in the None judgment of the Emergency judgment of the Emergency Coordinator Director warrant declaration of an warrant declaration of an ALERT Alert MODE: All MODE: All NEI Ex. SGS EA E NEI Example EAL Wording EAL SGS EAL Wording Difference/Deviation Justification EAL # EAL #Other conditions exist which in the HA6.1 Other conditions exist which in the None judgment of the Emergency judgment of the Emergency Coordinator Director indicate that events are in indicate that events are in progress or progress or have occurred which have occurred which involve an actual or involve an actual or potential potential substantial degradation of the substantial degradation of the level of safety of the plant or a security level of safety of the plant or a event that involves probable life security event that involves threatening risk to site personnel or probable life threatening risk to damage to site equipment because of site personnel or damage to site Hostile Action. ANY releases are equipment because of HOSTILE expected to be limited to small fractions ACTION. Any releases are of the EPA Protective Action Guideline expected to be limited to small exposure levels fractions of the EPA Protective Action Guideline exposure levels.115 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification HS2 Control room evacuation has been HS5 Control Room evacuation has been None initiated and plant control cannot initiated and plant control CANNOT be be established established MODE: All MODE: All NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #a. Control room evacuation has HS5.1 Control Room evacuation has been 15 minutes is the site-specific interval to establish plant been initiated, initiated control following Control Room evacuation.

AND AND Reference to Note 3 has been added to the SGS EAL for b. Control of the plant cannot be Control of the plant CANNOT be consistency with other NEI EALs with a timing component.

established within (site established within 15 minutes (Note 3)specific minutes).Note 3: 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 will likely exceed the applicable time.116 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording ls) SGS IC Wording Difference/Deviation Justification IC#(s) SSI odn HS3 Other conditions exist which in HS6 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 SITE AREA Site Area Emergency EMERGENCY MODE: All MODE: All NEI Ex. SGS NEI Example EAL Wording EAL SGS EAL Wording Difference/Deviation Justification EAL# EAL#Other conditions exist which in HS6.1 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)personnel or equipment that could that prevent effective access to lead to the likely failure of or; (2) equipment needed for the protection of that prevent effective access to the public. ANY releases are NOT equipment needed for the expected to result in exposure levels protection of the public. Any which exceed EPA Protective Action releases are not expected to Guideline exposure levels beyond the result in exposure levels which site boundary exceed EPA Protective Action Guideline exposure levels beyond the site boundary 117 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification HS4 HOSTILE ACTION within the HS4 HOSTILE ACTION within the None PROTECTED AREA PROTECTED AREA MODE: All MODE: All NEI Ex. NIEapeELWrig SGS ENEI Example EAL Wording SGS EAL Wording Difference/Deviation Justification EAL # EAL #A HOSTILE ACTION is occurring HS4.1 A HOSTILE ACTION is occurring or has The "Security Shift Supervision" is the Security Operations or has occurred within the occurred within the PROTECTED AREA Supervisor or designee.PROTECTED AREA as reported as reported by the Security Operations Added Note 8 to provide guidance to implement immediate by the (site security shift Supervisor or designee (Note 8) security based response actions prior to declaring the supervision).

security based emergency and to obtain critical information NOTE 9: Shift Manager (SM) should of the nature of the security event.implement the Prompt Actions of NC.EP-EP.ZZ-0102, EC Response, Attachment 10, prior to classification of a security emergency.

Key Information to obtain from Security Supervision upon SM notification of a security event: " Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION" If a HOSTILE ACTION, is location the OCA or PA?118 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification HG1 HOSTILE ACTION resulting in HG4 HOSTILE ACTION resulting in loss of None loss of physical control of the physical control of the facility facility MODE: All MODE: All NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL # G A odn 1 A HOSTILE ACTION has HG4.1 A HOSTILE ACTION has occurred such The parenthetical examples of safety functions have been occurred such that plant that plant personnel are unable to added the SGS EAL to clarify the intent of the EAL as personnel are unable to operate operate equipment required to maintain discussed in the NEI basis.equipment required to maintain safety functions (i.e., reactivity control, The NEI phrase "...for a freshly off-loaded reactor core in safety functions.

RCS inventory, or secondary heat pool" has been deleted. This phrase is not a defined removal) at Salem or Hope Creek (Note condition for SGS nor is there any relevant guidance for flA HOSTILE ACTION has caused 8) defining such a phrase. The threshold as proposed would failure of Spent Fuel Cooling Systems and IMMINENT fuel OR require a General Emergency declaration for any hostile daction resulting in a loss of spent fuel cooling leading to damage is likely for a freshly off- A HOSTILE ACTION has caused failure imminent fuel damage, regardless of the amount of time the loaded reactor core in pool. of Spent Fuel Cooling Systems and fuel has been off-loaded.

This change is addressed in IMMINENT fuel damage is likely at NEI/NRC FAQ #29.Salem or Hope Creek (Note 8) The phrase "at Salem or Hope Creek" has been added to the NOTE 9: Shift Manager (SM) should two conditions of this EAL for clarification.

implement the Prompt Actions of NC.EP- Added Note 8 to provide guidance to implement immediate EP.ZZ-0102, EC Response, Attachment security based response actions prior to declaring the 10, prior to classification of a security security based emergency and to obtain critical information emergency.

of the nature of the security event.Key Information to obtain from Security Supervision upon SM notification of a security event:* Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION 119 of 144 EAL Comparison Matrix OSSI -SGS* If a HOSTILE ACTION, is location the OCA or PA?120 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Matrix OSSI -SGS NEI IC#NEI IC Wording SGS IC#(s)SGS IC Wording Difference/Deviation Justification I; I HG2 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency MODE: All HG6 Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of GENERAL EMERGENCY MODE: All None L ______ L __________________________________

I ___________________________________________________

NEI Ex. NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification Other conditions exist which in HG6.1 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 off-site for more than the expected to exceed EPA immediate site area Protective Action Guideline exposure levels off-site for more than the immediate site area.121 of 144 EAL Comparison Matrix OSSI -SGS Category S System Malfunction 122 of 144 EAL Comparison Matrix OSS1 -SGS EAL Comparison Matrix 0SSI -SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s)SUl Loss of all Off-site AC power to SUl Loss of all offsite AC power to "Vital buses" is equivalent to the NEI phrase "emergency buses." emergency busses for 15 minutes vital buses for 15 minutes or or longer. longer MODE: Power Operation, Startup, MODE: 1 -Power Operations, 2 -Hot Standby, Hot Shutdown Startup, 3 -Hot Standby, 4 -Hot Shutdown NEI Ex. NSGxmlSA Wrig EL ~ SG A odn EAL E NEI Example EAL WorSGding SEL SGS EAL Wording Difference/Deviation Justification Loss of all off-site AC power to SUl .1 Loss of all Offsite AC power to all 4KV vital buses are the SGS emergency buses.(site specific emergency busses) 4KV Vital Buses for 15 minutes or longer. AND Note: The Emergency Director ? 15 minutes have elapsed (Note should not wait until the applicable time has 3)elapsed, but should Note 3: The Emergency declare the event as soon Coordinator should NOT as it is determined that the wait until the applicable condition has exceeded, time has elapsed, but or will likely exceed, the should declare the event applicable time. as soon as it is determined that the condition will likely exceed the applicable time.123 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording lC#(s) SGS IC Wording Difference/Deviation Justification SU2 Inability to reach required SU4 Inability to reach required None shutdown within Technical shutdown within Technical Specification limits Specification limits MODE: Power Operation, MODE: 1 -Power Operations, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL # G 1 Plant is not brought to required SU4.1 Plant is NOT brought to required None operating mode within Technical operating mode within Technical Specifications LCO Action Specifications LCO action Statement Time. statement time 124 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording s) SGS IC Wording Difference/Deviation Justification IC#(s) SSI odn SU3 UNPLANNED loss of safety SU5 UNPLANNED loss of safety None system annunciation or indication system annunciation or indication in the control room for 15 minutes in the Control Room for 15 or longer. minutes or longer MODE: Power Operation, Startup, MODE: 1 -Power Operations, 2 -Hot Standby, Hot Shutdown Startup, 3 -Hot Standby, 4 -Hot Shutdown NEI SGS Ex. NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification EAL #1 1. UNPLANNED Loss of greater SU5.1 UNPLANNED loss of > Parts a and b of the NEI example EAL have been introduced with the than approximately 75% of the approximately 75% of Control phrase "UNPLANNED loss of..." for clarification.

following for 15 minutes or Room Overhead Annunciators for "Control Room Overhead Annunciators" are the NEI "Site specific longer: 2 15 minutes (Note 3) control room safety system annunciation." Each Overhead a. (Site specific control room OR Annunciator panel displays multiple annunciators associated with safety system annunciation)

UNPLANNED loss of> safety systems.ORUNLNEloso>

approximately 75% of Control Control Room indicators associated with the listed safety functions b. (Site specific control room Room Indications associated with are the NEI "Site specific control room safety system indication." safety system indication) the following safety functions for> SGS safety systems are designed to fulfill one or more of these 15 minutes (Note 3): safety functions.

Note: The Emergency Director

Reactivity Control should not wait until the applicable time has -RCS Inventory-elapsed, but should declare

Decay Heat Removal the event as soon as it is determined that the

Fission Product Barriers condition has exceeded, or Note 3:The Emergency will likely exceed, the Coordinator should NOT applicable time. Codntrsol O wait until the applicable time has elapsed, but should declare the event 125 of 144 EAL Comparison Matrix OSSI -SGS as soon as it is determined that the condition will likely exceed the applicable time.126 of 144 EAL Comparison Matrix 0551 -SGS EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification SU4 Fuel Clad degradation SU7 Fuel clad degradation None MODE: Power Operation, MODE: 1 -Power Operations, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification 1 (Site specific radiation monitor SU7.1 VALID Letdown Line Monitor Letdown Line Monitors serve as a failed fuel detector by monitoring readings indicating fuel clad readings indicating fuel clad gamma levels in the reactor coolant letdown line. Unit 1 (1R31A)degradation greater than degradation greater than EITHER letdown line monitor is a gross iodine monitor. The Unit 2 (2R31)Technical Specification of the following Technical letdown line monitor is an ion chamber which measures letdown allowable limits.) Specification allowable limits: line activity.

The Letdown Line Monitor "warning" setpoints are set S1R31 A in warning at 50% of the "alarm" setpoints.

2R31 in alarm 1 R31 A "alarm" setpoint is based on 1% failed fuel.2R31 "alarm" setpoint is based on 0.1% failed fuel.Technical specification coolant activity level is approximately equivalent to 0.1% failed fuel. To associate the Letdown Line Monitor readings with Technical Specification coolant activity levels, the "alarm" setpoint has been selected for 2R31. To use a readily identifiable setpoint for 1 R31A that approximates Technical Specification allowable limits, the "warning" setpoint has been selected.2 (Site specific coolant sample SU7.2 Reactor coolant activity (Dose The specified reactor coolant activity is given in SGS Technical activity value indicating fuel clad Equivalent Iodine) exceeds limits of Specifications 3.4.8 (Unit 1) and 3.4.9 (Unit 2) Figure 3.4-1 for degradation greater than Technical Specification Figure 3.4- transient iodine spiking.Technical Specification 1 allowable limits.)127 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification SU5 RCS leakage SU8 RCS leakage None MODE: Power Operation, MODE: 1 -Power Operations, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -Hot Shutdown Shutdown NEI Example EAL Wor(SGS EAL Wording Difference/Deviation Justification Unidentified or pressure boundary leakage greater than 10 gpm Identified leakage greater than 25 gpm UNIDENTIFIED LEAKAGE or PRESSURE BOUNDARY LEAKAGE > 10 gpm (Note 6)OR IDENTIFIED LEAKAGE > 25 gpm (Note 6)Note 6: See the Fission Product Barrier Table for possible escalation above the UNUSUAL EVENT due to RCS Leakage SU8.1 implements Example EALs #1 and #2. These were combined for improved usability.

Note 6 has been added to remind the EAL-user to review the Fission Product Barrier Table for possible escalation to higher emergency classifications due to RCS leakage.128 of 144 EAL Comparison Matrix 0551- SGS EAL Comparison Matrix OSSI -SGS NEI IC Wording SGS IC#(s)SGS IC Wording Difference/Deviation Justification Loss of all On-site or Off-site communications capabilities MODE: Power Operation, Startup, Hot Standby, Hot Shutdown SU6 Loss of all onsite or offsite communications capabilities MODE: 1 -Power Operations, 2 -Startup, 3 -Hot Standby, 4 -Hot Shutdown None NEI Ex. NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification E A L # Di f re c /D v at o Ju t f c t o 1 Loss of all of the following on- SU6.1 Loss of all Table S-2 Onsite SU6.1 implements Example EALs #1 and #2. These were combined site communication methods communication methods affecting for improved usability.

affecting the ability to perform the ability to perform routine The NEI example EALs specify site-specific lists of onsite and offsite routine operations.

operations communications methods. The SGS EAL lists these methods in (site specific list of OR Table S-2 for simplification.

communications methods) Loss of all Table S-2 Offsite communication methods affecting the ability to perform offsite 2 Loss of all of the following off- notifications site communication methods affecting the ability to perform offsite notifications.(site specific list of communications methods)129 of 144 EAL Comparison Matrix 0551- SGS EAL Comparison Matrix OSSI -SGS Table S-2 Communications Systems System Onsite Direct Inward Dial System (DID) X.............................................

................

.........................

...........................

.........................................................

...... .... .............................................................

Station Page System (Gaitronics)

X Station Radio System X Nuclear Emergency Telephone System (NETS)Centrex Phone System (ESSX)NRC (ENS)I 130 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording s) SGS IC Wording Difference/Deviation Justification SU8 Inadvertent criticality SU3 Inadvertent criticality None MODE: Hot Standby, Hot MODE: 3 -Hot Standby, 4 -Hot Shutdown Shutdown NEI Ex. NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification EAL # SGS DifrneDvaio#utfcto 1 UNPLANNED sustained positive N/A N/A NEI BWR Example EAL #1 has not been implemented because it period observed on nuclear applies only to BWR plants. SGS is a PWR.instrumentation.

[BWR]1 UNPLANNED sustained positive SU3.1 UNPLANNED sustained positive None startup rate observed on nuclear startup rate observed on nuclear instrumentation.

[PWR] instrumentation 131 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification SA2 Automatic Scram (Trip) fails to SA3 Automatic trip fails to shut down Scram is deleted to use terminology common to a PWR.shutdown the reactor and the the reactor and the manual manual actions taken from the actions taken from the reactor reactor control console are control console are successful in successful in shutting down the shutting down the reactor reactor MODE: 1 -Power Operations, 2 -MODE: Power Operation, Startup Startup NEI Ex. SGS EA NEI Example EAL Wording EAL SGS EAL Wording Difference/Deviation Justification EAL # EAL #1 a. An automatic scram (trip) SA3.1 An automatic trip failed to shut Scram is deleted to use terminology common to a PWR.failed to shutdown the down the reactor The NEI phrase "Manual actions" has been changed to "Manual trip reactor. AND actions" for clarification.

AND Manual trip actions taken at the The phrase "(reactor trip switches, trip bkr bezels, supply breakers b. Manual actions taken at the reactor control console (reactor 1/2E6D and 1/2G6D)" has been added the meaning of the NEI reactor control console trip switches, trip bkr bezels, phrase "Manual actions taken at the reactor control console." The successfully shutdown the supply breakers 1/2E6D and specified controls are located in the Control Room at adjacent reactor as indicated by (site 1/2G6D) successfully shut down panels in the center control console. The operator immediately specific indications of plant the reactor as indicated by performs these actions, as necessary, in response to all reactor trips shutdown).

reactor power < 5% per 1(2)-EOP-TRIP-1.

Following a successful reactor trip, a prompt drop in reactor power to subcriticality should occur. Site-specific indication of plant shutdown is reactor power less than 5% which equates to the criteria used to determine a valid CFST Shutdown Margin (Subcriticality) red path.132 of 144 EAL Corn panson Matr~x OSS~-SGS EAL Comparison Matrix OSSI,- SGS r 1 1 r NEI IC#NEI IC Wording SGS IC#(s)SGS IC Wording Difference/Deviation Justification F I -t SA4 UNPLANNED Loss of safety system annunciation or indication in the control room with EITHER (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable.

MODE: Power Operation, Startup, Hot Standby, Hot Shutdown SA5 UNPLANNED loss of safety system annunciation or indication in the Control Room with either (1)a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable MODE: 1 -Power Operations, 2 -Startup, 3 -Hot Standby, 4 -Hot Shutdown None_________a

____________________________

i _______ i ______________________________________________________________________________________

NEI SGS Ex. NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification EAL #a. UNPLANNED Loss of greater SA5.1 UNPLANNED loss of > Parts a and b of the NEI example EAL have been introduced with than approximately 75% of the approximately 75% of Control the phrase "UNPLANNED loss of..." for clarification.

following for 15 minutes or Room Overhead Annunciators for "Control Room Overhead Annunciators" are the NEI "Site specific longer: ? 15 minutes (Note 3) control room safety system annunciation." Each Overhead* (Site specific control room OR Annunciator panel displays multiple annunciators associated with safety system UNPLANNED loss of > safety systems.annunciation) approximately 75% of Control Control Room indicators associated with the listed safety functions OR Room Indications associated with are the NEI "Site specific control room safety system indication."" (Site specific control room the following safety functions for > SGS safety systems are designed to fulfill one or more of these safety system indication) 15 minutes (Note 3): safety functions.

b. EITHER of the following:

Reactivity Control Table S-1 provides the list of events that constitute a "significant , A SIGNIFICANT transient" as specified Table 4, above.TRANSIENT in progress

RCS Inventory The NEI term "unavailable" has been changed to "NOT available"* Compensatory indications

Decay Heat Removal for clarification.

are unavailable

Fission Product Barriers OP-AB.ANN-0001 (Q) provides guidance for determining Note: The Emergency Director compensatory Control Room indications.

should not wait until the AND applicable time has EITHER of the following:

133 of 144 EAL Comparison Matrix OSSI -SGS elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.* A SIGNIFICANT TRANSIENT is in progress, Table S-1" Compensatory indications are NOT available per OP-AB.ANN-0001 (Q)Note 3: 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 will likely exceed the applicable time.Table S-1 SIGNIFICANT TRANSIENTS

Automatic turbine runback > 25% thermal reactor power* Electrical load rejection

> 25% full electrical load" Reactor Trip* Safety Injection Activation 134 of 144 EAL Comparison Matrix 031 -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification SA5 AC power capability to SA1 AC power capability to vital "Vital buses" is equivalent to the NEI phrase "emergency buses." emergency busses reduced to a buses reduced to a single power The term "station blackout" was replaced with "complete loss of AC single power source for 15 source for 15 minutes or longer power to vital buses" as this describes the intended condition leading minutes or longer such that any such that any additional single to the Alert threshold in CA1.1. Station Blackout is not an additional single failure would failure would result in complete operationally defined term for loss of all AC to vital buses.result in station blackout.

loss of AC power to vital buses MODE: Power Operation, MODE: 1 -Power Operations, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -Hot Shutdown Shutdown NEI Ex. SGS EI E NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification EAL # A#1 a. AC power capability to (site- SA1.1 Loss of 4KV Vital Bus Power 4 KV vital buses are the SGS emergency buses.specific emergency busses) Sources (Offsite and Onsite) The NEI phrase "AC power capability to (site specific emergency reduced to a single power which results in the availability of busses) reduced to a single power source" has been changed to source for 15 minutes or only one 4KV Vital Bus Power "Loss of 4KV Vital Bus Power Sources (Offsite and Onsite) which longer. Source (Offsite or Onsite) results in the availability of only one 4KV Vital Bus Power Source AND AND (Offsite or Onsite)" to reflect the specific SGS vital power b. Any additional single power > 15 minutes have elapsed configuration.

source failure will result in (Note 3)station blackout.(Nt3)]

Note: The Emergency Director Note 3: The Emergency The AND logic used in NEI 99-01 is improper as the second should not wait until the Coordinator should NOT condition is not a separate condition of equal weight but rather a applicable time has wait until the applicable qualifier of the first. The threshold statement has been reworded to elapsed, but should time has elapsed, but properly reflect the intent.declare the event as should declare the event Station Blackout is not an operationally defined term for loss of all soon as it is determined as soon as it is AC to vital buses.that the condition has determined that the exceeded, or will likely condition will likely exceed, the applicable exceed the applicable time. time.135 of 144 EAL Comparison Matrix OSSI -SGS EAL Comparison Matrix OSSI -SGS 136 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording s) SGS IC Wording Difference/Deviation Justification IC#(s) SSI odn SS1 Loss of all Off-site and all On- SS1 Loss of all offsite power and all "Vital buses" is equivalent to the NEI phrase "emergency buses." Site AC power to emergency onsite AC power to vital buses busses for 15 minutes or longer, for 15 minutes or longer MODE: Power Operation, MODE: 1 -Power Operations, 2 -Startup, Hot Standby, Hot Startup, 3 -Hot Standby, 4 -Hot Shutdown Shutdown NEI Ex. SGS EI # NEI Example EAL Wording EAL # SGS EAL Wording Difference/Deviation Justification EAL # A#1 Loss of all Off-Site and all On- SS1.1 Loss of all Power (Onsite and The NEI phrase "Loss of all off-site and all on-site AC power" has Site AC power to (site specific Offsite) to all 4KV Vital Buses been changed to "Loss of all Power (Onsite and Offsite)" for emergency busses) for 15 AND simplification.

minutes or longer. 14KV vital buses are the SGS emergency buses._> 15 minutes have elapsed Note: The Emergency Director (Note 3)should not wait until the applicable time has Note 3: The Emergency elapsed, but should Coordinator should NOT declare the event as wait until the applicable soon as it is determined time has elapsed, but that the condition has should declare the event exceeded, or will likely as soon as it is exceed, the applicable determined that the time. condition will likely exceed the applicable time.137 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification SS2 Automatic Scram (Trip) fails to SS3 Automatic trip fails to shut down Scram is deleted to use terminology common to a PWR.shutdown the reactor and the reactor and manual actions manual actions taken from the taken from the reactor control reactor control console are not console are not successful in successful in shutting down the shutting down the reactor reactor 1 -Power Operations, 2 -Startup MODE: Power Operation, Startup NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL# EAL#a. An automatic scram (trip) SS3.1 An automatic trip failed to shut Scram is deleted to use terminology common to a PWR.failed to shutdown the down the reactor The NEI phrase "Manual actions" has been changed to "Manual trip reactor. AND actions" for clarification.

AND Manual trip actions taken at the Following a successful reactor trip, a prompt drop in reactor power to b. Manual actions taken at the reactor control console (reactor subcriticality should occur. Site-specific indication of plant shutdown reactor control console do not trip switches, trip bkr bezels, is reactor power less than 5% which equates to the criteria used to shutdown the reactor as supply breakers 1/2E6D and determine a valid CFST Shutdown Margin (Subcriticality) red path.indicated by (site specific 1/2G6D) do NOT shut down the indications of reactor not reactor as indicated by reactor shutdown).

power 2 5%138 of 144 EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification SS3 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 Operations, 2 Startup, Hot Standby, Hot -Startup, 3 -Hot Standby, 4 -Shutdown Hot Shutdown NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL# EAL #1 Less than (site specific bus SS2.1 < 114 VDC bus voltage 114 VDC for the 125 VDC vital buses and 25 VDC for the 28 VDC voltage indication) on all (site indications on All 125 VDC vital vital buses are the site-specific bus voltages.

The minimum voltages specific Vital DC busses) for 15 buses for > 15 minutes (Note 3) for the 125 VDC vital buses vary from 112.3 VDC to 113.9 VDC and minutes or longer. OR have been rounded to 114 VDC for all buses for readability on Note: The Emergency Director Control Room instrumentation.

The minimum voltages for the 28 should not wait until the < 25 VDC bus voltage VDC vital buses vary from 24.8 VDC to 25 VDC and have been applicable time has indications on both 28 VDC vital rounded to 25 VDC for both buses for readability on Control Room elapsed, but should buses for _ 15 minutes (Note 3) instrumentation.

declare the event as AND loss of control of Safety 125 VDC vital buses 1A(2A), 1B(2B) and 1C(2C) and 28 VDC vital soon as it is determined Related Equipment from the buses 1A(2A) and 1B(2B) are the site-specific vital DC buses. The that the condition has Control Room has been 28 VDC system is required to operate pushbutton controls in the exceeded, or will likely confirmed Control Room. It thus provides control power for remote operation of exceed, the applicable Note 3: The Emergency switchgear, annunciators, vital instrument buses, communications to time. Coordinator should NOT auxiliary control system relay cabinets for manual control of ESF wait until the applicable equipment, non-safety related equipment, and RP4 Status Board time has elapsed, but indications.

should declare the event Reference to the NEI note is included in the EAL wording "(Note 3)." as soon as it is Numbering the note facilitates referencing in the EAL matrix.determined that the condition will likely exceed the applicable time.139 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification SS6 Inability to Monitor a SS5 Inability to monitor a None SIGNIFICANT TRANSIENT in SIGNIFICANT TRANSIENT in Progress progress MODE: Power Operation, MODE: 1 -Power Operations, 2 Startup, Hot Standby, Hot -Startup, 3 -Hot Standby, 4 -Shutdown Hot Shutdown NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #a. Loss of greater than SS5.1 Loss of > approximately 75% Parts a and b of the NEI example EAL have been introduced with approximately 75% of the of Control Room Overhead the phrase "UNPLANNED loss of..." for clarification.

following for 15 minutes or Annunciators for 2! 15 minutes "Control Room Overhead Annunciators" are the NEI "Site specific longer: (Note 3) control room safety system annunciation." Each Overhead 0 (Site specific control room OR Annunciator panel displays multiple annunciators associated with safety system Loss of > approximately 75% safety systems.annunciation) of Control Room Indications Control Room indicators associated with the listed safety functions OR associated with the following are the NEI "Site specific control room safety system indication."* Site specific control room safety functions for 2! 15 SGS safety systems are designed to fulfill one or more of these safety system indication) minutes (Note 3): safety functions.

AND *Table S-1 provides the list of events that constitute a "significant

b. A SIGNIFICANT TRANSIENT

Reactivity Control transient" as specified Table 4, above.in progress

RCS Inventory The NEI term "unavailable" has been changed to "NOT available" for AND

Decay Heat Removal clarification.

c. Compensatory indications are

Fission Product Barriers OP-AB.ANN-0001 (Q) provides guidance for determining unavailable compensatory Control Room indications.

Note: The Emergency Director AND should not wait until the A SIGNIFICANT TRANSIENT is applicable time has in progress, Table S-1 elapsed, but should declare the event as soon as it is determined that the Compensatory indications are 140 of 144 EAL Comparison Matrix OSSI -SGS condition has exceeded, NOT available per OP-AB.ANN-or will likely exceed, the 0001(Q)applicable time. Note 3: 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 will likely exceed the applicable time.Table S-1 SIGNIFICANT TRANSIENTS

Automatic turbine runback > 25% thermal reactor power* Electrical load rejection

> 25% full electrical load* Reactor Trip* Safety Injection Activation 141 of 144 EAL Comparison Matrix OSSI -SGS SGS NEI IC# NEI IC Wording IC#(s) SGS IC Wording Difference/Deviation Justification SG1 Prolonged loss of all Off-site and SG1 Prolonged loss of all offsite and "Vital buses" is equivalent to the NEI phrase "emergency buses." all On-Site AC power to all onsite AC power to vital emergency busses. buses MODE: Power Operation, MODE: 1 -Power Operations, 2 Startup, Hot Standby, Hot -Startup, 3 -Hot Standby, 4 -Shutdown Hot Shutdown NEI Ex. NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #1 a. Loss of all off-site and all on- SG1 .1 Loss of all Power (Onsite and The NEI phrase "Loss of all off-site and all on-site AC power" has site AC power to (site specific Offsite) to all 4KV Vital Buses been changed to "Loss of all Power (Onsite and Offsite)" for emergency busses). AND simplification.

AND EITHER of the following:

4KV vital buses are the SGS emergency buses.b. EITHER of the following:

4 are the "(site-specific)" hours for station blackout coping. The four-* Restoration of at least o Restoration of at least one hour interval to restore AC power is based on the blackout coping one emergency bus in Vital Bus in < 4 hrs is NOT analysis performed in conformance with 10 CFR 50.63 and less than (site specific likely Regulatory Guide 1.155.hours) is not likely.hous)itespi Indicatikely CFST Core Cooling RED or The NEI phrase "...(Site-Specific)

Indication of continuing" (Site specific Indication of PURPLE path exists degradation of core cooling based on Fission Product Barrier continuing degradation of monitoring" has been replaced with "CFST Core Cooling RED or core cooling based on PURPLE path exists" for clarification.

This threshold represents the Fission Product Barrier NEI conditions for degraded core cooling consistent with the monitoring.)

corresponding fission product barrier Fuel Clad Loss and Potential Loss thresholds.

142 of 144 EAL Comparison Matrix OSSI-SGS EAL Comparison Matrix OSSI -SGS NEI IC# NEI IC Wording SGS SGS IC Wording Difference/Deviation Justification IC#(s)SG2 Automatic Scram (Trip) and all SG3 Automatic trip and all manual Scram is deleted to use terminology common to a PWR.manual actions fail to shutdown actions fail to shut down the the reactor and indication of an reactor and indication of an extreme challenge to the ability extreme challenge to the ability to cool the core exists to cool the core exists MODE: Power Operation, MODE: 1 -Power Operations, 2 Startup -Startup NEI Ex. EALS EA E NEI Example EAL Wording SGS SGS EAL Wording Difference/Deviation Justification EAL # EAL #a. An automatic scram (trip) SG3.1 An automatic trip failed to shut Scram is deleted to use terminology common to a PWR.failed to shutdown the down the reactor The phrase "reactor power > 5%" has been added to clarify the reactor.AND conditions under which an automatic and manual reactor trip would AND All manual actions do NOT shut be determined to be unsuccessful.

Following a successful reactor b. All manual actions do not down the reactor as indicated by trip, a prompt drop in reactor power to subcriticality should occur.shutdown the reactor as reactor power>ý 5% Site-specific indication of plant shutdown is reactor power less than indicatedowy (site specictr a5% which equates to the criteria used to determine a valid CFST indicated by (site specific AND Shutdown Margin (Subcriticality) red path.indications of reactor not shutdown).

EITHER of the following:

The NEI example EAL specifies site-specific indication that core AND

CFST Core Cooling RED cooling is extremely challenged and site-specific indication that heat removal is extremely challenged.

To clarify the intent of the EAL, the c. EITHER of the following path exists SGS EAL includes the specific CFSTs that represent the NEI exist or have occurred due to

CFST Heat Sink RED path conditions (Core Cooling RED and Heat Sink RED entry conditions continued power generation:

exists due to actual loss of met).* (Site specific indication secondary heat sink and The NEI phrase "due to continued power generation" has been that core cooling is heat sink is required deleted because the reason core cooling or heat removal is extremely challenged.)

extremely challenged in an ATWS event is immaterial.

This change 9 (Site specific indication is being addressed in NEI/NRC FAQ #31.that heat removal is If the Heat Sink red path is due to a procedurally directed action, extremely challenged.)

classification under this EAL is not required.

EOP-FRSM-1 directs the operators to minimize feedwater flow to the steam generators in 143 of 144 EAL Comparison Matrix OSSI -SGS order to minimize cooldown and control reactivity.

A heat sink red path is generated as a result of this operator action- However, actual loss of control of the heat sink does not occur due to these actions.In addition, the heat sink red path is precursor to a loss of core cooling and is backed up by the core cooling red path. Declaration of a General Emergency is not justified if the heat sink red path is a result of procedurally directed actions.144 of 144

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