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Revised Pages to Table of Contents and Section 6.1 of Hope Creek Generating Event Classification Guide Technical Basis, October 11, 2006
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Document Transmittal Form TO NRC ATTN:DOC. CONTROL ID: HECGO065 ONE WHITE FLINT NORTH WASHINGTON, DC 20555-001 Date 10/11/2006 Please update your controlled set of documents with the following documents:

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HOPE CREEK GENERATING -STATION EVENT CLASSIFICATION GUIDE TECHNICAL BASIS October 11, 2006 CHANGE PAGES FOR REVISION #34 The Table of Contents forms a general guide to the current revision of each section and attachment of the Hope Creek ECG Technical Basis. The changes that are made in this TOC Revision #34 are shown below.

1. Check that your revision packet is complete.

2. Add the revised documents.

3. Remove and recycle the outdated material listed below.

ADD REMOVE Page Description Rev. Page Description Rev.

ALL T.O.C. 34 ALL T.O.C. 33 ALL Section 6.1 01 ALL Section 6.1 00 1 of 1

PSEG Internal Use'Only HC EAL Technical Basis T.O.C.

Pg. 1 of 4 HOPE CREEK ECGTECHNICAL BASIS TABLE OF CONTENTS/SIGNATURE PAGE SECTION TITLE REV # PAGES DATE T.O.C. Table of Contents/Signature Page 34 4 10/11/06 i Introduction and Usage 00 3 01/21/97 ii Glossary of Acronyms & Abbreviations 00 5 01/21/97 1.0 Fuel Clad Challenge 02 9 12/15/04 2.0 RCS Challenge 01 8 04/21/04 3.0 Fission Product Barriers (Table) 3.1 Fuel Clad Barrier 04 13 12/15/04 3.2 RCS Barrier 03 18 1215/04 3.3 Containment Barrier 05 15 12/15/04 4.0 EC Discretion 01 8 01/20/06 5.0 Failure to SCRAM 03 10 01/20/06 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release 01 42 10/11/06 6.2 Liquid Effluent Release 00 4 01/21/97 6.3 In - Plant Radiation Occurrences 00 6 01/21/97 6.4 Irradiated Fuel Event 03 11 01/20/06 7.0 Electrical Power 7.1 Loss of AC Power Capabilities 01 18 05/12/97 7.2 Loss of DC Power Capabilities 00 5 01/21/97 8.0 System Malfunctions 8.1 Loss of Heat Removal Capability 02 10 04/30/03 8.2 Loss of Overhead Annunciators 00 8 01/21/97 8.3 Loss of Communications Capability 00 4 01/21/97 8.4 Control Room Evacuation 01 4 12/15/04 8.5 Technical Specifications 01 2 08/03/05 9.0 Hazards - Internal/External 9.1 Security Threats 07 13 03/31/06 9.2 Fire 01 6 02/01/01 9.3 Explosion 01 5 02/01/01 9.4 Toxic/Flammable Gases 04 13 01/06/05 9.5 Seismic Event 03 4 04/21/04 9.6 High Winds 01 7 02/01/01 9.7 Flooding 01 5 02/01/01 9.8 Turbine Failure/Ve*hicle Crash/ 01 7 02/01/0.1 Missile Impact 9.9 River Level 00 4 01/21/97 HCGS Rev. 34

PSEG Internal Use Only HC EAL Technical Basis T.O.C.

Pg. 2 of,4 HOPE CREEK ECG TECHNICAL BASIS TABLE OF CONTENTS/SIGNATURE PAGE SECTION TITLE REV # PAGES DATE 10.0 Reserved for future use 11.0 Reportable Action Levels (RALs) 11.1 Technical Specifications 03 9 08/30/06 11.2 Degraded or Unanalyzed Condition 05 8 08/30/06 11.3 System Actuation 06 7 02/23/05 11.4 Personnel Safety/Overexposure 02 8 08/30/06 11.5 Environmental/State Notifications 02 4 10/01/03 11.6 After-the-Fact 02 1 02/28/02 11.7 Security/Emergency Response 06 5 03/31/06 Capabilities 11.8 Public Interest 01 3 01/23/01 11.9 Accidental Criticality/ 04 8 08/30/06 Special Nuclear Material /

Rad Material Shipments - Releases 11.10 Voluntary Notifications 01 2 01/23/01 HCGS Rev. 34

PSEG Internal Use Only HC EAL Technical Basis T.O.C.

Pg. 3 of 4

. REVISION

SUMMARY

Biennial Review Performed: Yes No X Editorial Revisions (Approved DCP):

EALs 6.1.1.d and 6.1.2.d being revised per DCP 80042523, which modifies the sampling skids for the North and South Plant Vents. EALs associated with the North and South Plant Vents iodine monitoring are being deleted.

HCGS Rev. 34

-PSEG Internal Use Only HC EAL Techniical Basis T.O.C.

Pg. 4 of 4 SIGNATURE, P Prepared By: Dennis Kabachinski 0.., 09/11/06 Section/Attachments Revised 6. 1.1.d and 6.1.2.d (List Non-Editorial Only - Section/Attachments)

Reviewed By: N/A - DCP 80042523 1 CFR5e.54q Effectiveness Reviewer , Date Reviewed By: N/A Hope Creek Operations Shift Manager Date Reviewed By: N/A Hope Creek Regulatory Assurance Date (Reportable Action Level [Section 11] and associated Attachments marked by "L")

Reviewed By:

EP Maagýer bate Reviewed By: N/A Nuclear Oversight Manager Date (If Applicable)

SORC Review and Station Approvals N/A N/A Mtg. No. Hope Creek Chairman Hope Creek Plant Manager Date Date Effective Date of this Revision: 10/11/06 Date HCGS Rev. 34

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release UNUSUAL EVENT - 6.1.1.a IC Any Unplanned Release of Gaseous Radioactivity to the Environment that Exceeds 2 Times the Radiological Technical Specifications for 60 minutes or longer EAL Dose Assessment indicates EITHER one of the following at the MEA or beyond as calculated on the SSCL:

e TEDE 4-Day Dose of > 2.OE-01 mRem

Thyroid-CDE Dose of > 6.8E-01 mRem based on Plant Vent effluent sample analysis and NOT on a default Noble Gas to Iodine Ratio AND Release is ongoing for > 60 minutes OPERATIONAL CONDITION - All BASIS Dose Assessment at or beyond the MEA exceeding the EAL threshold, can result from a Gaseous Radiological Release in excess of 2 times Technical Specifications. This condition results from an uncontrolled release of radioactivity to the environment, resulting in elevated offsite dose rates. The threshold for this EAL is NOT based on a specific offsite dose rate, but rather on the loss of plant control implied by a radiological release of this magnitude that was not isolated within 60 minutes. The final integrated dose is very low and is not the primary concern.

Classification is based on an ongoing release that does not comply with a license condition.

Unplanned is defined as any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions on the applicable permit.

Dose Assessment using actual meteorological data provides an accurate indication of release magnitude. The use of dose assessment based EALs is therefore preferred over the use of Release Rate based EALs which utilize calculations which have built-in inaccuracies because ODCM default meteorological data is used. As long as dose assessment is available, thisEAL should be used in place of EAL 6.1.1.d.

EAL - 6.1.1.a Rev. 01 Page l of .3

HCGS EAL/RALTechnical Basis It is not-intended that the release be averaged over 60 minutes, but exceed 2 times the Technical Specification limit for 60 minutes or longer. In addition, it is intended that the event be declared as soon as it is determined that the release will exceed 2 times the limit for 60 minutes or longer.

Barrier Analysis N/A ESCALATION CRITERIA Emergency Classification will escalate to an Alert when the effluent release concentration increases to 200 times the Technical Specification limit.

DISCUSSION Prorating the 500 mRem/yr criterion for the TEDE 4-day dose: time (8766 hr/yr); the 2 x Tech.

Spec. multiplier; and, Artificial Island's Allocation Factor of 0.5 (50% per site), the associated site boundary dose rate would be 0.057 mRem/hr.

TEDE 4-Day MEA Dose Rate= (500m Rem yr )(2)(.5) 0.057 mRem/hr 8766hr/yr This is rounded to .05 mRem/hr.

The TEDE 4-day Dose is based on a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months release duration. Therefore .05 mRem/hr

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months =

0.2 mnRem.

Prorating the 1500 mRem/yr criterion for the Thyroid-CDE Dose: time (8766 hr/yr); the 2 x Tech. Spec. multiplier; and, Artificial Island's Allocation Factor of 0.5 (50% per site), the associated site boundary dose rate would be 0.17 mRem/hr.

Thyroid-CDEMEA Dose Rate= ( 1500mRe ryr )(2)(.5)= 0.17 mRem/hr 8766hr/ yr The Thyroid-CDE Dose is based on a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months release duration. Therefore 0.17. mRem/hr *4 hours = 0.68 mRem.

DEVIATION None EAL - 6.1.La Rev. 01 Page 2 of 3

HCGS EAL/RALTechnical Basis REFERENCES NUMARC NESP-007, AUL.4 Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3.11.2.1 EAL - 6.1.1.a Rev. 01 Page 3 of 3

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release UNUSUAL EVENT - 6.1.1.b IC Any Unplanned Release of Gaseous Radioactivity to the Environment that Exceeds 2 Times the Radiological Technical Specifications for 60 minutes or longer EAL Dose Rate measured at the Protected Area Boundary or beyond EXCEEDS

.05 mRem/hr above normal background AND Release is ongoing for > 60 minutes OPERATIONAL CONDITION - All BASIS Measured Dose Rate at or beyond the Protected Area Boundary exceeding the EAL threshold can result from a Gaseous Radiological Release in excess of 2 times Technical Specifications. This condition results from an uncontrolled release of radioactivity to the environment, resulting in elevated offsite dose rates. The threshold for this EAL is NOT based on a specific offsite dose rate, but rather on the loss of plant control implied by a radiological release of this magnitude that was not isolated within 60 minutes. The final integrated dose is very low and is not the primary concern. Classification is based on an ongoing release that does not comply with a license condition. Unplanned is defined as any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions on the applicable permit.

It is not intended that the release be averaged over 60 minutes, but exceed 2 times Tech. Spec.

limits for 60 minutes or longer. Further, it is intended that the event be declared as soon as it is determined that the release will exceed 2 times the limit for 60 minutes or longer.

Barrier Analysis N/A EAL-- 6.1.1.b Rev. 01 Page l of 2

HCGS EAL/RALTechnical Basis ESCALATION CRITERIA Emergency Classification will escalate to an Alert when effluent release concentration increases to 200 times the Technical Specification limit.

DISCUSSION Prorating the 500 mRem/yr criterion for: time (8766 hr/yr); the 2 x Tech. Spec. multiplier; and, Artificial Island's Allocation Factor of 0.5 (50% per site), the associated site boundary (MEA) dose rate would be 0.057 mRem/hr.

Protected Area Boundary Dose Rate = (500m Re m /3)1 )(2)(y5) 0.057 mRem/hr 8766hr lyr This is rounded to .05 mRem/hr DEVIATION None REFERENCES NUMARC NESP-007, AU1.3 Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3.11.2.1 EAL - 6.1.L.b Rev. 01 Page 2 of 2

.HCGS EAL/RALTechnical Basis 60 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release UNUSUAL EVENT --6.1.1.c IC Any Unplanned Release of Gaseous Radioactivity to the Environment that Exceeds 2 Times the 10CFR20, Appendix B limits for 60 minutes or longer EAL Gaseous effluent release sample analysis for ANY one of the following indicates a concentration of:

" FRVS:

> 1.13E-03 piCi/ce Total Noble Gas

> 2.71E-07 ftCi/ec 1-131

" NPV:

" 2.43E-04 pCi/cc Total Noble Gas

" 5.81E-08 piCi/cc 1-131

" SPV:

> 2.27E-05 ptCi/ec Total Noble Gas

> 5.44E-09 ItCi/ec 1-131 AND Dose Assessment results NOT available AND Release is ongoing for > 60 minutes OPERATIONAL CONDITION - All BASIS Gaseous effluent release sample analysis exceeding the EAL threshold for any of the plant vents listed (FRVS, NPV, SPV), can result from a Gaseous Radiological Release in excess of 2 times

10CFR20, Appendix B limits. This condition results from an uncontrolled release of radioactivity to the environment, resulting in elevated offsite dose rates.

EAL - 6.1.1.c Rev. 01 Page 1 of 3

HCGS EAL/RALTechnical Basis The threshold for this EAL is NOT based on a specific offsite dose rate, but rather on the loss of plant control implied by a radiological release of this magnitude that was not isolated within 60 minutes. The final integrated dose-is very low and is not the primary concern. Classification is based on an ongoing release that does not comply with a license condition. The.HTV is not included under this EAL since there are no provisions for collecting a HTV grab sample.

Unplanned is defined as any release for which a radioactive discharge permit was not prepared, or a-release that exceeds the conditions on the applicable permit.

It is not intended that the release be averaged over 60 minutes, but exceed 2 times the 10CFR20, Appendix B limit for 60 minutes or longer. In addition, it is intended that the event be declared as soon as it is determined that the release will exceed 2 times the limit for 60 minutes or longer.

Barrier Analysis N/A ESCALATION CRITERIA Emergency Classification will escalate to an Alert when the effluent release concentration increases to 200 times the 10CFR20, Appendix B limit.

DISCUSSION Refer to Basis Section for EAL 6.1,1 d for the 10CFR20, Appendix B Noble Gas and Thyroid Committed Dose release rate calculations.

Calculation of the threshold sample concentrations are as follows:

4.80E + 03,uCi / see FR VS Noble Gas Sample Concentration /scf 472 x9000Ocfm 1.13E-03 gCi/cc

-4.0+3*

FRVS I-131 Sample Concentration= 1.15E+OOpCi/se= 2.71E-07 jtCi/cc 472x900Ocfm NPVNoble Gas Sample Concentration= 4.80E + 03,uCi / see 2,43E-04 tCi/cc 472x4.19E + 04cfm NPV1-131 Sample Concentration= 1.15E + 00,iCi / sec 5.81E-08 gCi/cc 472x4.19E + 04cfm SPVNoble Gas Sample Concentration= 4.80E + 03pCi / sec 2,27E-05 jiCilcc 472x4.48E + 05cfm EAL- 6.1.1.c Rev. 01 Page 2 of 3

HCGS EAL/RALTechnical Basis SPVI-131 Sample Concentration= 1.15E + OOpCi / see . 5.44E-09 ý.Ci/cc 472x4.48E + 05cfm Where: 472 = conversion factor (28,317 cc/ft3 x 1 min./60 see.)

9000 cfm = FRVS Vent Flow (maximum) 4-19E+04 cfin = NPV Vent Flow (maximum) 4.48E+05 cfin = SPV Vent Flow (maximum)

The noble gas release rate of 4.80E+03 IgCi/sec is obtained by multiplying the 10CFR20, Appendix B limit release rate of 2.40E+03 gCi/sec times 2.

The iodine release rate of 1.1 5E+00 liCi/sec is obtained by multiplying the 10CFR20, Appendix B limit release rate of 5.75E-01 gtCi/sec times 2.

DEVIATION The value for EAL 6.1.1.c is based on one meteorological case and one isotopic mixture found in the ODCM. A radiological release based on this specific release rate could produce a TEDE Dose which would require an Alert classification or not meet the Unusual Event classification, depending on the meteorological conditions and the isotopic mixture. EAL 6.1.1 .c would not be used unless EAL 6.1.1 .a (Dose Assessment) can not be used to determine the classification, if any, due to the potential uncertainty of this "default" EAL.

Two times the 10CFR20, Appendix B limits for noble gas and Iodine 131 are being used for this EAL, due to concerns that the State of New Jersey have pertaining to this EAL and based on the above mentioned uncertainties.

REFERENCES NUMARC NESP-007, AU1.2, AU1.L, AUL.4 Off-Site Dose Calculation Manual, Section 2.0 NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3.11.2.1 EAL - 6.1.1.c Rev. 01 Page 3 of 3

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release UNUSUAL EVENT -.6.1.1.d IC Any Unplanned Release of Gaseous Radioactivity to the Environment that Exceeds 2 times the 10CFR20, Appendix B limits for 60 minutes or longer EAL Valid High Alarm received from ANY one of the following Plant Effluent RMS Channels:

" FRVS Noble Gas (Grid 1/3; 9RX680)

" NPV Noble Gas (Grid 1/3; 9RX590)

SPV Noble Gas (Grid 1/3; 9RX580)

HTV Noble Gas (Grid 3; 9RX516)

AND Total Plant Vent release rate EXCEEDS 4.80E+03 piCi/sec Total Noble Gas AND Dose Assessment results NOT available AND Release is ongoing for > 60 minutes OPERATIONAL CONDITION - All BASIS Valid High alarm and effluent release rate values exceeding the EAL threshold, can result from a Gaseous Radiological Release in excess of 2 times 10CFR20, Appendix B limits. This condition results from an uncontrolled release of radioactivity to the environment, resulting in elevated offsite dose rates. The threshold for this EAL is NOT based on a specific offsite dose rate, but rather on the loss of plant control implied by a radiological release of this magnitude that was not isolated within 60 minutes. The final integrated dose is very low and is not the primary concern.

Valid is defined as the High alarm actuating specifically due to a Gaseous Release exceeding 10 CFR 20, Appendix B limits, thus precluding unwarranted event declaration as the result of EAL - 61.1A.d Rev. 01 Page 1 of 3

HCGS EAL/RALTechnical Basis spurious actuation. Classification is based on an ongoing release that does not comply with a license condition. Unplanned is defined as any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions on the applicable permit.

The EAL value for Total Plant Vent release rate was determined using default X/Q values from the ODCM which provides a less accurate method of evaluation release magnitude than using dose assessment with real time meteorological data. For that reason, this EAL should not be utilized if Dose Assessment is available. Dose Assessment will take in account actual meteorological conditions, plant vent flows and plant vent effluent concentrations to provide a more accurate assessment of a radiological release. If Dose Assessment is available then refer to EAL 6.1.1.a for classification.

It is not intended that the release be averaged over 60 minutes, but exceed 2 times 10 CFR20, Appendix B limits for 60 minutes or longer. In addition, it is intended that the event be declared as soon as it is determined that the release will exceed 2 times the limit for 60 minutes or longer.

Barrier Analysis N/A ESCALATION CRITERIA Emergency Classification will be escalated to an Alert when the effluent release concentration increases to 200 times the 10CFR20, Appendix B limits.

DISCUSSION The release rate threshold for this EAL is obtained by multiplying the Technical Specification release rate of 2.4E+03 giCi/sec for Noble Gases times 2. Total Noble Gas release rate is the summation of all plant vent release rates.

The 10CFR20, Appendix B limits are based on ODCM calculations.

10CFR20, Appendix B Calculation for Noble Gas uCi/Second = (100 m Rem / year) * (Allocation Factor)

(ODCM X / Q) * (ODCM DRCF)

WHERE: uCi/Second = Total Noble Gas Release Rate from Salem (Unit 1 & Unit 2) or Hope Creek (all Vents; NPV, SPV, FRVS, and HTV) which would result in a TEDE Dose Rate of 50 mRem/year.

ODCM X/Q = Site Specific (Salem or Hope Creek) dispersion factor at the Site Boundary in sec/m 3 .

EAL - 6.1.1d Rev. 01 Page2 of .3

HCGS EAL/RALTechnical Basis ODCM DRCF = Site Specific (Salem or Hope Creek) dose rate conversion factor in mRem/year/uCi/m 3 .

ODCM X/Q =2.67E-06 sec/m 3 3

ODCM DRCF- 7.80E+03 mRem/yr/uCi/m Allocation Factor = 5.OOE-01 2.40E+03 uCi/Second = (100 mRem / yr) * (5.OOE - 01)

(2.67E - 06 sec/ 3 ) * (7.80E + 03m Rem / yr //.tCi / M3 )

2.40E+03 RtCi/sec *2 = EAL value.

4.80E+03 ttCi/sec is the EAL value.

DEVIATION The value for EAL 6.1.1 .d is based on one meteorological case and one isotopic mixture found in the ODCM. A radiological release based on this specific release rate could produce a TEDE Dose which would require an Alert classification or not meet the Unusual Event classification, depending on the meteorological conditions and the isotopic mixture. EAL 6.1.1 .d would not be used unless EAL 6.1.1.a (Dose Assessment) can not be used to determine the classification, if any, due to the potential uncertainty of this "default" EAL Two times the 10CFR20, Appendix B limits for noble gas is being used for this EAL, due to concerns that the State of New Jersey have pertaining to this EAL and based on the above mentioned uncertainties.

REFERENCES NUMARC NESP-007, AUI1, AU1.4 HC.OP-AB.ZZ-126(Q), Abnormal Releases of Gaseous Radioactivity HC.RP-AR.SP-0001(Q), Radiation Monitoring System Alarm Response Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3.11.2.1 EAL - 6.1.1.d Rev. 01 Page 3 of 3

HCGS EALURALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release ALERT - 6.1.2.a IC Any Unplanned Release of Gaseous Radioactivity to the Environment that exceeds 200 Times Radiological Technical Specifications for 15 minutes or longer EAL Dose Assessment indicates EITHER of the following at the MEA or beyond as calculated on the SSCL:

" TEDE 4-Day Dose of > 2.OE+01 mRem

" Thyroid-CDE Dose of > 6.8E+01 mRem based on Plant Vent effluent sample analysis and NOT on a default Noble Gas to Iodine Ratio AND Release is ongoing for > 15 minutes OPERATIONAL CONDITION - All BASIS Dose Assessment at or beyond the MEA exceeding the EAL threshold, can result from a Gaseous Radiological Release in excess of 200 times Technical Specifications. This condition results from an uncontrolled release of radioactivity to the environment, resulting in significantly elevated offsite dose rates. The threshold for this EAL is NOT based on a specific offsite dose rate, but rather on the loss of plant control implied by a radiological release of this magnitude that was not isolated within 15 minutes. Classification is based on an ongoing release that does not compl with a license condition. Unplanned is defined as any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions on the applicable permit.

Dose Assessment using actual meteorological data provides an accurate indication of release magnitude. The use of dose assessment based EALs is therefore preferred over the use of Release Rate based EALs which utilize calculations which have built-in inaccuracies because ODCM default meteorological data is used. As long as dose assessment is available, this EAL should be used in place of EAL 6.1.2.d.

EAL- 6.1.2:a Rev. 01 Pagel of 3

HCGS EAL/RALTechnical Basis It is not intended that the release be averaged over 15 minutes, but exceed 200 times the Technical Specification limit for 15 minutes or longer. In addition, it is intended that the event be declared as soon as it is determined that the release will exceed 200 times the limit for 15 minutes or longer.

Barrier Analysis N/A ESCALATION CRITERIA Emergency Classification will escalate to a Site Area Emergency when the effluent release concentration increases to a level that would cause a 100 mRem dose at the Protected Area Boundary.

DISCUSSION Prorating the 500 mRem/yr criterion for the TEDE 4-day dose: time (8766 hr/yr); the 200 x Tech. Spec. multiplier; and, Artificial Island's Allocation Factor of 0.5 (50% per site), the associated site boundary dose rate would be 5.7 mRem/hr.

TEDE 4-Day MEA Dose Rate = 500m Rem/yr )(200)(05) = 5.7 mRem/hr 8766hr / yr This is rounded to 5.0 mRem/hr.

The TEDE 4-day Dose is based on a default (assumed) 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months release duration. Therefore 5.0 mRem/hr

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months = 20 mRem.

Prorating the 1500 mRem/yr criterion for the Thyroid-CDE Dose: time (8766 hr/yr); the 200 x Tech. Spec. multiplier; and, Artificial Island's Allocation Factor of 0.5 (50% per site), the associated site boundary dose rate would be 17 mnRem/hr.

Thyroid-CDEMEA Dose Rate = 1500mRem /yr )(200)(.5) = 0.17 mRem/hr 8766hr / yr The Thyroid-CDE Dose is based on a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months release duration. Therefore 17 mRem/hr *4 hours

=68 miRem.

DEVIATION None EAL - 6.1.2.a Rev. 01 Page 2 of 3

HCGS EAURALTechnical Basis

. REFERENCES NUMARC NESP-007, AA1.4 Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3.11.2.1 EAL - 6.1.2.a Rev. 01 Page 3 of 3

HCGS EAL/RALTechnical Basis 60 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release ALERT - 6.1.2.b IC Any Unplanned Release of Gaseous Radioactivity to the Environment that exceeds 200 Times Radiological Technical Specifications for 15 minutes or longer EAL Dose Rate measured at the Protected Area Boundary or beyond EXCEEDS 5 mRem/hr AND Release is ongoing for > 15 minutes OPERATIONAL CONDITION - All BASIS Measured Dose Rates at or beyond the MEA exceeding the EAL threshold, can result from a Gaseous Radiological Release in excess of 200 times Technical Specifications. This condition results from an uncontrolled release of radioactivity to the environment, resulting in significantly elevated offsite dose rates. The threshold for this EAL is NOT based on a specific offsite dose rate, but rather on the loss of plant control implied by a radiological release of this magnitude that was not isolated within 15 minutes. Classification is based on an ongoing release that does not comRlv with a license condition. Unplanned is defined as any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions on the applicable permit.

It is not intended that the release be averaged over 15 minutes, but exceed 200 times the Technical Specification limit for 15 minutes or longer. In addition, it is intended that the event be declared as soon as it is determined that the release will exceed 200 times the limit for 15 minutes or longer.

Barrier Analysis N/A EAL - 6.1.2.b Rev. 01 Page l of -2

HCGS EAL/RALTechnical Basis ESCALATION CRITERIA Emergency Classification will escalate to a Site Area Emergency when effluent release concentration increases to a level that would cause a 100 mRem dose at the Protected Area Boundary.

DISCUSSION Prorating the 500 mRem/yr criterion for: time (8766 hr/yr); the 200 x Tech. Spec. multiplier; and, Artificial Island's Allocation Factor of 0.5 (50% per site), the associated site boundary dose rate would be 5.7 mRem/hr.

= 500mRem/yr ProtectedArea Boundary Dose Rate )(200)(.5) 5.7 mRem/hr 8766hr/yr This is rounded to 5.0 mRem/hr DEVIATION None REFERENCES NUMARC NESP-007, AA1 3 Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3.11.2.1 EAL-- 6.1.2.b Rev. 01 Page 2 of 2

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release ALERT - 6.1.2.c IC Any Unplanned Release of Gaseous Radioactivity to the Environment that exceeds 200 Times the 10CFR20, Appendix B limits for 30 minutes or longer EAL Gaseous effluent release sample analysis for ANY one of the following indicates a concentration of:

" FRVS:

> 1.13E-01 ptCi/ee Total Noble Gas

> 2.71E-05 ptCi/ce 1-131

" NPV:

> 2.43E-02 pCi/ee Total Noble Gas

> 5.81E-06 piCi/ee 1-131

" SPV:

> 2.27E-03 pCi/cc Total Noble Gas

> 5.44E-07 pCi/ce 1-131 AND Dose Assessment results NOT available AND Release is ongoing for > 30 minutes OPERATIONAL CONDITION - All BASIS Total gaseous effluent release sample analysis exceeding the EAL threshold for any of the plant vents listed (FRVS, NPV, SPV), can result from a Gaseous Radiological Release in excess of 200 times 10CFR20, Appendix B limits. This condition results from an uncontrolled release of radioactivity to the environment, resulting in elevated offsite dose rates.

EAL-- 6.1.2.c Rev. 01 Page 1 of 3

HCGS EAL/RALTechnical Basis The threshold for this EAL is NOT based on a specific offsite dose rate, but rather on the loss of plant control implied by a radiological release of this magnitude that was not isolated within 30 minutes. The final integrated dose is very low and is not the primary concern. Classification is based on an ongoing release that does not comEly with a license condition. The HTV is not included under this EAL since there are no provisions for collecting a HTV grab sample.

Unplanned is defined as any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions on the applicable permit.

It is not intended that the release be averaged over 30 minutes, but exceed 200 times the 10CFR20, Appendix B limit for 30 minutes or longer. In addition, it is intended that the event be declared as soon as it is determined that the release will exceed 200 times the limit for 30 minutes or longer.

Barrier Analysis N/A ESCALATION CRITERIA Emergency Classification will escalate to a Site Area Emergency when effluent release concentration increases to a level that would cause a 100 mRem TEDE dose or Thyroid-CDE of 500 mRem for 1-131 at the Protected Area Boundary.

DISCUSSION Refer to Basis Section for EAL 6.1.2.d for the 10CFR20, Appendix B Noble Gas and Thyroid Committed Dose release Rate Calculations.

Calculation of the threshold sample concentrations are as follows:

4.80E + 05,uCi / sec FR VS Noble Gas Sample Concentration =-= 472x9000cfm 1.13E-01 itCi/cc 1.1 5E + 02,uCi / sec FR VS 1-131 Sample Concentration= = 2.71E-05 ýICi/cc 472x9000cfm NPV Noble Gas Sample Concentration= 4.80E + / sec ==5/iCi 2.43E-02 i.Ci/cc 472x4.19E + 4cfm 1.1 5E + 02/.Ci / sec NPV 1-131 Sample Concentration= 472x4.19E + 02 c

+ 04cfm = 5.81E-06 RCi/cc EAL - 6.1.2.c Rev. 01 Page 2 of 3

HCGS EAL/RALTechnical Basis 4.80E + 05ptCi / sec SPV Noble Gas Sample Concentration= 4.8E+O5cie = 2.27E-03 ýtCi/cc 472x4.48E + 5cfm SPVI-131 Sample Concentration 1.15E + 02,Ci / sec = 5.44E'07 ýCi/cc 472x4.48E + 05cfm Where: 472 = conversion factor (28,317 cc/ft3 x 1 min./60 sec.)

9000 cfm = FRVS Vent Flow (maximum) 4.19E+04 cfm = NPV Vent Flow (maximum) 4.48E+05 cfm = SPV Vent Flow (maximum)

The noble gas release rate of 4.80E+05 jiCi/sec is obtained by multiplying the IOCFR20, Appendix B limit release rate of 2.40E+03 p.Ci/sec times 200.

The iodine release rate of 1.1 5E+02 gtCi/sec is obtained by multiplying the 10CFR20, Appendix B limit release rate of 5.75E-01 gtCi/sec times 200.

DEVIATION The value for EAL 6.1.2*c is based on one meteorological case and one isotopic mixture found in the ODCM. A radiological release based on this specific release rate could produce a TEDE Dose which would require a General Emergency classification or not meet the Alert classification, depending on the meteorological conditions and isotopic mixture. EAL 6.1.2.c would not be used unless EAL 6.1.2.a (Dose Assessment) can not be used to determine the classification, if any, due to the potential uncertainty of this "default" EAL.

Two hundred times the 10CFR20, Appendix B limit noble gas and Iodine 131 are being used for this EAL, due to concerns that the State of New Jersey had pertaining to this EAL and based on the above mentioned uncertainties.

The time limit has been increased from 15 minutes to 30 minutes, to allow additional time to perform dose assessment, since the threshold fore this EAL is only 20% of the value allowed per NESP-007 and we do not wish to use this "default" EAL, unless absolutely necessary.

REFERENCES NUMARC NESP-007, AA1.2, AA1.1, AA1.4 Off-Site Dose Calculation Manual, Section 2.0 NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3.11.2.1 EAL - 6.1.2.c Rev. 01 Page 3 of 3

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release ALERT - 6.1.2.d IC Any Unplanned Release of Gaseous Radioactivity to the Environment that exceeds 200 Times 10 CFR20, Appendix B Limits for 30 minutes or longer EAL Valid High Alarm received from ANY one of the following Plant Effluent RMS Channels:

FRVS Noble Gas (Grid 1/3; 9RX680)

NPV Noble Gas (Grid 1/3; 9RX590)

SPV Noble Gas (Grid 1/3; 9RX580) 9 HTV Noble Gas (Grid 3; 9RX516)

AND Total Plant Vent release rate EXCEEDS 4.80E+05 ftCi/sec Total Noble Gas AND Dose Assessment results NOT available AND Release is ongoing for > 30 minutes OPERATIONAL CONDITION - All BASIS Valid High alarm and effluent release rate values exceeding the EAL threshold, can result from a Gaseous Radiological Release in excess of 200 times 10CFR20, Appendix B limits. This condition results from an uncontrolled release of radioactivity to the environment, resulting in elevated offsite dose rates. The threshold for this EAL is NOT based on a specific offsite dose rate, but rather on the loss of plant control implied by a radiological release of this magnitude that was not isolated within 30 minutes. The final integrated dose is very low and is not the primary concern. Valid is defined as the High alarm actuating specifically due to a Gaseous EAL - 6.1.2.d Rev. 01 Page 1 of 3

HCGS EAL/RALTechnical Basis Release exceeding Technical Specification limits, thus precluding unwarranted event declaration

as the result of spurious actuation. Classification is based on an ongoing release that does not comply with a license condition. Unplanned is defined as any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions on the applicable permit.

The EAL value for Total Plant Vent release rate was determined using default X/Q values from the ODCM which provides a less accurate method of evaluation release magnitude then using dose assessment with real time meteorological data. For that reason, this EAL should not be utilized if Dose Assessment is available. Dose Assessment will take in account actual meteorological conditions, plant vent flows and plant vent effluent concentrations to provide a more accurate assessment of a radiological release. If Dose Assessment is available than refer to EAL 6.1.2a for classification.

The Total Plant Vent release rate can be obtained from SPDS or by adding up NPV, SPV, FRVS and HTV noble gas readings.

It is not intended that the release be averaged over 30 minutes, but exceed 200 times 10CFR20, Appendix B limits for 30 minutes or longer. In addition, it is intended that the event be declared as soon as it is determined that the release will exceed 200 times the limit for 30 minutes or longer.

Barrier Analysis N/A ESCALATION CRITERIA Emergency Classification will escalate to a Site Area Emergency when effluent release concentration increases to a level that would cause a 100 mRem dose at the Protected Area Boundary DISCUSSION The release rate threshold for this EAL is obtained by multiplying the 10CFR20, Appendix B Limit release rates of 2.4E+03 gxCi/sec for Noble Gases times 200. Total Noble Gas release rate is the summation of all plant vent release rates.

10CFR20, Appendix B Limit Calculation for Noble Gas uCi/Second = 100 mRem/year * (Allocation Factor)

(ODCM X/Q) * (ODCM DRCF)

EAL - 6.1.2.d Rev. 01 Page2 of 3

HCGS EAL/RALTechnical Basis WHERE: uCi/Second = Total Noble Gas Release Rate from Salem (Unit 1 & Unit 2) or Hope Creek (all Vents; NPV, SPV, FRVS, and HTV) which would result in a TEDE Dose Rate of 50 mRem/year.

ODCM X/Q Site Specific (Salem or Hope Creek) dispersion factor at the Site Boundary in sec/m 3 .

ODCM DRCF = Site Specific (Salem or Hope Creek) dose rate conversion factor in mRem/year/uCi/m 3 .

ODCM X/Q = 2.67E-06 sec/m3 3

ODCM DRCF = 7.80E+03 mRem/yr/uCi/m Allocation Factor = 5.OOE-01 2.40E+03 uCi/Second = (100 mRemLyear) * (5.00E-0 1)

(2.67E-06 sec/m 3 ) * (7.80E+03 mRem/yr/uCi/m 3 )

2.40E+03 ýtCi/sec

200 = EAL value.

4.80E+05 pCi/sec = EAL value DEVIATION The value for EAL 6.1.2.d is based on one meteorological case and one isotopic mixture found in the ODCM. A radiological release based on this specific release rate could produce a TEDE Dose which would require a General Emergency classification or not meet the Alert classification, depending on the meteorological conditions and the isotopic mixture. EAL 6.1.2.d would not be used unless EAL 6.1.2.a (Dose Assessment) can not be used to determine the classification, if any, due to the potential uncertainty of this "default" EAL.

Two hundred times the I0CFR20, Appendix B limits of noble gas is being used for this EAL, due to concerns that the State of New Jersey had pertaining to this EAL and based on the above mentioned uncertainties.

The time limit has been increased from 15 minutes-to 30 minutes, to allow additional time to perform dose assessment, since the threshold for this EAL is only 20% of the value allowed per NESP-007 and we do not wish to use this "default" EAL, unless absolutely necessary.

REFERENCES NUMARC NESP-007, AAI.1, AA1.4 OP-AB.ZZ-126(Q), Abnormal Releases of Gaseous Radioactivity Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3.11.2.1 EAL - 6.1.2.d Rev. 01 Page3 of 3

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release SITE AREA EMERGENCY-- 6.1.3.a IC Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds .100 mRem Total Effective Dose Equivalent (TEDE) or 500 mRem Thyroid CDE Dose for the actual or projected duration of the release EAL Dose Assessment indicates EITHER one of the following at the MEA or beyond as calculated on the SSCL:

" TEDE 4-Day Dose of > 1.OE+02 mRem

Thyroid-CDE Dose of > 5.OE+02 mRem based on Plant Vent effluent sample analysis and NOT on a default Noble Gas to Iodine Ratio OPERATIONAL CONDITION - All BASIS The TEDE 4-Day Dose of> 1.OE+02 mRem corresponds directly to the NUMARC dose of 100 mRem.

The Thyroid-CDE Dose of> 5.OE+02 mRem corresponds directly to the NUMARC dose of 500 mRem.

Dose Assessment using actual meteorological data provides an accurate indication of release magnitude. The use of dose assessment based EALs is therefore preferred over the use of Release Rate based EALs which utilize calculations which have built-in inaccuracies because ODCM default Meteorological data is used. Imminent is defined as expected to occur within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Barrier Analysis N/A EAL - 6.1.3.a Rev. 01 Pagel of 2

HCGS EAL/RALTechnical Basis ESCALATION CRITERIA Emergency Classification escalates to a General Emergency when actual or projected doses exceed EPA Protective Action Guidelines.

DISCUSSION This value provides a desirable gradient (one order of magnitude) between the Site Area Emergency and General Emergency classifications. No site allocation factor (.5) is used in this calculation due to the assumption that releases of this magnitude will be from one site.

The dose projection code assumes a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months release utilizing current 15 minute average release rate data. For the TEDE 4-Day Dose, 100 mRem/hr

4 hr 400 mRem. For the Thyroid-CDE Dose, 500 mRem/hr

4 hr = 2000 mRem.

DEVIATION None REFERENCES

. NUMARC NESP-007, AS 1.3 EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents NUMARC Draft White Paper, 7-25-94, 9-10-94 EAL - 6.1.3.a Rev. 01 Page 2 of. 2

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release SITE AREA EMERGENCY - 6.1.3.b IC Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mRem Total Effective Dose Equivalent (TEDE) or 500 mRem Thyroid CDE Dose for the actual or projected duration of the release EAL Dose Rate measured at the Protected Area Boundary or beyond EXCEEDS 100 mRem/hr AND Release is expected to continue for > 15 minutes OPERATIONAL CONDITION - All BASIS An actual dose rate of 100 mRem/hr which is expected to continue for >15 minutes indicates a substantial radiological release which could exceed the 10CFR20 annual average population exposure limit of 100 mRem TEDE, using the assumption of a one hour release duration.

Barrier Analysis N/A ESCALATION CRITERIA Emergency Classification will escalate to a General Emergency when actual or projected doses exceed EPA Protective Action Guidelines.

DISCUSSION An actual dose of 100 mRem Total Effective Dose Equivalent (TEDE).is based on the 10CFR20 annual average population exposure limit. Unless otherwise indicated, the conversion from whole body dose to TEDE is 1: 1. Measured dose rates will be taken at the Protected Area Boundary, and a >15 minute release duration threshold will be applied to be conservative.,

EAL - 6.1.3.b Rev. 01 Page 1 of 2

HCGS EAL/RALTechnical Basis DEVIATION None REFERENCES NUMARC NESP-007, AS 1.4 EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents NUMARC Draft White Paper, 7-25-94, 9-10-94 EAL - 6. 13.b Rev. 01 Page 2 of 2

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release SITE AREA EMERGENCY- 6.1.3.c IC Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mRem Total Effective Dose Equivalent (TEDE) or 500 mRem Thyroid CDE Dose for the actual or projected duration of the release EAL Analysis of field survey samples at the Protected Area Boundary indicates EITHER one of the following:

0 > 4.36E+02 CCPM

> 3.85E-07 ltCi/cc 1-131 OPERATIONAL CONDITION - All BASIS The Corrected Counts per Minute (CCPM) value is based on reading(s) obtained using a radiation count rate meter such as a RM-14 or E-140N with an HP260 probe attached. The Iodine-131 field survey sample concentration threshold is based on 1-131 dose conversion factors from EPA-400. The thresholds are based on a Thyroid-CDE dose rate of 500 mRem/hr for I-131.

Barrier Analysis N/A ESCALATION CRITERIA Emergency Classification will escalate to a General Emergency when actual or projected doses exceed EPA Protective Action Guidelines.

EAL - 6.1 3.c Rev. 01 Pagel of 3

HCGS EAL/RALTechnical Basis DISCUSSION The release sample concentration calculations are as follows.

The sample concentration is calculated using the 1-131 Dose Conversion Factor from EPA-400:

Solving the following equation for jiCi/cc:

mRem/hr = (tCi/cc) (Dose Conversion Factor)

Then; 1-131 Sample Concentration 0+0mRem/ /Ci/cr / 3.85E-07 1.30E + 09m Rem / AuCi /cc /hr 38E0ji/c Where 1.30E+09 mRem/iCi/cc/hr is the Dose Conversion Factor from EPA-400, Table 5-4 and includes the EPA-400 breathing rate.

The Corrected Counts per Minute reading is calculated using the 1-131 Sample concentration, and factors for using an RM-14 or E-140N with an HP260 probe.

. Solving the following equation for CCPM:

gCi/cc = CCPM 3 (Detector Efficiency)(Collection Efficiency)(Conversion Factor - DPM to pCi)(Volume - ft )(Conversion Factor - cc to it3 Then; CCPM = (3.85E-07 p.Ci/cc) (2.OOE-03 CCPM/DPM) (0.9) (2.22E+06 DPNM/pCi) *

(10 ft3 ) (2.832E+04 cc/ft3) = 4.36E+02 CCPM Where:

2. OOE-03 - DetectorEfficiency - CCPM/DPM

0. 9 (or 90%) = Collection Efficiency 2.22E+06 = Conversionfactor - DPM/ICi 10 ft 3 = Volume 2.832E+04 Conversionfactor - cc tofi3 CCPM = Corrected Counts per Minute using an RM-14 or E-140N with an HP260probe.

EAL- 6.1.3.c Rev. 01 Page 2 of 3

HCGS EAL/RALTechnical Basis DEVIATION

. None REFERENCES NUMARC NESP-007, AS1.4 EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents FEMA REP-2, Rev. 1, 7/87, Guidance on Offsite Emergency Radiation Measurement Systems, Phase-I Airborne Release SORC Summary 07/10/89 RPCS Thyroid Dose Commitment Factor Paper (NRP-94-0557), 11/22/94 EAL - 6.1.3.c Rev, 01 Page 3 of 3

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release SITE AREA EMERGENCY - 6.1.3.d IC Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mRem Total Effective Dose Equivalent (TEDE) or 500 mRem Thyroid CDE Dose for the actual or projected duration of the release EAL Valid High Alarm received from ANY of the following Effluent RMS Channels:

" FRVS Noble Gas (Grid 1/3; 9RX680)

. NPV Noble Gas (Grid 1/3; 9RX590)

SPY Noble Gas (Grid 1/3; 9RX580)

HTV Noble Gas. (Grid 3; 9RX516)

AND Total Plant Vent release rate EXCEEDS 7.6E+07 giCi/sec Total Noble Gas AND Dose Assessment results NOT available AND Release is ongoing for > 15 minutes OPERATIONAL CONDITION - All BASIS Valid High alarm and effluent release rate values exceeding the EAL threshold, indicates a substantial Gaseous Radiological Release which could exceed the 10CFR20 average annual population exposure limit of 100 mRem TEDE, using the assumption of a one hour release duration.

The EAL value for Total Plant Vent release rate was determined using default X/Q values from the ODCM which provides a less accurate method of evaluation release magnitude then using EAL - 6,1.3.d Rev. 01 Page 1 of 3

HCGS EAL/RALTechnical.Basis dose assessment with real time meteorological data. For that reason, this EAL should not be utilized if Dose Assessment is available. Dose Assessment will take in account actual meteorological conditions,plant vent flows and plant vent effluent concentrations to provide a more accurate assessment of a radiological release. If Dose Assessment is available then refer-to EAL 6.1.3.a for classification.

The Total Plant Vent release rate can be obtained from SPDS or by adding up NPV, SPV, FRVS and HTV noble gas readings.

It is not intended that the release be averaged over 15 minutes, but that the Release Rate exceed the EAL value for > 15 minutes.

Barrier Analysis N/A ESCALATION CRITERIA Emergency Classification will escalate to a General Emergency when effluent release concentration increases to a level that would cause a 1000 mRem dose at the Protected Area Boundary.

DISCUSSION To obtain a site specific value to trigger the performance of dose assessment is not necessary, since this will be done when the UE value is reached. This value will supply a set point to classify a Site Area Emergency (SAE), if dose assessment has not been performed within 15 minutes.

A release rate of 7.6E+07 [tCi/sec was back calculated from a TEDE Dose of 100 mRem/hour at the Site MEA. The assumptions that went into this calculation were as follows:

Release Point: FRVS Release Rate: 9000cfln 3

ODCM X/Q = 2.67E-06 sec/mi Isotopic mixture: FSAR isotopic mixture for a design basis LOCA Dose Rate Conversion Factors: EPA 400-R-92-001 (Manual of Protective Actions for Nuclear Incidents) Dose Rate Conversion Factors.

EAL - 6.1.3.d Rev. 01 Page2 of 3

HCGS EAL/RALTechnical Basis DEVIATION The NUJMARC basis states that the FSAR source term assumptions should be used in determining the indications for monitors. The NUMARC Draft White Paper states the FSAR source term should not be used unmodified.

This NUMARC EAL is calculated using the FSAR Isotopic Mixture for a Design Basis LOCA and the Dose Rate Conversion Factors found in EPA 400-R-001. The combination of using the FSAR Isotopic mixture and the EPA 400 dose Rate Conversion Factors calculate an accurate accident source term.

REFERENCES NUMARC NESP-007, AS 1.1, AS 1.4 OP-AB.ZZ-126(Q), Abnormal Releases of Gaseous Radioactivity Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94, 9-10-94.

ODCM3.11.2.1 FSAR Section 15 EPA 400-R-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents EAL - 6.1.3.d Rev. 01 Page3 of 3

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release GENERAL EMERGENCY - 6.1.4.a IC Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 1000 mRem Total Effective Dose Equivalent (TEDE) or 5000 mRem Thyroid CDE Dose for the actual or projected duration of the release EAL Dose Assessment indicates EITHER one of the following at the MEA or beyond as calculated on the SSCL:

TEDE 4-Day Dose of > 1.OE+03 mRem 0 Thyroid-CDE Dose of > 5.OE+03 mRem based on Plant Vent effluent sample analysis and NOT on a default Noble Gas to Iodine Ratio OPERATIONAL CONDITION - All BASIS The TEDE 4-Day Dose of> 1.OE+03 mRem corresponds directly to the NUMARC dose of 1000 mRem which exceeds EPA Protective Action Guideline criteria for a General Emergency.

The Thyroid-CDE Dose of > 5.OE+03 mRem corresponds directly to the NUMARC dose of 5000 mRem which exceeds EPA Protective Action Guideline criteria for a General Emergency.

Imminent is defined as expected to occur within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Barrier. Analysis N/A ESCALATION CRITERIA N/A EAL - 6.1.4.a Rev. 01 Page l of 2

HCGS EAL/RALTechnical Basis DISCUSSION No site allocation factor (.5) is used in this calculation due to the assumption that releases of this magnitude will be from one site.

DEVIATION None REFERENCES NUMARC NESP-007, AG1.3 EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents NLJMARC Draft White Paper 7-25-94, 9-10-94 EAL - 6.1.4.a Rev. 01 Page 2 of 2

HCGS EALURALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release GENERAL EMERGENCY - 6.1.4.b IC Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 1000 mRem Total Effective Dose Equivalent (TEDE) or 5000 mRem Thyroid CDE Dose for the actual or projected duration of the release EAL Dose Rate measured at the Protected Area Boundary or beyond EXCEEDS 1000 mRem/hr AND Release is expected to continue for > 15 minutes OPERATIONAL CONDITION - All BASIS An actual dose rate of 1000 mRem/hr indicates the EPA Protective Action Guide may be exceeded for the general public.

Barrier Analysis N/A ESCALATION CRITERIA N/A DISCUSSION An actual projected dose of 1000 mRem Total Effective Dose Equivalent (TEDE) is based on the EPA protective action guidance which indicates that public protective actions are indicated if the dose exceeds 1 Rem whole body. This is consistent with the emergency class description for a General Emergency. A release rate equivalent to 1000 mRemihr boundary dose rate may also be used if TEDE projections are not available. Unless otherwise indicated, the conversion from whole body dose to TEDE is 1: 1.

EAL - 6.14.b Rev. 01 Pagel of 2

HCGS EAL/RALTechnical Basis DEVIATION None REFERENCES NUMARC NESP-007, AG1.4 EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents EAL - 6.1.4.b Rev. 01 Page2 of 2

HCGS EAL/RALTechnical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release GENERAL EMERGENCY - 6.1.4.c IC Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 1000 mRem Total Effective Dose Equivalent (TEDE) or 5000 mRem Thyroid CDE Dose for the actual or projected duration of the release EAL Analysis of field survey samples at the Protected Area Boundary indicates EITHER one of the following:

> 4.36E+03 CCPM

> 3.85E-06 tCi/cc 1-131 OPERATIONAL CONDITION - All BASIS The Corrected Counts per Minute (CCPM) value is based on reading(s) obtained using a radiation count rate meter such as a RM-14 or E-140N with an HP260 probe attached. The Iodine-131 field survey sample concentration threshold is based on 1-131 dose factors from EPA-400. The thresholds are based on a dose rate of 5000 mRemihr Thyroid-CDE for 1-131.

Barrier Analysis N/A ESCALATION CRITERIA N/A DISCUSSION The release sample concentration calculations are as follows.

The sample concentration is calculated using the 1-131 Dose Conversion Factor from EPA-400:

EAL - 6.1,4.c Rev. 01 Page a of 3

HCGS EAL/RALTechnical Basis Solving the following equation for !ICi/cc:

mRem/hr = (tCi/cc) (Dose Conversion Factor)

Then; 1-13] Sample Concentration 5000mRem / hr 1.30E + 09m Rem / /_Ci / cc / hr ) = 3.85E-06 pCi/cc Where 1.30E+09 mRem/gCi/cc/hr is the Dose Conversion Factor from EPA-400, Table 5-4 and includes the EPA-400 breathing factor.

The Corrected Counts per Minute reading is calculated using the 1-131 Sample concentration, and factors for using an RM-14 or E-140N with an HP260 probe.

Solving the following equation for CCPM:

[LCi/cc = CCPM 3 3 (Volume - ft ) (Conversion Factor - cc to ft )

(Detector Efficiency) (Collection Efficiency) (Conversion Factor - DPM to PQCi)

Then; CCPM = (3.85E-06 pCi/cc) (2.00E-03 CCPM/DPM) (0.9) (2.22E+06 DPM/pCi) (10 ft3 ) *

(2.832E+04 cc/ft3) = 4.36E+03 CCPM Where:

2.00E-03 = DetectorEfficiency - CCPM/DPM 0.9 (or 90%) Collection Efficiency 2.22E+06 1o0ft3 = Conversionfactor - DPM/flCi

=

Volume 3

2.832E+04 = Conversionfactor - cc to ft CCPM = Corrected Counts per Minute using an RM-14 or E-140N with an HP260probe.

DEVIATION None EAL - 6.1.4.c Rev. 01 Page 2 of 3

HCGS EAL/RALTechnical Basis REFERENCES NUMARC NESP-007, AG1.4 EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents FEMA REP-2, Rev. 1/July 1987, Guidance on Offsite Emergency Radiation Measurement Systems, Phase-I Airborne Release SORC Summary 07/10/89 RPCS Thyroid Dose Commitment Factor paper NRP-94-0557, 11-22-94 EAL - 6.1.4.c Rev. 01 Page 3 of 3

HCGS EAU/RALTechriical Basis 6.0 Radiological Releases/Occurrences 6.1 Gaseous Effluent Release GENERAL EMERGENCY - 6.1.4.d IC Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 1000 mRem Total Effective Dose Equivalent (TEDE) or 5000 mRem Thyroid CDE Dose for the actual or projected duration of the release EAL Valid High Alarm received from ANY one of the following Plant Effluent RMS Channels:

FRVS Noble Gas (Grid 1/3; 9RX680)

NPV Noble Gas (Grid 1/3; 9RX590) 0 SPV Noble Gas (Grid 1/3; 9RX580)

HTV Noble Gas (Grid 3; 9RX516)

AND Total Plant Vent release rate EXCEEDS 7.6E+08 piCi/sec Total Noble Gas AND Dose Assessment results NOT available AND Release is ongoing for > 15 minutes OPERATIONAL CONDITION - All BASIS Valid High alarm and effluent release rate values exceeding the EAL threshold, indicates a substantial Gaseous Radiological Release which could exceed the EPA Protective Action Guide exposure of 1000 mRem TEDE, using the assumption of a one hour release duration.

The EAL value for Total Plant Vent release rate was determined using default X/Q values from the ODCM which provides a less accurate method of evaluation release magnitude then using dose assessment with real time meteorological data. For that reason, this EAL should not be EAL - 6.1.4.d Rev. 01

.Page 1 of 3

HCGS EAL/RALTechnical Basis utilized if Dose Assessment is available. Dose Assessment will take into account actual

meteorological conditions, plant vent flows and plant vent effluent concentrations to provide a more accurate assessment of a radiological release. If Dose Assessment is available then refer to EAL 6.1..4.a for classification.

The Total Plant Vent release rate can be obtained from SPDS or by adding up NPV, SPV, FRVS and HTV noble gas readings.

It is not intended that the release be averaged over 15 minutes, but that the Release Rate exceed the EAL value for >15 minutes.

Barrier Analysis N/A ESCALATION CRITERIA None DISCUSSION To obtain a site specific value to trigger the performance of dose assessment is not necessary,

since this will be done when the UE value is reached. This value will supply a set point to classify a General Emergency (GE), if dose assessment has not been performed within 15 minutes.

A release rate of 7.6E+08 gCi/sec was backcalculated from a TEDE Dose of 1000mRem/hour at the Site MEA. The assumptions that went into this calculation were as follows:

Release Point: FRVS Release Rate: 9000cfm 3

ODCM X/Q = 2.67E-06 sec/m Isotopic mixture: FSAR isotopic mixture for a design basis LOCA Dose Rate Conversion Factors: EPA 400-R-92-001 (Manual of Protective Actions for Nuclear Incidents) Dose Rate Conversion Factors.

DEVIATION The NUMARC basis states that the FSAR source term assumptions should be used in determining the indications for monitors. The NUMARC Draft White Paper states the FSAR source term should not be used unmodified.

EAL - 6A.4.d Rev. 01 Page 2 of 3

HCGS EAURALTechnical Basis This NUMARC EAL is calculated using the FSAR Isotopic Mixture for a Design Basis LOCA and the Dose Rate Conversion Factors found in EPA 400-R-001. The combination of using the FSAR Isotopic mixture and .the EPA 400 dose Rate Conversion Factors calculate an accurate accident- source term.

REFERENCES NUMARC NESP-007, AGI.1, AG1.4 OP-AB.ZZ-126(Q), Abnormal Releases of Gaseous Radioactivity Off-Site Dose Calculation Manual, Section 2.0 - Gaseous Effluents NUMARC Draft White Paper, 7-25-94, 9-10-94.

Technical Specification 3.11.2.1 FSAR Section 15 EPA 400-R-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents EAL - 6.1.4.d Rev. 01 Page 3 of 3

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