Text

Submittal of Emergency Plan Document Revision Implemented December 6, 2017 and January 30, 2018
	ML18046A865
Person / Time
Site:	Salem, Hope Creek
Issue date:	02/15/2018
From:	Barr S; Public Service Enterprise Group
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	LR-N18-0028
	Download: ML18046A865 (58)
	v • d • e

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 0PSEG NuclearLLC FEB 1 5 2018 10 CFR 50.54(q) 10 CFR 50.4(b)(5)

LR-N18-0028 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Nuclear Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75)

NRC Docket Nos. 50-272 and 50-311 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

Emergency Plan Document Revision Implemented December 6, 2017 and January 30, 2018 Pursuant to 10 CFR 50.54(q) and 10 CFR 50.4(b)(5), PSEG Nuclear LLC (PSEG) hereby submits 10 CFR 50.54(q) Summary Analysis Reports (ID#2017-67 and ID# 2017-73) for Emergency Plan Document revisions implemented on December 6, 2017 and January 30, 2018 (Attachment 1) and a copy of the revised documents in their entirety (Enclosure 1) associated with the PSEG Nuclear LLC Emergency Plan.

There are no regulatory commitments contained in this letter.

This letter, Attachment 1, and Enclosure 1 do not contain any personal privacy, proprietary, or safeguards information for which protection is requested under the provisions for 10 CFR 2.390.

If you have any questions or require additional information, please contact Philip Quick, Emergency Preparedness Program Manager, at 856-339-3262.

Respectfully, Stephen Barr Manager - Emergency Preparedness

Page 2 10 CFR 50.54(q)

LR-N18-0028 10 CFR 50.4(b)(5) - 10 CFR 50.54(q) Summary Analysis Reports - Emergency Plan Document Revisions: EP-AA-124, Rev. 2 EP-HC-111-210, Rev. 1 EP-SA-111-210, Rev. 1 cc (without enclosures):

Administrator, Region I, NRC Ms. C. Parker, Project Manager, NRC NRC Senior Resident Inspector, Salem NRC Senior Resident Inspector, Hope Creek P. Mulligan, Chief, NJBNE Commitment Tracking Coordinator, Salem Commitment Tracking Coordinator, Hope Creek Corporate Commitment Tracking Coordinator

LR-N18-0028 Attachment 1 10 CFR 50.54(q) Summary Analysis Reports 1

LR-N18-0028 10 CFR 50.54(g)

SUMMARY

ANA L VSIS R E PORT 50.54Q I.D. Number: 2017-67 50.54Q

Title:

E P-AA-124, Revision 2, Communications Drills and Inventories (Doc#, Rev.#, Name, If applicable)

Description of the change made to the Emergency Plan/Procedures:

EP-AA-124 is being revised to reorganize and consolidate emergency response facility (ERF) communications drills, inventories, and equipment tests. The frequencies of multiple activities are being changed to better align with the PSEG Nuclear Emergency Plan and to gain efficiencies when performing regular facility maintenance activities.

Description of why the change is editorial (if not editorial, N/A this block):

N/A Description of the licensing basis affected by the change to the Emergency Plan/Procedure (if not affected, omit this element):

This change does not result in any Emergency Plan changes but is instead intended to better align with the Emergency Plan. Specifically, Section 15 describes the requirements for communications drills.

A description of how the change to the Emergency Plan/Procedures still complies with regulation:

EP-AA-124 contains the frequencies of the inventories, equipment tests, and communications drills.

Most activities are staying at the same frequency or are proposed to be conducted on a more frequent basis. The inventory activities for the TSCs, OSCs, EOF, and ENC are all being adjusted to a frequency of "after use with a minimum of 2 times per year". The prior frequency of "after use and one time per quarter': had no basis in the Emergency Plan or regulations and was done because those activities were combined with other quarterly activities. Performing the inventories after use, whether it is due to a drill or an actual event, ensures that the supplies in the facility are restored after they have been used and potentially depleted. If a facility is not used, the inventory will still be conducted at a minimum of twice per year in order to ensure that the supply levels remain adequate. The Control Point (CP) inventory item is not currently performed by EP but instead is covered under the CP RP Inventory activity.

Therefore, there is no actual change for the frequency of the CP inventory.

For the monthly required Federal (NRC) call, the Emergency Plan makes the following statement in section 15: "A communications drill to NRC Headquarters and the NRC Regional Office Operations Center from the Control Rooms, TSCs and EOF is completed monthly." This requirement is satisfied by the monthly calls made to the NRC Headquarters Operations Center.

A description of why the proposed change was not a reduction in the effectiveness of the Emergency Plan/Procedure:

The proposed change will not have an impact on the effectiveness of the PSEG Nuclear Emergency Plan. It ensures that emergency response facilities are maintained in a state of readiness and that adequate communications are available.

LR-N18-0028 10 CFR 50.54(g)

SUMMARY

ANA L V SIS R E PORT 50.54Q 1.0. Number: 2017-73 50.54Q

Title:

EP-HC/SA-111-210, EAL Technical Basis - Hazards and Other Conditions Affecting Plant Safety- Security (Doc#, Rev.#, Name, If applicable)

Description of the change made to the Emergency Plan/Procedures:

EP-HC/SA-111-210, EAL Technical Basis- Hazards and Other Conditions Affecting Plant Safety- Security are being revised. HU4.1, HA4.1 and HS4.1 of EP-HC/SA-111-210 include a table titled Security Contingency Event Summary Table. This table contains a list of 20 contingency events and possible classification levels for those events. This revision adds contingency event 21 and the possible classification levels for those events.

Description of why the change is editorial (if not editorial, N/A this block):

N/A Description of the licensing basis affected by the change to the Emergency Plan/Procedure (if not affected, omit this element):

Documents reviewed include: Emergency Plan Section 5- Emergency Classification System, 3.0 Event Classification Guide (ECG). NEI 99-01 Revision 5- Methodology for Development of Emergency Action Levels, Condition HU4, EAL #1 This threshold is based on site specific security plans. Site specific Safeguards Contingency Plans are based on guidance provided by NEI 03-12. NEI 03 Template for Security Plans, NEI 03-12 Revision 7 includes Security Event 21. Salem and Hope Creek Security Plan, The Salem and Hope Creek Security Plan was updated (revision 21) to comply with NEI 03-12 revision 7. The Security Plan now includes Security Event 21and the requirement to inform the Operating Crew of the event and classification requirements based on the severity of the event.

A description of how the change to the Emergency Plan/Procedures still complies with regulation:

There is a definitive link between NEI 03-12 and NEI 99-01. A revision to NEI 03-12 was implemented that required a new Security Event 21. To ensure compliance with the requirements of NEI 03-12 and NEI 99-01, it will be necessary to add Security Event 21 to the list of applicable Security Events in the Emergency Classification Guide.

A description of why the proposed change was not a reduction in the effectiveness of the Emergency Plan/Procedure:

The proposed change will ensure compliance with the Salem and Hope Creek Security Plan.

The change is required as a result of the addition of Security Event 21 to NEI 03-12 and the subsequent adoption of Security Event 21 in the Salem and Hope Creek Security Plan. There will be no reduction in effectiveness of Emergency Plan functions as a result of this change.

2

LR-N18-0028 Enclosure 1 Emergency Plan Document Revisions Implemented December 6, 2017 and January 30, 2018 EP-AA-124, Communications Drills and Inventories, Revision 2 EP-HC-111-210, Security, Revision 1 EP-SA-111-210, Security, Revision 1 1

PSEG Internal Use Only PSEG NUCLEAR L.L.C PSEG Nuclear Common EMERGENCY PREPAREDNESS EP-AA-124 - Rev. 2 COMMUNICATIONS DRILLS AND INVENTORIES ADHERENCE LEVEL: LEVEL 2 - REFERENCE USE Configuration Change Packages and Affected Document Numbers incorporated into this revision:

None License Renewal Related: Yes No Revision Summary Location Description of Change Entire Procedure

Procedure converted to new procedure template.

Replaced Surveillances with Drills in title of procedure to align with the Emergency Plan. Added Communications to title of procedure.

Restructured procedure to align by type of action being performed and not by facility.

Step 2.2 Changed title to Communications Drills and changed definition to align with Emergency Plan Section 15, Step 2.2.1.

Step 2.3 Changed title to Facility Inventory to differentiate between a facility and radiation protection inventory.

Step 2.4 Added definition of a Radiation Protection Inventory.

Step 2.5 Added definition of an Equipment Test.

Step 3.1 Changed title to match current organizational structure.

Step 3.3 Changed due to change in organizational structure.

Step 4.1.2 Deleted the word corrective and added guidance on how to deal with any issues identified during the performance of the inventory/test.

Step 4.2.1

Changed requirement to perform facility inventory to after use basis and at a minimum on a semi-annual basis.

Deleted the requirement to perform an inventory in the Control Rooms because EP is not responsible for maintaining stationery them.

Deleted the requirement to perform an inventory and equipment tests because EP is not responsible for maintaining stationery or equipment tests in the Control Points. The Control Point fax is tested through the equipment tests performed from the Control Rooms, TSCs, and the EOF.

Page 2 of 8 PSEG Nuclear Common LEVEL 2 - REFERENCE USE EP-AA-124 Rev: 2 COMMUNICATIONS DRILLS AND INVENTORIES Step 4.3.1

Added requirement to perform Radiation Protection inventory if the seal has been broken to align with EP-AA-124-1002.

Added new step for the on-site emergency vehicle radiation protection inventory.

Step 4.4.1 Added requirement to complete an equipment test in the OSCs.

Step 4.6 Added requirement to perform Emergency Diesel Engine tests.

Step 4.8 Added note to document that by conducting a communication drill with the NRC Headquarters Operations Center satisfies the Emergency Plan Requirement to conduct a communication drill with the NRC Regional Office.

Step 4.7 Added requirement to perform EOF Ventilation tests.

Step 4.5 Added Communications to the title.

Step 4.4.1 Added clarification to test the primary communication lines on a monthly basis and which facilities it has to be performed from to align with the Emergency Plan.

Step 4.4.2 New step to test the secondary communication lines on a quarterly basis and which facility it has to be performed from to align with the Emergency Plan.

Section 5.0 Updated references that were referred to within the procedure or were used to develop the procedure.

Step 6.0 In first bullet changed attachment to form to align with document type.

Page 3 of 8 PSEG Nuclear Common LEVEL 2 - REFERENCE USE EP-AA-124 Rev: 2 COMMUNICATIONS DRILLS AND INVENTORIES TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE AND SCOPE ................................................................................................ 4 2.0 DEFINITIONS ................................................................................................................. 4 3.0 RESPONSIBILITIES ....................................................................................................... 5 4.0 INSTRUCTIONS ............................................................................................................. 5 4.1 Inventories and Equipment Tests..................................................................... 5 4.2 Facility Inventories ............................................................................................ 6 4.3 Radiation Protection Inventories ...................................................................... 6 4.4 Equipment Tests................................................................................................ 6 4.5 Emergency Response Data System (ERDS) .................................................... 6 4.6 EOF Emergency Diesel Engine Tests .............................................................. 7 4.7 EOF Ventilation Tests........................................................................................ 7 4.8 Communications Drills...................................................................................... 7

5.0 REFERENCES

AND COMMITMENTS ........................................................................... 8 6.0 RECORDS ...................................................................................................................... 8

Page 4 of 8 PSEG Nuclear Common LEVEL 2 - REFERENCE USE EP-AA-124 Rev: 2 COMMUNICATIONS DRILLS AND INVENTORIES 1.0 PURPOSE AND SCOPE 1.1 Purpose 1.1.1. The purpose of this procedure is to describe the process used to ensure that the emergency facilities and equipment are inspected and inventoried in accordance with the emergency plan.

1.2 Scope 1.2.1. None 2.0 DEFINITIONS 2.1 Test 2.1.1. A review to ensure equipment is functional.

2.2 Communications Drills 2.2.1. Test of the primary and secondary communications links between Control Rooms, TSCs, and EOF and the appropriate state and local government contact points.

2.3 Facility Inventory 2.3.1. Verification that required material and equipment is available.

2.4 Radiation Protection Inventory 2.4.1. Verification that required Radiation Protection material and equipment is available.

2.5 Equipment Test 2.5.1. Verification that required equipment is functional.

2.6 Monthly (M) 2.6.1. Once per calendar month.

2.7 Quarterly 2.7.1. A three calendar month period. The 1st quarter being the months of January, February and March; the 2nd quarter being April, May and June; the 3rd quarter being July, August and September; and the 4th quarter being October, November and December.

2.8 Annual (A) 2.8.1. Once every calendar year (January 1 - December 31).

Page 5 of 8 PSEG Nuclear Common LEVEL 2 - REFERENCE USE EP-AA-124 Rev: 2 COMMUNICATIONS DRILLS AND INVENTORIES 2.9 Semi-Annual (S) 2.9.1. Twice per calendar year (1st: January 1 - June 30; and 2nd: July 1 - December 31).

2.10 Biennial (B) 2.10.1. Once every other calendar year.

2.11 18 month 2.11.1. Once every 18 months.

3.0 RESPONSIBILITIES 3.1 Manager - Emergency Preparedness

The overall development, conduct and evaluation of inventories and tests pertaining to the Emergency Plan.

Ensure completion of inventories and tests for the EOF and ENC/JIC as applicable, in support of the offsite Emergency Preparedness Program.

3.2 Emergency Preparedness Station Manager

Provide station support for the conduct of inventories and tests of station related equipment and facilities.

3.3 EP Staff

Perform or ensure completion of the applicable inventories and tests.

4.0 INSTRUCTIONS 4.1 Inventories and Equipment Tests 4.1.1. CONDUCT the following inventories and tests at specified frequencies, and after exercises or actual events. These inventories and tests are intended to verify the readiness of the facility or material for an emergency.

4.1.2. DOCUMENT any inventory or test on the appropriate checklist or recurring task per EP-AA-124-1001. List the actions to resolve the discrepancies (i.e. IT Tickets for telecommunication issues, documentation of supplies that need to be replenished, etc.).

1. A Condition Report should be initiated IAW LS-AA-120 to document a deficiency that would impact a facilitys operability or the ability to perform a required function.

Page 6 of 8 PSEG Nuclear Common LEVEL 2 - REFERENCE USE EP-AA-124 Rev: 2 COMMUNICATIONS DRILLS AND INVENTORIES 4.2 Facility Inventories 4.2.1. PERFORM a facility inventory after each use of a facility for a drill, exercise, or actual event.

At a minimum, the facility MUST be inventoried on a semi-annual basis per EP-AA-124-1001. Below are the facilities that are to be inventoried:

Salem and Hope Creek Technical Support Centers (TSCs)

Salem and Hope Creek Operational Support Centers (OSCs)

Emergency Operations Facility (EOF)

Emergency News Center/Joint Information Center (ENC/JIC) 4.3 Radiation Protection Inventories 4.3.1. PERFORM Radiation Protection Inventory once per quarter and after each drill exercise, actual event, IF the seal on any locker/kit has been broken per EP-AA-124-1002. Below are the facilities/vehicles that are to be inventoried:

Salem and Hope Creek Control Rooms/OSCs

Salem and Hope Creek Technical Support Centers (TSCs)

Salem and Hope Creek Control Points (CPs)

Salem and Hope Creek Emergency Vehicles

Emergency Operations Facility (EOF) 4.4 Equipment Tests 4.4.1. PERFORM equipment test once per quarter per EP-AA-124-1001 in the following facilities:

Salem and Hope Creek Control Rooms (CRs)

Salem and Hope Creek Technical Support Centers (TSCs)

Salem and Hope Creek Operational Support Centers (OSCs)

Emergency Operations Facility (EOF)

Emergency News Center/Joint Information Center (ENC/JIC) 4.5 Emergency Response Data System (ERDS) 4.5.1. PERFORM the equipment test once per quarter per NC.EP-FT.ZZ-0006(Q), and NC.EP-FT.ZZ-0007(Q).

Page 7 of 8 PSEG Nuclear Common LEVEL 2 - REFERENCE USE EP-AA-124 Rev: 2 COMMUNICATIONS DRILLS AND INVENTORIES 4.6 EOF Emergency Diesel Engine Tests 4.6.1. PERFORM no-load test of the EOF Emergency Diesel Engine once per month per NC.EP-FT.ZZ-0008(Q).

4.6.2. PERFORM load test of the EOF Emergency Diesel Engine once per year per NC.EP-FT.ZZ-0008(Q).

4.7 EOF Ventilation Tests 4.7.1. PERFORM EOF Ventilation Test once per year per NC.EP-FT.ZZ-0009(Q).

4.7.2. PERFORM EOF HVAC DOP Test once every 18 months per NC.EP-FT.ZZ-0009(Q).

NOTE A communications drill conducted with the "NRC Headquarters Operations Center" will satisfy the requirement to communicate with the NRC Headquarters and the NRC Regional Office Operations Center per Section 2.2.1 of the PSEG Nuclear Emergency Plan, Section 15.

4.8 Communications Drills 4.8.1. PERFORM the communications drills on the primary lines once per month per EP-AA-124-1001 from the following facilities:

Salem and Hope Creek Control Rooms (CRs)

Salem and Hope Creek Technical Support Centers (TSCs)

Emergency Operations Facility (EOF) 4.8.2. PERFORM the communications drills on the secondary lines once per quarter per EP-AA-124-1001 from one of the following facilities:

Salem or Hope Creek Control Room (CR) or

Salem or Hope Creek Technical Support Center (TSC) or

Emergency Operations Facility (EOF) 4.8.3. PERFORM communications drills for off-site and on-site field team vehicles once per year per EP-AA-124-1001.

END of Instructions

Page 8 of 8 PSEG Nuclear Common LEVEL 2 - REFERENCE USE EP-AA-124 Rev: 2 COMMUNICATIONS DRILLS AND INVENTORIES

5.0 REFERENCES

AND COMMITMENTS 5.1 Performance References 5.1.1. EP-AA-124-1001, Emergency Response Facility Inventories and Equipment Tests 5.1.2. EP-AA-124-1002, Emergency Preparedness Inventory Radiation Protection 5.1.3. LS-AA-120, Issue Identification and Screening Process 5.1.4. NC.EP-FT.ZZ-0006(Q), Emergency Response Data System (ERDS) Test with NRC Salem Station 5.1.5. NC.EP-FT.ZZ-0007(Q), Emergency Response Data System (ERDS) Test with NRC Hope Creek Station 5.1.6. NC.EP-FT.ZZ-0008(Q), Operational Testing of the EOF Emergency Diesel Engine 5.1.7. NC.EP-FT.ZZ-0009(Q), Emergency Operations Facility (EOF) Ventilation System Testing 5.1.8. RM-AA-101, Records Management Program 5.2 Developmental References 5.2.1. NUREG-0654, Section H, Bullet 10 5.2.2. NUREG-0654, Section N 5.2.3. NUREG-0696, Section 4.7 5.2.4. PSEG Nuclear Emergency Plan, Section 9, Emergency Facilities and Equipment 5.2.5. PSEG Nuclear Emergency Plan, Section 15, Exercises and Drills 5.3 Commitments 5.3.1. None 6.0 RECORDS

Each associated Functional Test/T&RM Form provides for the documentation of the inventory or test.

Completed inventory/test checklists (hard copy or electronic) shall be retained IAW the Records Management Program.

HCGS ECG - EAL Technical Basis EP-HC-111-210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant OPCON Applicability: All EAL# & Classification Level: HU4.1 - UNUSUAL EVENT (Common Site)

EAL:

A SECURITY CONDITION that does NOT involve a HOSTILE ACTION as reported by the Security Operations Supervisor or designee (Note 9)

OR Receipt of a CREDIBLE/ACTUAL THREAT to Salem or Hope Creek station - (determined by security in accordance with SY-AA-101-132, Threat Assessment) (Note 9)

OR A VALIDATED notification from NRC providing information of a Salem/Hope Creek AIRCRAFT threat Note 9: Shift Manager (SM) should implement the Prompt Actions of the Security Emergency Guideline Attachment located in NC.EP-EP.ZZ-0102, EC Response, 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?

Basis:

Security events which do not represent a potential degradation in the level of safety of the plant are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under EAL HA4.1, EAL HS4.1 and EAL HG4.1.

Hope Creek Page 1 of 6 Rev. 01 EAL#: HU4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 A higher initial classification could be made based upon the nature and timing of the security threat and potential consequences. The Emergency Coordinator shall consider upgrading the emergency response status and emergency classification level in accordance with the Salem

- Hope Creek Security Contingency Plan.

1st Condition (SECURITY CONDITION)

Reference is made to the specific security shift supervision (Security Operations Supervisor or designee) because these individuals are the designated personnel on-site qualified and trained to confirm that a security event is occurring or has occurred. Training on security event classification confirmation is closely controlled due to the strict secrecy controls placed on the Salem - Hope Creek Security Contingency Plan.

This threshold is based on the Salem - Hope Creek Security Contingency Plan. The Salem -

Hope Creek Security Contingency Plan is based on guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Security Contingency Plan and ISFSI Program.

2nd Condition (CREDIBLE / ACTUAL THREAT)

This threshold is included to ensure that appropriate notifications for the security threat are made in a timely manner. This includes information of a credible threat. Only the site to which the specific threat is made needs declare the Notification of an UNUSUAL EVENT.

The determination of CREDIBLE is made through use of information found in Threat Assessment, SY-AA-101-132.

3rd Condition (AIRCRAFT threat)

The intent of this part of the EAL is to ensure that notifications for the AIRCRAFT threat are made in a timely manner and that offsite response organization (OROs) and plant personnel are at a state of heightened awareness regarding the credible threat. It is not the intent of this EAL to replace existing non-hostile related EALs involving AIRCRAFT.

This EAL is met when a plant (site) receives information regarding an AIRCRAFT threat from NRC. Validation is performed by calling the NRC or by other approved methods of authentication. Only the site to which the specific threat is made need declare the UNUSUAL EVENT.

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an AIRLINER (AIRLINER is meant to be a large AIRCRAFT with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC.

Escalation to ALERT emergency classification level would be via EAL HA4.1 and would be appropriate if the threat involves an AIRLINER within 30 minutes of the plant or a HOSTILE ACTION in the OCA or PA.

Hope Creek Page 2 of 6 Rev. 01 EAL#: HU4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 Explanation/Discussion/Definitions:

If the security events do not meet the threshold for an UNUSUAL EVENT classification, they may result in the need to make a non-emergency report per RAL Section 11.7.1.a, One Hour Non-Emergency Safeguards Event (10 CFR 73.71) as determined by Security per SY-AA-1002, Safeguards Event Report.

Security will be focused on actions to mitigate the security event and will provide the SM with key information as the event progresses. Communications between the SMs and the Security Team Leader should be accurate, concise, and focused on EAL criteria and protection of key target sets. As Security and Operations terminology sometimes differ, clarifying questions should be asked to ensure accurate information exchange.

1st Condition (SECURITY CONDITION)

Page 6 of this EAL Basis is a Security Contingency Event Summary Table that indicates which Security Contingency Events could result in Security Supervision determining that a SECURITY CONDITION exists and therefore an UNUSUAL EVENT classification should be made OR, could result in Security Supervision determining that a HOSTILE ACTION is or has occurred and therefore classification at the ALERT or higher level should be made based on the location (OCA or PA) of the HOSTILE ACTION.

2nd Condition (CREDIBLE / ACTUAL THREAT)

This threshold is included to ensure that threat information from any source which is assessed by security supervision as being a CREDIBLE/ACTUAL THREAT is classified as an UNUSUAL EVENT. Only the site to which the specific threat is made needs to declare the UNUSUAL EVENT. For Security Events, Salem and Hope Creek is considered a single site, therefore a CREDIBLE/ACTUAL THREAT to either Salem or Hope Creek would affect the entire site and a Common Site UE declaration would be made.

Timely classification will ensure that Offsite Response Organizations and plant personnel are notified in a timely manner resulting in a state of heightened awareness. Threats are evaluated by security per Threat Assessment, SY-AA-101-132. Security threats that do not meet the definition of a CREDIBLE/ACTUAL THREAT should be dispositioned IAW Threat Assessment, SY-AA-101-132.

3rd Condition (AIRCRAFT threat)

AIRCRAFT threat calls from the NRC should be VALIDATED by use of NRC authentication code or a return call to the NRC Headquarter Operations Center.

For security events, Salem and Hope Creek is considered a single site, therefore, a VALIDATED AIRCRAFT THREAT to either Salem or Hope Creek would affect the entire site and a Common Site UE declaration would be made.

Hope Creek Page 3 of 6 Rev. 01 EAL#: HU4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 Definitions:

SECURITY CONDITION: Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.

VALIDATED: AIRCRAFT threat call from the NRC that is confirmed to be authentic.

Calls from the NRC are VALIDATED by use of the NRC provided authentication code or by making a return call to the NRC Headquarter Operations Center and confirming threat information with the NRC Operation Officer. AIRCRAFT threat calls from other agencies, NORAD, FAA, or FBI should be VALIDATED by calling the NRC Operations Officer.

AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. A large AIRCRAFT is referred to as an AIRLINER.

AIRLINER/LARGE AIRCRAFT: Any size or type of AIRCRAFT with the potential for causing significant damage to the plant (refer to the Security Contingency Plan for a more detailed definition).

CREDIBLE / ACTUAL THREAT: Is a threat which poses a likely and serious danger to the safe operation of the facility or to site personnel and public safety.

HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force.

Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OCA).

OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, the area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA.

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.

Hope Creek Page 4 of 6 Rev. 01 EAL#: HU4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 PROJECTILE: An object that impacts Salem/Hope Creek that could cause concern for continued operability, reliability, or personnel safety.

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

EAL Basis Reference(s):

1. NEI 99-01, Rev. 05, HU4 Example EAL #1, #2, #3

2. Salem - Hope Creek Security Contingency Plan

3. SY-AA-101-132 Threat Assessment

4. HC.OP-AB.SEC-0001 Security Event

5. HC.OP-AB.SEC-0002 Airborne Threat Hope Creek Page 5 of 6 Rev. 01 EAL#: HU4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 Security Contingency Event Summary Table Note: Do not include titles of Security Contingency Event documents in future revisions Event Could Result in Event Could Contingency Determination Result in Determination Event of a of a Number SECURITY CONDITION HOSTILE ACTION (UE ONLY) (ALERT or Higher)

Yes / No Yes / No

1 Yes Yes

2 Yes Yes

3 Yes No

4 No Yes

5 Yes Yes

6 No No

7 No No

8 Yes Yes

9 Yes Yes

10 Yes Yes

11 Yes No

12 Yes No

13 Yes No

14 Yes No

15 Yes No

16 Yes Yes

17 Yes Yes

18 No Yes

19 Yes Yes

20 Yes No

21 Yes No Hope Creek Page 6 of 6 Rev. 01 EAL#: HU4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat OPCON Applicability: All EAL# & Classification Level: HA4.1 - ALERT EAL:

A HOSTILE ACTION is occurring or has occurred within the OCA as reported by the Security Operations Supervisor or designee (Note 9)

OR A VALIDATED notification from NRC of a AIRLINER attack threat < 30 minutes away from Salem/Hope Creek (Note 9)

Note 9: Shift Manager (SM) should implement the Prompt Actions of the Security Emergency Guideline Attachment located in NC.EP-EP.ZZ-0102, EC Response, 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?

Basis:

This EAL addresses the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. They are not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.

Hope Creek Page 1 of 6 Rev. 01 EAL#: HA4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 The fact that the site is under serious attack or is an identified attack target with minimal time available for further preparation or additional assistance to arrive requires a heightened state of readiness and implementation of protective measures that can be effective (such as on-site evacuation, dispersal or sheltering).

1st Condition (OCA HOSTILE ACTION)

This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION within or directed towards the OWNER CONTROLLED AREA (OCA). It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small AIRCRAFT impact, hunters, or physical disputes between employees within the OCA.

Those events are adequately addressed by other EALs or RALs.

Note that this EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA.

If not previously notified by the NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, although not certain, that notification by an appropriate Federal agency would follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. However, the declaration should not be unduly delayed awaiting Federal notification.

2nd Condition (AIRLINER threat)

This EAL addresses the immediacy of an expected threat (AIRLINER) arrival or impact on the site within a relatively short time (< 30 minutes).

The intent of this EAL is to ensure that notifications for the AIRLINER attack threat are made in a timely manner and that OROs and plant personnel are at a state of heightened awareness regarding the credible threat. AIRLINER is meant to be a large AIRCRAFT with the potential for causing significant damage to the site.

This EAL is met when a plant receives information regarding an AIRLINER attack threat from NRC and the AIRLINER is within 30 minutes of the plant. Only the site to which the specific threat is made need declare the ALERT.

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an AIRLINER (AIRLINER is meant to be a large AIRCRAFT with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC.

Hope Creek Page 2 of 6 Rev. 01 EAL#: HA4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 Explanation/Discussion/Definitions:

This event will be escalated to a SITE AREA EMERGENCY based upon HOSTILE ACTION affecting the PROTECTED AREA (PA). Also, if Salem declares an SAE due to their PA being affected by the security event, Hope Creek will escalate to SAE to match them.

1st Condition (OCA HOSTILE ACTION)

Reference is made to the specific security shift supervision (Security Operations Supervisor or designee) because these individuals are the designated personnel on-site qualified and trained to confirm that a HOSTILE ACTION is occurring or has occurred.

This EAL condition is not premised solely on adverse health effects caused by a radiological release. Rather the issue is the immediate need for assistance due to the nature of the event and the potential for significant and indeterminate damage. Although nuclear plant security officers are well trained and prepared to protect against HOSTILE ACTION, it is appropriate for Offsite Response Organizations (OROs) to be notified and encouraged to begin activation to be better prepared should it be necessary to consider further actions.

Page 6 of this EAL Basis is a Security Contingency Event Summary Table that indicates which Security Contingency Events could result in Security Supervision determining that a HOSTILE ACTION is or has occurred and therefore classification at the ALERT or higher level should be made based on the location (OCA or PA) of the HOSTILE ACTION. Security events that do not involve a HOSTILE ACTION may result in Security Supervision determining that a SECURITY CONDITION exists and therefore an UNUSUAL EVENT classification should be made per EAL HU4.1.

2nd Condition (AIRLINER threat)

The fact that the site is an identified attack candidate with minimal time available for further preparation requires a heightened state of readiness and implementation of protective measures that can be effective (onsite evacuation, dispersal, or sheltering) before arrival or impact.

This EAL is met when a plant receives VALIDATED information regarding an AIRLINER attack threat from NRC and the AIRLINER is less than 30 minutes away from the site. Only the site (Salem and Hope Creek is considered a single site for Security event classifications) to which the specific threat is made needs declare the ALERT.

AIRLINER threat calls from the NRC should be VALIDATED by use of NRC authentication code or a return call to the NRC Headquarter Operations Center.

Hope Creek Page 3 of 6 Rev. 01 EAL#: HA4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 Definitions:

HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force.

Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA.

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

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.

AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. A large AIRCRAFT is referred to as an AIRLINER.

AIRLINER/LARGE AIRCRAFT: Any size or type of AIRCRAFT with the potential for causing significant damage to the plant (refer to the Security Contingency Plan for a more detailed definition).

SECURITY CONDITION: Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.

PROJECTILE: An object directed toward Salem/Hope Creek that could cause concern for its continued operability, reliability, or personnel safety.

Hope Creek Page 4 of 6 Rev. 01 EAL#: HA4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 VALIDATED: AIRCRAFT threat call from the NRC that is confirmed to be authentic.

Calls from the NRC are VALIDATED by use of the NRC provided authentication code or by making a return call to the NRC Headquarter Operations Center and confirming threat information with the NRC Operation Officer. AIRCRAFT threat calls from other agencies, NORAD, FAA, or FBI should be VALIDATED by calling the NRC Operations Officer.

EAL Basis Reference(s):

1. NEI 99-01, Rev. 05, HA4 Example EAL #1, #2

2. Salem - Hope Creek Security Contingency Plan

3. HC.OP-AB.SEC-0001 Security Event

4. HC.OP-AB.SEC-0002 Airborne Threat Hope Creek Page 5 of 6 Rev. 01 EAL#: HA4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 Security Contingency Event Summary Table Note: Do not include titles of Security Contingency Event documents in future revisions Event Could Result in Event Could Contingency Determination Result in Determination Event of a of a Number SECURITY CONDITION HOSTILE ACTION (UE ONLY) (ALERT or Higher)

Yes / No Yes / No

1 Yes Yes

2 Yes Yes

3 Yes No

4 No Yes

5 Yes Yes

6 No No

7 No No

8 Yes Yes

9 Yes Yes

10 Yes Yes

11 Yes No

12 Yes No

13 Yes No

14 Yes No

15 Yes No

16 Yes Yes

17 Yes Yes

18 No Yes

19 Yes Yes

20 Yes No

21 Yes No Hope Creek Page 6 of 6 Rev. 01 EAL#: HA4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: HOSTILE ACTION within the PROTECTED AREA OPCON Applicability: All EAL# & Classification Level: HS4.1 - SITE AREA EMERGENCY EAL:

A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the Security Operations Supervisor or designee (Note 9)

Note 9: Shift Manager (SM) should implement the Prompt Actions of the Security Emergency Guideline Attachment located in NC.EP-EP.ZZ-0102, EC Response, 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?

Basis:

This condition represents an escalated threat to plant safety above that contained in the ALERT in that a HOSTILE FORCE has progressed from the OWNER CONTROLLED AREA to the PROTECTED AREA.

This EAL addresses the contingency for a very rapid progression of events due to a HOSTILE ACTION within or directed towards the PROTECTED AREA (PA). Plant VITAL AREAS are within the PROTECTED AREA and are generally controlled by card key readers. A HOSTILE ACTION in the PROTECTED AREA (which includes VITAL AREAS) could represent a situation that threatens the safety of plant personnel and the general public.

These EALs address the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. It is not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.

Hope Creek Page 1 of 6 Rev. 01 EAL#: HS4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 The fact that the site is under serious attack with minimal time available for further preparation or additional assistance to arrive requires Offsite Response Organization (ORO) readiness and preparation for the implementation of protective measures.

This EAL is not intended to address incidents that are accidental events or acts of civil disobedience, such as small AIRCRAFT impact, hunters, or physical disputes between employees within the PROTECTED AREA. Those events are adequately addressed by other EALs or RALs.

Although nuclear plant security officers are well trained and prepared to protect against HOSTILE ACTION, it is appropriate for OROs to be notified and encouraged to begin preparations for public protective actions to be better prepared should it be necessary to consider further actions.

If not previously notified by NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, although not certain, that notification by an appropriate Federal agency would follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. However, the declaration should not be unduly delayed awaiting Federal notification.

Escalation of this emergency classification level to a GENERAL EMERGENCY, if appropriate, would be based upon the actual loss of physical control of the facility. If necessary, Salem will declare this event.

Explanation/Discussion/Definitions:

The Security Shift Supervision is defined as the Security Operations Supervisor or designee.

These individuals are the designated on-site personnel qualified and trained to confirm that a security event is occurring or has occurred. Training on security event classification confirmation is closely controlled due to the strict secrecy controls placed on the Salem -

Hope Creek Security Contingency Plan (Safeguards) information.

PROJECTILES that are directed into or that have impacted the PA from the OCA or beyond are considered under this EAL as HOSTILE ACTIONS within the PA.

Page 5 of this EAL Basis is a Security Contingency Event Summary Table that indicates which Security Contingency Events could result in Security Supervision determining that a HOSTILE ACTION is or has occurred and therefore classification at the ALERT or higher level should be made based on the location (OCA or PA) of the HOSTILE ACTION. Security events that do not involve a HOSTILE ACTION may result in Security Supervision determining that a SECURITY CONDITION exists and therefore an UNUSUAL EVENT classification should be made per EAL HU4.1.

Hope Creek Page 2 of 6 Rev. 01 EAL#: HS4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 Definitions:

HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force.

Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OCA).

OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA.

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

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

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.

SECURITY CONDITION: Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.

AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. A large AIRCRAFT is referred to as an AIRLINER.

AIRLINER/LARGE AIRCRAFT: Any size or type of AIRCRAFT with the potential for causing significant damage to the plant (refer to the Security Contingency Plan for a more detailed definition).

PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability, or personnel safety.

Hope Creek Page 3 of 6 Rev. 01 EAL#: HS4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation.

EAL Basis Reference(s):

1. NEI 99-01, Rev. 05, HA4 Example EAL #1, #2

2. Salem - Hope Creek Security Contingency Plan

3. HC.OP-AB.SEC-0001 Security Event

4. HC.OP-AB.SEC-0002 Airborne Threat Hope Creek Page 4 of 6 Rev. 01 EAL#: HS4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 Security Contingency Event Summary Table Note: Do not include titles of Security Contingency Event documents in future revisions Event Could Result in Event Could Contingency Determination Result in Determination Event of a of a Number SECURITY CONDITION HOSTILE ACTION (UE ONLY) (ALERT or Higher)

Yes / No Yes / No

1 Yes Yes

2 Yes Yes

3 Yes No

4 No Yes

5 Yes Yes

6 No No

7 No No

8 Yes Yes

9 Yes Yes

10 Yes Yes

11 Yes No

12 Yes No

13 Yes No

14 Yes No

15 Yes No

16 Yes Yes

17 Yes Yes

18 No Yes

19 Yes Yes

20 Yes No

21 Yes No Hope Creek Page 5 of 6 Rev. 01 EAL#: HS4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 This page intentionally blank Hope Creek Page 6 of 6 Rev. 01 EAL#: HS4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: HOSTILE ACTION resulting in loss of physical control of the facility OPCON Applicability: All EAL# & Classification Level: HG4.1 - GENERAL EMERGENCY EAL:

A HOSTILE ACTION has occurred such that plant personnel are unable to operate equipment required to maintain safety functions (i.e., reactivity control, RPV water level, or decay heat removal) at Salem or Hope Creek (Note 9)

OR A HOSTILE ACTION has caused failure of Spent Fuel Cooling Systems and IMMINENT fuel damage is likely at Salem or Hope Creek (Note 9)

Note 9: Shift Manager (SM) should implement the Prompt Actions of the Security Emergency Guideline Attachment located in NC.EP-EP.ZZ-0102, EC Response, 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?

Basis:

1st Condition This EAL encompasses conditions under which a HOSTILE ACTION has resulted in a loss of physical control of VITAL AREAS (containing vital equipment or controls of vital equipment) required to maintain safety functions and control of that equipment cannot be transferred to and operated from another location.

Hope Creek Page 1 of 4 Rev. 01 EAL#: HG4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 Typically, these safety functions are reactivity control (ability to shut down the reactor and keep it shutdown), reactor water level (ability to cool the core), and decay heat removal (ability to maintain a heat sink).

If control of the plant equipment necessary to maintain safety functions can be transferred to another location, then the threshold is not met.

2nd Condition This EAL addresses failure of spent fuel cooling systems as a result of HOSTILE ACTION if IMMINENT fuel damage is likely.

Explanation/Discussion/Definitions:

Definitions:

HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force.

Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OCA).

PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability, or personnel safety.

VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation.

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.

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

OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the Hope Creek Page 2 of 4 Rev. 01 EAL#: HG4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA.

IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will. Where IMMINENT timeframes are specified, they shall apply.

EAL Basis Reference(s):

1. NEI 99-01, Rev. 05, HG1 Example EAL #1, #2

2. HC.OP-AB.SEC-0001 Security Event

3. HC.OP-AB.SEC-0002 Airborne Threat Hope Creek Page 3 of 4 Rev. 01 EAL#: HG4.1

HCGS ECG - EAL Technical Basis EP-HC-111-210 This page intentionally blank Hope Creek Page 4 of 4 Rev. 01 EAL#: HG4.1

SGS ECG - EAL Technical Basis EP-SA-111-210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant Mode Applicability: All EAL# & Classification Level: HU4.1 - UNUSUAL EVENT (Common Site)

EAL:

A SECURITY CONDITION that does NOT involve a HOSTILE ACTION as reported by the Security Operations Supervisor or designee (Note 8)

OR Receipt of a CREDIBLE/ACTUAL THREAT to Salem or Hope Creek station - (determined by security in accordance with SY-AA-101-132, Threat Assessment) (Note 8)

OR A VALIDATED notification from NRC providing information of a Salem/Hope Creek AIRCRAFT threat (Note 8)

Note 8: Shift Manager (SM) should implement the Prompt Actions of the Security Emergency Guideline Attachment located in NC.EP-EP.ZZ-0102, EC Response, 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?

Salem Page 1 of 6 Rev. 01 EAL#: HU4.1

SGS ECG - EAL Technical Basis EP-SA-111-210 Basis:

Security events which do not represent a potential degradation in the level of safety of the plant are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under EAL HA4.1, EAL HS4.1 and EAL HG4.1.

A higher initial classification could be made based upon the nature and timing of the security threat and potential consequences. The Emergency Coordinator shall consider upgrading the emergency response status and emergency classification level in accordance with the Salem

- Hope Creek Security Contingency Plan.

1st Condition (SECURITY CONDITION)

Reference is made to the specific security shift supervision (Security Operations Supervisor or designee) because these individuals are the designated personnel on-site qualified and trained to confirm that a security event is occurring or has occurred. Training on security event classification confirmation is closely controlled due to the strict secrecy controls placed on the Salem - Hope Creek Security Contingency Plan.

This threshold is based on the Salem - Hope Creek Security Contingency Plan. The Salem -

Hope Creek Security Contingency Plan is based on guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Security Contingency Plan and ISFSI Program.

2nd Condition (CREDIBLE / ACTUAL THREAT)

This threshold is included to ensure that appropriate notifications for the security threat are made in a timely manner. This includes information of a credible threat. Only the site to which the specific threat is made needs declare the Notification of an UNUSUAL EVENT.

The determination of CREDIBLE is made through use of information found in Threat Assessment, SY-AA-101-132.

3rd Condition (AIRCRAFT Threat)

The intent of this part of the EAL is to ensure that notifications for the AIRCRAFT threat are made in a timely manner and that offsite response organization (OROs) and plant personnel are at a state of heightened awareness regarding the credible threat. It is not the intent of this EAL to replace existing non-hostile related EALs involving AIRCRAFT.

This EAL is met when a plant (site) receives information regarding an AIRCRAFT threat from NRC. Validation is performed by calling the NRC or by other approved methods of authentication. Only the site to which the specific threat is made need declare the UNUSUAL EVENT.

Salem Page 2 of 6 Rev. 01 EAL#: HU4.1

SGS ECG - EAL Technical Basis EP-SA-111-210 The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an AIRLINER (AIRLINER is meant to be a large AIRCRAFT with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC.

Escalation to ALERT emergency classification level would be via EAL HA4.1 and would be appropriate if the threat involves an AIRLINER within 30 minutes of the plant or a HOSTILE ACTION in the OCA or PA.

Explanation/Discussion/Definitions:

If the security events do not meet the threshold for an UNUSUAL EVENT classification, they may result in the need to make a non-emergency report per RAL Section 11.7.1.a, One Hour Non-Emergency Safeguards Event (10 CFR 73.71) as determined by Security per SY-AA-1002, Safeguards Event Report.

Security will be focused on actions to mitigate the security event and will provide the SM with key information as the event progresses. Communications between the SMs and the Security Team Leader should be accurate, concise, and focused on EAL criteria and protection of key target sets. As Security and Operations terminology sometimes differ, clarifying questions should be asked to ensure accurate information exchange.

1st Condition (SECURITY CONDITION)

Page 6 of this EAL Basis is a Security Contingency Event Summary Table that indicates which Security Contingency Events could result in Security Supervision determining that a SECURITY CONDITION exists and therefore an UNUSUAL EVENT classification should be made OR, could result in Security Supervision determining that a HOSTILE ACTION is or has occurred and therefore classification at the ALERT or higher level should be made based on the location (OCA or PA) of the HOSTILE ACTION.

2nd Condition (CREDIBLE / ACTUAL THREAT)

This threshold is included to ensure that threat information from any source which is assessed by security supervision as being a CREDIBLE/ACTUAL THREAT is classified as an UNUSUAL EVENT. Only the site to which the specific threat is made needs to declare the UNUSUAL EVENT. For Security Events, Salem and Hope Creek is considered a single site, therefore a CREDIBLE/ACTUAL THREAT to either Salem or Hope Creek would affect the entire site and a Common Site UE declaration would be made.

Timely classification will ensure that Offsite Response Organizations and plant personnel are notified in a timely manner resulting in a state of heightened awareness. Threats are evaluated by security per Threat Assessment, SY-AA-101-132. Security threats that do not meet the definition of a CREDIBLE/ACTUAL THREAT should be dispositioned IAW Threat Assessment, SY-AA-101-132.

Salem Page 3 of 6 Rev. 01 EAL#: HU4.1

SGS ECG - EAL Technical Basis EP-SA-111-210 3rd Condition (AIRCRAFT Threat)