Text

Enclosure 2 to Fple Letter SBK-L-06227 - Emergency Initiating Condition Matrix, Modes 1, 2, 3, & 4
	ML073110410
Person / Time
Site:	Seabrook
Issue date:	10/17/2007
From:	; Florida Power & Light Energy Seabrook
To:	; Office of Nuclear Reactor Regulation
References
	SBK-L-06227
	Download: ML073110410 (90)
	v • d • e

EMERGENCY INITIATING CONDITION MATRIX Modes 1, 2, 3 and 4 Unu uaIEi,&t ALERT ry A -Abnormal Rad LevelslRadlologlcal Effluent ".... : Any UNPLANNED release of AA1 , Any UNPLANNED release of gaseous gaseous or liquid radioactiity to the or liquid radioactivity to the environment environment

> 2 times the ODCM >1 v 200 times the ODCM limits for ? 15 limits for a 60 minutes minutes Op. Modes: All 7' Op. Modes., All , AA2 Damage to irradiated fuel or loss of twaer level that has or will resutt in the uncovering of irradiated fuel outside the reactor vessel Op. Modes: All Uneoxpected increase in plant ----.AA3 Release of radioactive material or radiation increases in radiation levels within the Op. Modes: All facility that impedes operation of systems required to maintain safe operations or to establish or maintain cold shutdown Op. Modes: Al Actual or projected offsite dose s 1.000 mRem TEDE or 5,000 rnRem Thyroid CDE Op. Modes: All Op. Modes: All* CategoryE w EnReIatedto ISFSI.Malfunction

.: 0- OI Damage to a loaded cask CONFINEMENT BOUNDARY Op. Mode: AM affecting the PROTECTED AREA Op. Modes All FIRE within PROTECTED AREA boundary not extinguished within 15 minutes of detection Op. Modes: All Release of toxic, corrosive.

asphyxiant or flammable gases deemed detrimental to normal operation of the plant Op. Modes: All Confirmed security event which indicates a potential degradation In the level of safety of the plant Op. Modes: All Other conditions existing which in the judgment of the STED/SED warrant declaration of an Unusual Event Op. Modes: All cftng Pli'ht'Sfety Natural and destructive phenomena affecting the plant VITAL AREA Op. Modes: All FIRE or EXPLOSION affecting the operability of plant safety systems required to establish or maintain safe shutdown Op.: Modes: All Release of a toxic. corrosive.

asphyxiant or flammable gas within or contiguous to a VITAL AREA affecting equipment required to maintain safe operations, or establish or maintain safe shutdown Op. Modes: All Confirmed security event in a plant PROTECTED AREA Op. Modes: All Notification of HOSTILE ACTION within the OCA Op. Modes: All Notification of an airbome attack threat Op. Modes: All Control Room evacuation has been initiated Op. Modes: All-------------------------

Other conditions existing which in the judgment of the STED/SED warrant declaration of an Alert Op. Modes: Al Notification of HOSTILE ACTION within the PROTECTED AREA Op. Modes:. Aft Security event resulting in loss of physical control of the facility Op. Modes: All Malfunction:

Loss of all offsite power to AC SAS Power to AC emergency buses emergency buses for > 15 minutes = reduced to a single power source for Op. Modes: 1, 2 3,4 ' >/ >15 minutes such that any additional single failure would result in station blackoutOp. Modes:, 2,3,4ýsA2 ATiWS and manual trip from the MCB was successful Op. Modes: t, 2, 3 Inability to reach required shutdown within Technical Specification limits-Op. Modes: 1, Z3, 4.UNPLANNED oss of most or all SA?,4 UNPLANNED loss of most or all safety safety system annunciation or system annunciation or indication in indication in the Control Room for r Control Room with either (1) a>15 minutes i,;vyi$ SIGNIFICANT TRANSIENT in Op. Modeo: 1, 2, 3, 4 progress, or (2) compensatory non, alamning indicators are unavailable

pModes: 1, 2, 3,4 -Fiuet ctad degradation Op. Modes: 1, 2, 3, 4 RCS -1eaka-ge

Op. Modes.: 1, 2, 3, 4 ,'-UNPLANNED loss of all onsite or offsite communications capabilities Op. Modes: f, 2 3, 4 Control Room evacuation has been initiated and plant control cannot be established Op. Modes: Aft Other conditions existing which in the judgment of the STED/SED warrant declaration of Site Area Emergency Op. Modes: All Loss of both AC emergency buses for> 15 minutes Op. Modes: 1, 2, 3, 4 ATWS and manual trip from the MCB was NOT successful Op. Modes: 1. 2 Loss of all vital DC power for > 15 minutes Op. Modes: 4, 2, 3, 4 Inability to monitor a SIGNIFICANT TRANSIENT in progress Op. Modes: 1, 2, 3, 4 Other conditions emisting which in the judgment of the'STEDISED warrant declaration of General Emergency Op. Modes: All Prolonged loss of both AC emergency buses Op. Modes: 1, 2, 3, 4 AIrS and manual trip from the MCB was NOT successful.

AND extreme challenge to Core Cooling or Heat Sink Op. Modes: ., 2 Inadver tent criticality Op Modes: 3. 4 ER 1.1A Rev. A EMERGENCY INITIATING CONDITION MATRIX Modes 5, 6 and Defueled~Ui&-dE-nl

~ .ALERTh ~v A -Abnormal Rad Levels/Radiologlcal Effluent Any UNPLANNED release of 'AAEi1 Any UNPLANNED release of gaseous Actual or projected offsite dose > 100 gaseous or liquid radioactivity to the or liquid radioactivity to the environment mRem TEDE or 500 mRem Thyroid environment

> 2 times the ODCM , y 200 times the ODCM limits for 2:15 CDE limits for 5 60 minutes minutes Op. Modes: All OP. Modes:, All ~ h~Op. Modes:, All AA2 Damage to irradiated fuel or loss of water Jevel that has or wil result in the uncoveringvof irradiated fuel outside the.Op. Modes: All Unexpected increase in plant --AA,3 Release of radioactive materaIl or radiation increases in radiation levels within the Op. Modes,: AM facility that impedes operation of 4 systems required to maintain safe operations or to establish or maintain cold shutdown Op. Modes: All Actual or projected offsite dose> 1,000 mRem TEDE or 5,000 mRem Thyroid CDE Op. Modes: All p o -~ven0s tqerarea so tol-ci MOItUflCOOfl 0r ry E: ýEvents Related to ISFSl Malfunction:.;

7 .: .,: .: .: -.:. :: :-:;.;.: : : .. : .. .-. .: Damage to a loaded cask CONFINEMENT BOUNDARY Op. Mode: All Other Conditlons Affecltng.Plant Safety Natural and destructive phenomena

.HAI Natural and destructive phenomena affecting the PROTECTED AREA affecting the plant VITAL AREA Op. Modes: All Op. Modes: All FIRE within PROTECTED AREA ---gHIA2 FIRE or EXPLOSION affecting the boundary not extinguished within 15 1 operability of plant safety systems minutes of detection , required to establish or maintain safe Op. Modes: All shutdown------ Op. Modes: All Release of -oic, corrosive, HA3 Release of a tooic. corrosive.

asphyxiant or flammable gases; asphyxiant or flammable gas within or deemed detrimental to normal contiguous to a VITAL AREA affecting operation of the plant 4 aequipment required to maintain safe Op. Modes: Af" .operations, or establish or maintain safe shutdown Confirmed security evoat which --- .HA44 Confirmed security event in a plant indicates a potential degradation in PROTECTED AREA the level of safety of the plant Op Modes: All op. Modes: All ',i HA8 Notification ot HOSTILE ACTION within: the OCA Op. Modes:All;yHA7: Notification of an airbone a kack threat i~l Op. Modes:, All* HA5 Control Room evacuation has been initiated , Op. Modes: All Other conrditioos existing which in the HA6 Other conditions existing which in the judgment of the STED/SED warrant j' udgment of the STEDISED warrant declaration of an Unusual Event i declaration of an Alert Op. Modes: All Op. Modes: All Elam I Notification of HOSTILE ACTION within the PROTECTED AREA Op. Modes: All Control Room evacuation has been initiated and plant control cannot be established Op. Modes: All-6Other conditions existing which in the judgment of the STEDISED warrant declaration of Site Area Emergency Op. Modes: All Security event resulting in loss of physical control of the facility Op. Modes: All Other conditions existing which in the judgment of the STEDISED warrant declaration of General Emergency Op. Modes: All Loss of RCS or reactor vessel inventory with irradiated fuel in the reactor vessel AND containment challenged Op. Modes: 5, 6'old ShutdownlRefuellng System Malfunction.

RCS leakage CAI Loss of RCS inventory Op. Mode: 5 *Op Mooa:'5 UNPLANNED, lo.s ofreactor vessel CA .Ls ofactsr v l ,inventory with inventory with irradiated fuel in the irradiated fuel in the reactor vessel reactor vessel Op. Mode: 6 Op. Mode: 6-Los- ;f-a1 -ii -Wto- AC ........ ; CA 'oLoss-o;fboth AC -e- merg-eybs

--for emergency buses for > 15 minutes .15 minutes Op. Modes: 5, 6

Ii Op Modes: 5, 6. Defueled UNPLANNED coos of devay heat -CA4- Inability to mnaintain plant in cod removal capability with irradiated fuel ..' shutdown with irradiated fuel in the in the reactor vessel -reactor vessel Op. Modes: 5. 6 ", Op. Modes: 5, 6 Fuel clad degradation

Op. Mode: 5 UNPL1ANNED toss. o~f alt'o-n'sit-eo 0---offsite communicatons capabilities

1 Op. Modes: 5, 6 power for > 15 minutes Op. Modes: 5, 6ýInoart criticality Op Modes:, 5, 6 Loss of RCS inventory affecting core decay heat removal capability Op. Mode: 5 Loss of reactor vessel inventory affecting core decay heat removal capability with irradiated fuel in the reactor vessel Op. Mode: 6..............................ER i.C Rev. A COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/G Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition A UI Any UNPLANNED Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds Two Times the Radiological Effluent Technical Specifications for 60 Minutes or Longer.0o. Modes: All Initiating Condition AU1 Any UNPLANNED release of gaseous or liquid radioactivity to the environment

> 2 times the ODCM limits for > 60 minutes Op. Modes: All Difference The Seabrook Station radiological effluent/release limits are specified in the ODCM.Emergency Action Level(s)1. VALID reading on any effluent monitor that exceeds two times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.OR 2. VALID reading on one or more of the following radiation monitors that exceeds the reading shown for 60 minutes or longer: (site-specific list)OR r-mul ulluy mulull L VVwl(W 1. -a. VALID reading on any of the following effluent monitors that exceeds two times the value of the current high-alarm setpoint for 60 minutes or longer." RM-6509-1 (WTT Disch)* RM-6521-1 (TB Sump)* RM-6519-1 (SG Blowdown)* RM-6473-1 (WT LIQ EFF)" RM-6528-4 (WRGM rate)AND b. The discharge flow to the environment is not isolated within 60 minutes.OR Added site-specific list of effluent radiatio monitors for which the "high-alarm setpoint" corresponds to the value of the"current radiological discharge permit".Added EAL 1 .b to address site-specific design. The discharge flowpaths associated with RM-6509-1, 6521-1, 6519-1, and 6473-1 have automatic and manual flow isolation capability.

An Unusual Event will be declared if the discharge flow is not isolated within the time criteria associated with EAL 1 .a (i.e., 60 minutes).

This aligns the EAL with the IC wording "to the environment" and the basis discussion.

Not applicable; Seabrook Station has no effluent monitors that both meet the basis discussion criteria and are on-scale (i.e., provide valid readings) for release rates meeting the IC definition.

Not used.OR Page 1 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/NEI9901,Re.

4Sebrok tatonDifference!

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation 3. Confirmed sample analyses for 2. Confirmed sample analysis for a Difference The Seabrook Station radiological gaseous or liquid releases indicates gaseous or liquid release indicates effluent/release limits are specified in the concentrations or release rates, with a concentrations or release rates in ODCM. Reworded EAL statement to release duration of 60 minutes or excess of two times ODCM allowable improve readability.

Included document longer, in excess of two times (site- limits, with a release duration of 60 reference to location of limits specified in specific technical specifications).

minutes or longer. ODCM.* Limits are specified in ODCM, Part A, Section 6 (liquid) and Section 7 (gaseous)OR 4. VALID reading on perimeter radiation Not used. Per basis discussion, this EAL was not monitoring system greater than 0.10 used since Seabrook Station does not mRPhr above normal background have telemetered perimeter monitors.sustained for 60 minutes or longer [for sites having telemetered perimeter monitors].

OR 5. VALID indication on automatic real- Not used. Per basis discussion, this EAL was not time dose assessment capability used since Seabrook Station does not greater than (site-specific value) for 60 have automatic real-time dose assessment minutes or longer [for sites having capability.

such capability].

The intent and meaning of the IC and EALs are not altered.Page 2 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 1 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) I Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation D e v ia t io n ........ .... ...... .. ... ..... ........Initiating Condition A U2 Unexpected Increase in Plant Radiation.

n- AA,,,*,,--

All Initiating Condition A U2 Unexpected increase in plant radiation Verbatim I N/A 1. a. VALID (site-specific) indication of uncontrolled water level decrease in the reactor refueling cavity, spent fuel pool, or fuel transfer canal with all irradiated fuel assemblies remaining covered by water.AND b. Unplanned VALID (site-specific)

Direct Area Radiation Monitor reading increases OR 2. Unplanned VALID Direct Area Radiation Monitor readings increases by a factor of 1000 over normal*levels.*Normal levels can be considered as the highest reading in the past twenty-four hours excluding the current peak value.a. VALID indication of uncontrolled water level decrease in the reactor refueling cavity, spent fuel pool, or fuel transfer canal with all irradiated fuel assemblies remaining covered by water.AND 111Uuuuu 51M.-bpeULAL;u quipinum identification

-the installed area radiation monitors.b. UNPLANNED and VALID reading increase on one of the following Area Radiation Monitors." RM-6535-A-1, Containment Manipulator Crane" RM-6535-B-1, Containment Manipulator Crane" RM-6549-1, FSB Spent Fuel Range Low" RM-6518-1, FSB Spent Fuel Range Hi OR 2. UNPLANNED and VALID increase in an Area Radiation Monitor reading by a factor of 1000 over normal* levels.*Normal levels can be considered as the highest reading in the past twenty-four hours excluding the current peak value.Editorial change in EALs #1 .b and #2 (added "and" between UNPLANNED and VALID).Changed monitor reference from plural to singular in EAL #2.The intent and meaning of the EALs are not altered.Page 3 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/!

Basis for Difference or Deviation a SDeviation Initiating Condition AA I Initiating Condition AA 1 ___________

K K Any UNPLANNED Release of Gaseous or Any UNPLANNED release of gaseous or Difference The Seabrook Station radiological Liquid Radioactivity to the Environment liquid radioactivity to the environment

> effluent/release limits are specified in the that Exceeds 200 Times the Radiological 200 times the ODCM limits for _> 15 ODCM.Effluent Technical Specifications for 15 minutes Minutes or Longer.Op. Modes: All Op. Modes: All Emergency Action Level(s) Emergency Action Level(s) : 1. VALID reading on any effluent monitor 1. a. VALID reading on any of the Difference Added site-specific list of effluent radiation that exceeds 200 times the alarm following effluent monitors that monitors for which the "high-alarm setpoint established by a current exceeds 200 times the value of the setpoint" corresponds to the value of the radioactivity discharge permit for 15 current high-alarm setpoint for 15 "current radiological discharge permit".minutes or longer. minutes or longer." RM-6509-1 (WTT Disch) Added EAL 1.b to address site-specific

RM-6521-1 (TB Sump) design. The discharge flowpaths* RM-6519-1 (SG Blowdown) associated with RM-6509-1, 6521-1, 6519-* RM-6473-1 (WT LIQ EFF) 1, and 6473-1 have automatic and manual" RM-6528-4 (WRGM rate) flow isolation capability.

An Alert will be AND declared if the discharge flow is not b. The discharge flow to the isolated within the time criteria associated environment is not isolated within 15 with EAL 1.a (i.e., 15 minutes).

This aligns minutes. the EAL with the IC wording "to the environment" and the basis discussion.

OR OR 2. VALID reading on one or more of the 2. a. VALID reading of> 10 mR/hr on one Difference Added site-specific radiation monitors and following radiation monitors that or more main steam line radiation reading corresponding to 200X the ODCM exceeds the reading shown for 15 monitors for 15 minutes or longer, dose rate. Added an "and" statement (2.b)minutes or longer:

RM-6481-1 (A) stipulating that there must be a release* RM-6482-1 (B) path to the environment, and included (site-specific list)

RM-6482-2 (C) examples.

This aligns the EAL with the IC* RM-6481-2 (D) wording "to the environment".

AND Page 4 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/NEI9901,Re.

4Sebrok tatonDifference!

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation b. Release path to the environment from affected steam line, e.g., open ASDV or SRV, line is faulted, open steam supply to 1-FW-P-37A, etc.OR OR 3. Confirmed sample analyses for 3. Confirmed sample analysis for a Difference The Seabrook Station radiological gaseous or liquid releases indicates gaseous or liquid release indicates effluent/release limits are specified in the concentrations or release rates, with a concentrations or release rates in ODCM. Reworded EAL statement to release duration of 15 minutes or excess of 200 times ODCM allowable improve readability.

Included'document longer, in excess of 200 times (site- limits, with a release duration of 15 reference to location of limits specified in specific technical specifications).

minutes or longer. ODCM.* Limits are specified in ODCM, Part A, Section 6 (liquid) and Section 7 (gaseous)OR 4. VALID reading on perimeter radiation Not used. Per basis discussion, this EAL was not monitoring system greater than 10.0 used since Seabrook Station does not mR/hr above normal background have telemetered perimeter monitors.sustained for 15 minutes or longer [for sites having telemetered perimeter Per basis discussion, this EAL was not monitors].

used since Seabrook Station does not OR have automatic real-time dose assessment

5. VALID reading on perimeter radiation Not used. capability.

monitoring system greater than 10.0 mR/hr above normal background The intent and meaning of the IC and sustained for 15 minutes or longer [for EALs are not altered.sites having telemetered perimeter monitors].

Page 5 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition AA2 Initiating Condition AA2 Damage to Irradiated Fuel or Loss of Damage to irradiated fuel or loss of water Verbatim N/A Water Level that Has or Will Result in the level that has or will result in the Uncovering of Irradiated Fuel Outside the uncovering of irradiated fuel outside the Reactor Vessel. reactor vessel Op. Modes: All Op. Modes: All Emergency Action Level(s) Emergency Action Level(s) , 1. A VALID (site-specific) alarm or 1. An UNPLANNED and VALID high- Difference Added site-specific radiation monitors.reading on one or more of the alarm, or reading in excess of the following radiation monitors: (site- current high-alarm setpoint, on one or Included UNPLANNED in EAL #1 to specific monitors) more of the following radiation exclude a reading or event that is the monitors:

result of an intended evolution and does" Refuel Floor Area Radiation Monitor not. require corrective action. Readings in" Fuel Handling Building Ventilation o RM-6518-1, FSB High Range excess the "high alarm setpoint" would Monitor a RM-6562-1, FSB Vent represent an actual or potential substantial" Refueling Bridge Area Radiation

RM-6535A-1, Manip Crane degradation of the level of safety of the Monitor

RM-6535B-1, Manip Crane plant, and require immediate assessment OR OR and corrective action.2. Water level less than (site-specific)

2. An irradiated fuel assembly is Due to station instrumentation design, feet for the reactor refueling cavity, uncovered in the reactor refueling visual observation (e.g., closed circuit TV)spent fuel pool and fuel transfer canal cavity, spent fuel pool .or fuel transfer will be the primary indicator for fuel that will result in irradiated fuel canal. uncovery in the specified locations.

uncovering.

The intent and meaning of the EALs are not altered.Page 6 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition AA3 Initiating Condition AA3 Release of Radioactive Material or Release of radioactive material or Verbatim N/A Increases in Radiation Levels Within the increases in radiation levels within the Facility That Impedes Operation of facility that impedes operation of systems Systems Required to Maintain Safe required to maintain safe operations or to Operations or to Establish or Maintain Cold establish or maintain cold shutdown Shutdown Op. Modes: All Op. Modes: All Emergency Action Level(s) Emergency Action Level(s) .1. VALID (site-specific) radiation monitor 1. VALID radiation monitor or survey Difference Added "survey readings" as an EAL criteria in readings GREATER THAN 15 mR/hr readings > 15 mR/hr in the Control case a radiation monitor is not available.

in areas requiring continuous Room, the Central Alarm Station occupancy to maintain plant safety (CAS) or the Secondary Alarm Included those siteospecific plant areas functions:

Station (SAS). requining continuous occupancy to maintain plant safety functions, and infrequent access to maintain plant safety functions.(Site-specific) list OR OR Included UNPLANNED in EAL #2 to exclude a 2. VALID (site-specific) radiation monitor 2. UNPLANNED and VALID radiation reading or event that is the result of an intended readings GREATER THAN <site monitor or survey readings > 1 R/hr in evolution and does not require corrective specific>

values in areas requiring areas requiring infrequent access to action.infrequent access to maintain plant maintain plant safety functions.

safety functions.

The 1 R/hr value defines a Locked High Radiation Area and meets the criteria in the* Diesel Generator Building basis discussion, i.e., would result in exposure (Site-specific) list 0 Remote Safe Shutdown Panels control measures intended to maintain doses* Main Steam & Feedwater Pipe within normal occupational exposure guidelines Chases and limits (i.e., 10 CFR 20)." Emergency Feedwater Pumphouse The intent and meaning of the EALs are not* Condensate Storage Tank altered.Enclosure* Turbine Building Page 7 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station .Verbatim/

Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation I Initiating Condition ASI Offsite Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mR TEDE or 500 mR Thyroid CDE for the Actual or Projected Duration of the Release.Oo. Modes: All Initiating Condition ASI Actual or projected offsite dose > 100 mRem TEDE or 500 mRem Thyroid CDE Difference Shortened IC description for easier reading i.e., the offsite doses in question can only result from an actual or imminent release of gaseous radioactivity.

Intent of IC statement was not chanqed. Dose is Note: If dose assessment results are available at the time of declaration, the classification should be based on EAL #2 instead of EAL #1. While necessary declarations should not be delayed awaiting results, the dose assessment should be initiated

/ completed in order to determine if the classification should be subsequently escalated.

1. VALID reading on one or more of the following radiation monitors that exceeds or is expected to exceed the reading shown for 15 minutes or longer: (site-specific list)Note:' If dose assessment results are available at the time of declaration, the classification should be based on EAL #2 instead of EAL #1. While necessary declarations should not be delayed awaiting results, the dose assessment should be initiated/

completed in order to determine if the classification should be subsequently escalated.

1. VALID reading on one or more of the following radiation monitors that exceeds, or is expected to exceed, the reading shown for 15 minutes or longer:* RM-6528-4 (WRGM rate): 2.85E+7 uCi/sec" RM-6481-1* (MSL A): See below" RM-6482-1* (MSL B): See below* RM-6482-2* (MSL C): See below" RM-6481-2* (MSL D): See below Difference Added site-specific radiation monitors and values. These monitors are associated with the plant vent and the main steam lines. Added asterisked note stipulating that there must be a release path to the environment from the main steam line(s), and included examples.

This aligns the EAL with the IC wording "to the environment" and the basis discussion.

Tsd -Time after shutdown.Trd-< 1 hr 1 hr < Tsd <- 2 hrs 2 hrs < Tsd < 5 hrs Tsd > 5 hrs 130 100 50 20 mR/hr mR/hr mR/hr mR/hr I Page 8 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation OR 2. Dose assessment using actual meteorology indicates doses greater than 100 mR TEDE or 500 mR thyroid CDE at or beyond the site boundary.OR 3. A VALID reading sustained for 15 minutes or longer on perimeter radiation monitoring system greater than 100 mR/hr. [for sites having telemetered perimeter monitors]OR 4. Field survey results indicate closed window dose rates exceeding 100 mR/hr expected to continue for more than one hour; or analyses of field survey samples indicate thyroid CDE of 500 mR for one hour of inhalation, at or beyond the site boundary.* With release path to the environment from affected steam line, e.g., open ASDV or SRV, line is faulted, open steam supply to 1-FW-P-37A, etc.OR 2. -Dose assessment using actual meteorology, and the actual or projected .duration of the release, indicates doses > 100 mRem TEDE or 500 mRem thyroid CDE at or beyond the site boundary.Not used.OR 3. Field survey results indicate closed window dose rates > 100 mR/hr expected to continue for more than one hour at or beyond the site boundary; OR analyses of field survey samples indicate thyroid CDE of > 500 mRem for one hour of inhalation at or beyond the site boundary.Difference Difference Added phrase "and the actual or projected duration of the release" to ensure EAL is evaluated in accordance with basis discussion.

TEDE and thyroid CDE are correctly expressed in mRem.Per basis discussion, this EAL was not used since Seabrook Station does not have telemetered perimeter monitors.The phase" at or beyond the site boundary" was added after the closed window reading criteria to improve readability.

Thyroid CDE is correctly expressed in mRem.In EAL 3, added ">" before 500 mR to ensure EAL is evaluated in accordance with basis discussion.

The intent and meaning of the IC and EALs are not altered.Page 9 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition A G 1 Initiating Condition A G 1 K: Offsite Dose Resulting from an Actual or Actual or projected offsite dose > 1,000 Difference Shortened IC description for easier reading Imminent Release of Gaseous mRem TEDE or 5,000 mRem Thyroid cDE i.e., the offsite doses in question can only Radioactivity Exceeds 1000 mR TEDE or result from an actual or imminent release 5000 mR Thyroid CDE for the Actual or of gaseous radioactivity, and the Projected Duration of the Release Using meteorology criteria is stated in EALs.Actual Meteorology.

Intent of IC statement was not changed.Op. Modes: All Op. Modes: All Dose is correctly expressed in mRem.Emergency Action Level(s) Emergency Action Level(s)Note: If dose assessment results are Note: If dose assessment results are Verbatim N/A available at the time of declaration, the available at the time of declaration, the classification should be based on EAL classification should be based on EAL#2 instead of EAL #1. While necessary

2 instead of EAL #1. While necessary declarations should not be delayed declarations should not be delayed awaiting results, the dose assessment awaiting results, the dose assessment should be initiated

/ completed in order should be initiated

/ completed in order to determine if the classification should to determine if the classification should be subsequently escalated.

be subsequently escalated.

1. VALID reading on one or more of the 1. VALID reading on one or more of the Difference Added site-specific radiation monitors and following radiation monitors that following radiation monitors that values. These monitors are associated exceeds or expected to exceed the exceeds, or is expected to exceed, with the plant vent and the main steam reading shown for 15 minutes or the reading shown for 15 minutes or lines. Added asterisked note stipulating longer: longer: that there must be a release path to the (site-specific list)

RM-6528-4 (WRGM rate): environment from the main steam line(s), 2.85E+8 uCi/sec and included examples.

This aligns the" RM-6481-1* (MSL A): See below EAL with the IC wording "to the" RM-6482-1* (MSL B): See below environment" and the basis discussion.

RM-6482-2* (MSL C): See below* RM-6481-2* (MSL D): See below Tsd- Time after shutdown.Tsd < 1 hr 1,310 mRFhr 1 hr < T~sd -2 hrs 1,060 mR/hr 2 hrs < Tsd -< 5 hrs 570 mR/hr 5 hr.s < Tsd -< 10 hrs 220 mR/hr Tsd > 10 hrs 50 mR/hr Page 10 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation OR 2. Dose assessment using actual meteorology indicates doses greater than 1000 mR TEDE or 5000 mR thyroid CDE at or beyond the site boundary.OR 3. A VALID reading sustained for 15 minutes or longer on perimeter radiation monitoring system greater than 1000 mR/hr. [for sites having telemetered perimeter monitors]OR 4. Field survey results indicate closed window dose rates exceeding 1000 mR/hr expected to continue for more than one hour; or analyses of field survey samples indicate thyroid CDE of 5000 mR for one hour of inhalation, at or beyond site boundary.* With release path to the environment from affected steam line, e.g., open ASDV or SRV, line is faulted, open steam supply to 1 -FW-P-37A, etc.OR 2. Dose assessment using actual meteorology, and the actual or projected duration of the release, indicates doses > 1,000 mRem TEDE or 5,000 mRem thyroid CDE at or beyond the site boundary.Not used.OR 3. Field survey results indicate closed window dose rates > 1000 mR/hr expected to continue for more than one hour at or beyond the site boundary; OR analyses of field survey samples indicate thyroid CDE of > 5,000 mRem for one hour of inhalation, at or beyond site boundary.Difference Difference Added phrase "and the actual or projected duration of the release" to ensure EAL is evaluated in accordance with basis discussion.

TEDE and thyroid CDE is correctly expressed in mRem.Per basis discussion, this EAL was not used since Seabrook Station does not have telemetered perimeter monitors.The phase "at or beyond the site boundary" was added after the closed window reading criteria to improve readability.

Thyroid CDE is correctly expressed in mRem.In EAL 3, added ">" before 5,000 mR to ensure EAL is evaluated in accordance with basis discussion.

The intent and meaning of the IC and EALs are not altered.Page 11 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition CUI Initiating Condition CU1 _ _ _ P RCS Leakage RCS leakage Verbatim N/A Op. Modes: 5 Op. Modes: 5 Emergency Action Level(s) Emergency Action Level(s) , 1. Unidentified or pressure boundary 1. RCS unidentified or pressure Difference Inserted "RCS" into EALs 1 and 2 to leakage greater than 10 gpm. boundary leakage > 10 gpm. improve clarity and maintain consistency OR OR with IC wording.2. Identified leakage greater than 25 2. RCS identified leakage > 25 gpm.gpm. The intent and meaning of the EALs are not altered.Page 12 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM Verbatim/NEI 99-01, Rev. 4 Seabrook StationVebtm Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition CU2 Initiating Condition CU2 J-. ..UNPLANNED Loss of RCS Inventory with UNPLANNED loss of reactor vessel Difference Replaced terms "RCS" and "RPV" with Irradiated Fuel in the RPV. inventory with irradiated fuel in the reactor "reactor vessel" to improve readability and vessel maintain consistency with station Op. Modes: 6 Op. Modes: 6 procedures.

Emergency Action Level(s) Emergency Action Levels 1. UNPLANNED RCS level decrease 1. a. UNPLANNED reactor coolant level Difference Included site-specific level instrumentation below the RPV flange for >15 minutes decrease below the reactor vessel and EAL value.flange as indicated by:* 1-RC-LI-9405

< 0", and/or Broke out the 15-minute criteria into a* 1-SF-LI-2629

< 0" separate EAL statement (1.b) to improve AND readability.

b. 15 minutes has elapsed with reactor coolant level below the reactor Included "irradiated fuel" EAL statements OR vessel flange. (1 .c and 2.c) to ensure EAL assessments AND are consistent with the Initiating Condition c. Irradiated fuel in the reactor vessel, statement and basis discussion.

OR 2. a. Loss of RPV inventory as 2. a. Loss of reactor vessel inventory as Replaced terms "RCS" and "RPV" with indicated by unexplained

{site- indicated by unexplained increases "reactor coolant" and "reactor vessel", specific}

sump and tank level in sump and/or tank levels, respectively, to improve readability and increase maintain consistency with station AND procedures.

b. RPV level cannot be monitored

b. Reactor vessel level cannot be monitored.

In EAL 2.a, changed "and" to "and/or" AND since tank and sump levels may respond c. Irradiated fuel in the reactor vessel. independently.

The intent and meaning of the IC and EALs are not altered.Page 13 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/

T Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition CU3 Loss of All Offsite Power to Essential Buses for Greater Than 15 Minutes.Op. Modes: 5 and 6 Initiating Condition CU3 Loss of all offsite power to AC emergency buses for > 15 minutes Op. Modes: 5 and 6 Difference Included site-specific noun name;Seabrook procedures refer to these buses as "AC emergency", not "essential".

Refer* e" l t" "t" i t Emercencv Action Level(s)Emercencv Action Level(s)+1. a. Loss of power to (site-specific) transformers for greater than 15 minutes.AND b. At least (site-specific) emergency generators are supplying power to emergency buses.1. Both AC emergency busses E5 AND E6 are not powered from an offsite source for> 15 minutes.AND 2. Power restored to at least one AC emergency bus (E5 OR E6) from an emergency diesel generator or SEPS.Difference Changed EAL #1 to evaluate the status of AC emergency buses instead of their associated transformers..

This aligns the EAL wording with the IC intent/wording, and with steps and terminology used in station procedures.

It focuses the classification on the loss of bus power rather than the status of one or more transformers that may or may not be capable of powering an emergency bus.This change is consistent with the IC basis description and EAL FAQ #2006-017.

Included site-specific equipment identification.

Bus E5 and E6 are the AC emergency buses that supply ECCS and other safety-related loads. SEPS is the Supplemental Emergency Power System.The intent and meaning of the IC and EALs is not altered, i.e., an Unusual Event will be required if all offsite power is lost to AC emergency buses, and one or both AC emergency buses is/are powered by their respective emergency diesel generator or SEPS.________________________________________

I _________________________________________

L ______________

+/- _________________________________________

Page 14 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition CU4 Initiating Condition CU4 _UNPLANNED Loss of Decay Heat UNPLANNED loss of decay heat removal Difference Replaced term "RPV" with "reactor vessel" Removal Capability with Irradiated Fuel in capability with irradiated fuel in the reactor to be consistent with station procedures.

the RPV. vessel Op. Modes: 5 and 6 O___p. Modes: .5 and 6 SEmergency Action Level(s) Emergency Action Level(s) ,,.: 1. An UNPLANNED event results in RCS 1. An UNPLANNED event results in Difference In EAL #1, included the site-specific cold temperature exceeding the Technical RCS temperature

> 2000 F. shutdown temperature limit specified in Specification cold shutdown Technical Specifications.

temperature limit.OR OR In EAL #2, replaced the term "RPV" with 2. Loss of all RCS temperature and RPV 2. Loss of all RCS temperature and "reactor vessel" to be consistent with level indication for > 15 minutes. reactor vessel level indication for > station procedures.

15 minutes.The intent and meaning of the IC and EALs are not altered.Page 15 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim 1 Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition CU5 Initiating Condition CU5 ______________________

Fuel Clad Degradation.

Fuel clad degradation Deviation Seabrook Station has no Technical Op. Modes: 5 and 6 Op. Modes: 5 Specification LCO for RCS activity in Mode 6.Emergency Action Level(s Emergency Action Level(s) .1. (Site-specific) radiation monitor Not used. Deviation-In Modes 5 and 6, the station has no radiation readings indicating fuel clad monitor capable of directly determining if degradation greater than Technical coolant activity exceeds Technical Specification Specification allowable limits. allowable limits. Specifically, the RCS letdown monitor is not in the flow path of RHR recirculation flow. Various radiation monitors in the Primary Auxiliary Building and Equipment Vault would indirectly detect an increase in coolant activity.

If this occurred, the Chemistry Department would be notified and a coolant sample requested (along with likely changes to the sampling frequency).

Sample analysis results greater than Technical Specification allowable limits would be classified as an Unusual Event in accordance with EAL 1.The increased radiation levels would prompt implementation of additional in-plant protective measures and notification of plant management; these actions are not contingent upon an Unusual Event declaration.

The occurrence of this event would not threaten public health and safety.OR 2. (Site-specific) coolant sample activity 1. Reactor coolant sample activity value Difference Reworded EAL statement to improve value indicating fuel clad degradation

> LCO for Technical Specification readability.

A sample value greater than greater than Technical Specification 3/4.4.8. Technical Specification allowable limits allowable limits. implies fuel clad degradation.

The intent and meaning of the IC and EAL are not altered.Page 16 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition CU6 Initiating Condition CU6 UNPLANNED Loss of All Onsite or Offsite UNPLANNED loss of all onsite or offsite Verbatim N/A Communications Capabilities.

communications capabilities Op. Modes: 5 and 6 Op. Modes: 5 and 6 Emergency Action Level(s) Emergency Action Level(s)1. Loss of all (site-specific list) onsite 1. Loss of all of the following onsite Difference Added site-specific communications communications capability affecting communications capabilities affecting equipment to EALs.the ability to perform routine the ability to perform routine operations.

operations.

The intent and meaning of the EALs are 0 Telephones not altered.E Gai-Tronics N Plant Radio System OR OR 2. Loss of all (site-specific list) offsite 2. Loss of all of the following offsite communications capability, communications capabilities.

a Nuclear Alert System (NAS)0 Backup NAS (Zetron/Nextel unit)E Emergency Notification System (ENS)2 Telephones Page 17 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition CU7 Initiating Condition CU7 >J UNPLANNED Loss of Required DC Power UNPLANNED loss of required DC power Difference Used mathematical symbol instead of text for Greater than 15 Minutes. for > 15 minutes for value comparison.

Op. Modes: 5 and 6 Op. Modes: 5 and 6 Emergency Action Level(s) Emergency Action Level(s)1. a. UNPLANNED Loss of Vital DC 1. UNPLANNED voltage indications of Difference Added site-specific equipment power to required DC buses based < 105V on both vital DC buses identification.

11 A, 11 B, 11 C and. 11D are on (site-specific) bus voltage associated with the Protected Train. the vital DC power buses.indications.

TrainA-11Aand 11C e Train B -11B and 11D Substituted term "Protected Train" for"required";

Protected Train is the term AND AND used at Seabrook Station to define the b. Failure to restore power to at least 2. 15 minutes has elapsed without a train-related equipment and components one required DC bus within 15 sustained reading of 105V or greater that are required to be operable for minutes from the time of loss. on at least one Protected Train vital protecting the reactor core.DC bus.D TrainA-11Aor11C Included site-specific DC bus voltage o TrainB-11lBor11D reading at the low end of the operability range, i.e., a DC bus is considered lost if bus voltage is less than 105V.The intent and meaning of the IC and EALs are not altered.Page 18 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance.

IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition CU8 Initiating Condition CU8 , Inadvertent Criticality.

Inadvertent criticality Verbatim N/A Op. Modes: 5 and 6 Op. Modes: 5 and 6 Emrec Action Level(s) Emergency Action Level(s) 1 .An UNPLANNED extended positive 1 .An UNPLANNED sustained positive Difference The EAL containing "positive period" period observed on nuclear startup rate observed on nuclear (generic EAL #1) was not used as this instrumentation.

instrumentation.

term is not consistent with Seabrook OR Station operating procedures.

Operators 2. An UNPLANNED sustained positive use "startup rate" to monitor criticality and startup rate observed on nuclear the Seabrook Station EAL using "startup instrumentation.

rate" adequately addresses events involving an inadvertent criticality.

The intent and meaning of the EAL are not altered.Page 19 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/NEI9901,Re.

4Sebrok tatonDifference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation

, Initiating Condition CA I Initiating Condition CA I _ _ _ -_ _-1 Loss of RCS Inventory Loss of RCS inventory Verbatim N/A Op. Modes: 5 Op. Modes: 5 Emergency Action Level(s) Emergency Action Level(s) A .1. Loss of RCS inventory as indicated by 1. Loss of RCS inventory as indicated by Difference Used abbreviation of site-specific term: RPV level less than {site-specific RVLIS full range < 64%. Reactor Vessel Level Instrumentation level}. System (RVLIS). Indicated RVLIS value (bottom ID of the RCS loop) (PWR) was calculated per generic EAL and basis OR OR discussion.

2. a. Loss of RCS inventory as 2. a. RCS level cannot be monitored for indicated by unexplained

{site- > 15 minutes. Reversed order of generic EAL 2.a and 2.b specific}

sump and tank level to improve readability.

increase AND AND In EAL 2.b, changed "and" to "and/or" b. RCS level cannot be monitored for b. RCS inventory loss is indicated by since tank and sump levels may respond> 15 minutes unexplained sump and/or tank level independently.

Also refer to EAL FAQ increases.

2006-001.

The intent and meaning of the EALs are not altered.Page 20 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV.-4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation GDeviation Initiating Condition CA2 Initiating Condition CA2 _Loss of RPV Inventory with Irradiated Fuel Loss of reactor vessel inventory with Difference Replaced term "RPV" with "reactor vessel" in the RPV. irradiated fuel in the reactor vessel to be consistent with station procedures.

Op. Modes: 6 Op. Modes: 6 Emergency Action Level(s) Emergency Action Level(s)1. Loss of RPV inventory as indicated by Not used. Difference Replaced term "RPV" with "reactor vessel" RPV level less than {site-specific to improve readability and consistency with level}. station procedures.(bottom ID of the RCS loop) (PWR)OR Generic EAL #1 was not used. Station 2. a. Loss of RPV inventory as 1. Reactor vessel level cannot be level instrumentation limits valid reactor indicated by unexplained

{site- monitored for > 15 minutes. vessel level readings to approximately 5" specific}

sump and tank level above the bottom ID of the RCS loop (i.e., increase -95"). Anything below this level cannot be AND AND monitored.

b. RPV level cannot be monitored for 2. Reactor vessel inventory loss is> 15 minutes indicated by unexplained sump and/or Reversed order of 2.a and 2.b to improve tank level increases.

readability.

AND 3. Irradiated fuel in the reactor vessel. Added EAL statement 3 to specify that irradiated fuel be present in the reactor vessel for a classification to be made (per the IC description and basis discussion).

" In EAL 2, changed "and" to "and/or" since tank and sump levels may respond independently.

The intent and meaning of the IC and EALs are not altered.Page 21 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station 1 Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation' Initiating Condition CA3 Loss of All Offsite Power and Loss of All Onsite AC Power to Essential Buses.Op. Modes: 5, 6 and Defueled Emergency Action Level(s)Initiating Condition CA3 Loss of both AC emergency buses for > 15 minutes Op. Modes: 5, 6 and Defueled Difference Included site-specific noun name; Seabrook procedures refer to these buses as "AC emergency", not "essential".

Refer to EAL FAQ#2006-004.

Used synonymous wording; the loss of an AC emergency bus requires a "Loss of All Offsite Power and Loss of All Onsite AC Power". Pulled in the "15 minute" criteria from 1. a. Loss of power to (site-specific) transformers.

AND b. Failure of (site-specific) emergency generators to supply power to emergency buses.AND c. Failure to restore power to at least one emergency bus within 15 minutes from the time of loss of both offsite and onsite AC power.BOTH AC emergency buses E5 AND E6 are de-energized.

AND 2. 15 minutes has elapsed with BOTH AC emergency buses E5 AND E6 de-energized.

Changed EAL #1.a to EAL #1; evaluate the status of AC emergency buses instead of their associated transformers.

This aligns the EAL wording with the IC intent/wording, and with steps and terminology used in station procedures.

It focuses the classification on the loss of bus power rather than the status of one or more transformers that may or may not be capable of powering an emergency bus. This change is consistent with the IC basis description and EAL FAQ #2006-004.

Generic EAL 1 .b is subsumed by EAL #1 (de-energized means no emergency generator).

Used term "de-energized" instead of "loss" to be consistent with station procedures.

Included site-specific equipment identification.

Bus E5 and E6 are the AC emergency buses that supply ECCS and other safety-related loads.The intent and meaning of the IC and EALs are not altered., i.e., the loss of both AC emergency buses for greater than 15 minutes will result in an Alert declaration.

Page 22 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition CA4 Initiating Condition CA4 .Inability to Maintain Plant in Cold Inability to maintain plant in cold shutdown Difference Replaced term "RPV" with "reactor vessel" Shutdown with Irradiated Fuel in the RPV. with irradiated fuel in the reactor vessel to be consistent with station procedures.

Op. Modes: 5 and 6 Op. Modes: 5 and 6 Emergency Action Level(s) Emergency Action Level(s)1. With CONTAINMENT CLOSURE and 1. a. An UNPLANNED event results in Difference Broke out multiple criteria contained in RCS integrity not established an RCS temperature

> 2000 F. each generic EAL into individual EAL UNPLANNED event results in RCS statements.

Reworded statements to temperature exceeding the Technical AND improve readability.

Specification cold shutdown temperature limit. b. Containment integrity is not Generic EAL 1 = SS EALs 1.a, 1.b and 1.c OR established as tracked by Generic EAL 2 = SS EALs 2.a, 2.b, 2.c 2. With CONTAINMENT CLOSURE Procedure OS1 056.03, and 2.d established and RCS integrity not Containment Penetrations.

Generic EAL 3 = SS EALs 3 and 4 established or RCS inventory reduced an UNPLANNED event results in RCS AND Included site-specific cold shutdown temperature exceeding the Technical temperature limit. Included site-specific Specification cold shutdown c. The RCS is not intact. RCS pressure value (per basis temperature limit for greater than 20 discussion).

minutes'.OR Replaced term "CONTAINMENT

3. An UNPLANNED event results in RCS CLOSURE" with site-specific procedure.

temperature exceeding the Technical reference "Containment integrity is not Specification cold shutdown established as tracked by Procedure temperature limit for greater than 60 OS1056.03, Containment Penetrations." minutes 1 or results in an RCS pressure increase of greater than {site specific}

Replaced term "RCS integrity not psig. established" with site-specific procedural term "RCS is not intact".OR'Note: if an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced then this EAL is not applicable.

Page 23 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation 2. a. An UNPLANNED event results in Used site-specific value for defining when RCS temperature

> 2000 F for > 20 the RCS inventory is considered minutes 1."reduced", i.e., "<-36"".AND b. Containment integrity is established The intent and meaning of the IC and as tracked by Procedure EALs are not altered.OS1056.03, Containment Penetrations.

AND (c or d)c. The RCS is not intact.OR d. Reactor vessel level is < -36".OR 3. An UNPLANNED event results in RCS temperature

> 2000 F for > 60 minutes 1.OR 4. An UNPLANNED event results in an RCS pressure increase of > 10 psig.'Note: if an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced then this EAL is not applicable.

Page 24 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation L Initiating Condition CS1 Loss of RPV Inventory Affecting Core Decay Heat Removal Capability.

Initiating Condition CS1 Loss of RCS inventory affecting core decay heat removal capability^Artdý o-Difference Replaced term "RPV" with "RCS" to remain consistent with ICs CUl and CAl.C:111V~yt11Uy Mull L-tv~vip)1. With CONTAINMENT CLOSURE not established:

a. RPV inventory as indicated by RPV level less than {site-specific level}(6" below the bottom ID of the RCS loop) (PWR)OR b. RPV level cannot be monitored for> 30 minutes with a loss of RPV inventory as indicated by unexplained

{site-specific}

sump and tank level increase OR 2. With CONTAINMENT CLOSURE established

a. RPV inventory as indicated by RPV level less than TOAF OR b. RPV level cannot be monitored for> 30 minutes with a loss of RPV inventory as indicated by either: " Unexplained

{site-specific}

sump and tank level increase* Erratic Source Range Monitor Indication

1. a. Reactor vessel level cannot be monitored for > 30 minutes.AND b. Loss of reactor coolant inventory as indicated by unexplained sump and/or tank level increases, or erratic source range monitor indication.

OR 2. a. RVLIS Full Range < 63%AND b. Containment integrity is not established as tracked by Procedure OS1056.03, Containment Penetrations.

The classification resulting from an inability to monitor reactor vessel level for > 30 minutes with a loss of reactor coolant inventory indicated is the same regardless of CONTAINMENT CLOSURE status.Seabrook EALs 1.a and 1 .b address both generic EALs 1 .b and 2.b.From generic EAL 1 .b and 2.b, changed"and" to "and/or" since tank and sump levels may respond independently.

Seabrook EALs 2.a and 2.b address generic EAL 1.a.Seabrook EALs 3.a and 3.b address generic EAL 2.a.Generic EAL 1 .b does not specify the use of SRM indication for loss of inventory when containment closure is not established.

SRM indication is not affected by the status of containment closure and is a valid alternate indication of inventory loss when core uncovery is threatened regardless of containment integrity status. Refer to EAL FAQ #2006-009.Page 25 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Incorporated site-specific instrumentation noun name -Reactor Vessel Level OR Instrumentation System (RVLIS). RVLIS values are included per the generic EAL requirements and basis discussion.

3. a. RVLIS Full Range < 55%.AND b. Containment integrity is established Replaced term "CONTAINMENT as tracked by Procedure CLOSURE" with site-specific procedure OS1056.03, Containment reference "Containment integrity is not Penetrations.

established as tracked by Procedure OS1056.03, Containment Penetrations." The intent and meaning of the IC and EALs are not altered.Page 26 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/l Basis for Difference or Deviation Deviation Initiating Condition CS2 Initiating Condition CS2 _______________

Loss of RPV Inventory Affecting Core Loss of reactor vessel inventory affecting Difference Replaced term "RPV" with "reactor vessel" Decay Heat Removal Capability with core decay heat removal capability with to be consistent with station procedures.

Irradiated Fuel in the RPV. irradiated fuel in the reactor vessel Op. Modes: 6 Op. Modes: 6 Emergency Action Level(s) Emergency Action Level(s)1. With CONTAINMENT CLOSURE not Difference The classification resulting from an inability to established:

monitor reactor vessel level with core uncovery a. RPV inventory as indicated by 1. Reactor vessel level cannot be indicated is the same regardless of RPV level less than {site-specific monitored.

CONTAINMENT CLOSURE status. Seabrook level} EALs 1 and 2 address both generic EALs 1 .b (6" below the bottom ID of the and 2.b.RCS loop) (PWR) Station level instrumentation limits valid reactor OR AND vessel level readings to approximately 5" above b. RPV level cannot be monitored

2. Irradiated fuel in the reactor vessel is the bottom ID of the RCS loop (i.e., -95").with Indication of core uncovery as uncovered as indicated by any Anything below this level cannot be monitored.

evidenced by one or more of the combination of the following:

For this reason, generic EALs 1.a and 2.a were following:

' RM-6535A-1 (Manipulator Crane) not used; however, Seabrook EAL 1 subsumes* Containment High Range off-scale high both.Radiation Monitor reading > .RM-6535B-1 (Manipulator Crane) Because Seabrook's Containment High Range{site-specific}

setpoint off-scale high Radiation Monitors do not "see" the reactor* Erratic Source Range Monitor

Erratic source range monitor cavity, the Containment Manipulator Crane Indication readings Monitors are specified.

These monitors have* Other {site-specific}

indications

Visual observation (e.g., closed an upper end reading of 10 R/hr, and are circuit TV) expected to be "off-scale high" prior to the OR AND uncovery of irradiated fuel. Also refer to EAL FAQ #2006-005.

2. With CONTAINMENT CLOSURE 3. Containment integrity is established as established tracked by Procedure OS1056.03, Included EAL 3 to discriminate CS2 from CG1.Containment Penetrations.

Replaced term "CONTAINMENT CLOSURE" a. RPV inventory as indicated by with site-specific procedure reference RPV level less than TOAF "Containment integrity is not established as tracked by Procedure OS 1056.03, Containment OR Penetrations." Page 27 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation b. RPV level cannot be monitored with Indication of core uncovery as The intent and meaning of the IC and evidenced by one or more of the EALs are not altered.following: " Containment High Range Radiation Monitor reading >{site-specific}

setpoint* Erratic Source Range Monitor Indication

Other {site-specific}

indications Page 28 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition CG I Initiating Condition CG 1 _____Loss of RPV Inventory Affecting Fuel Clad Loss of RCS or reactor vessel inventory Difference Reworded IC statement to improve Integrity with Containment Challenged with with irradiated fuel in the reactor vessel readability.

Replaced term "RPV" with Irradiated Fuel in the RPV. AND containment challenged "reactor vessel" to be consistent with Op. Modes: 5 and 6 Op. Modes: 5 and 6 station procedures.

Included term "RCS" to maintain consistency with ICs CU1, CA1 and CS1.Emergency Action Level(s) Emergency Action Level(s) ______1. Loss of RPV inventory as indicated by 1. Loss of reactor vessel inventory as Difference In EAL 1, changed "and" to "and/or" since unexplained

{site-specific}

sump and indicated by unexplained sump and/or tank and sump levels may respond tank level increase tank level increase.

independently.

Replaced term "RPV" with AND AND "reactor vessel" to be consistent with 2. RPV Level: 2. a. RVLIS Full Range < 55% for > 30 station procedures.

a. less than TOAF for > 30 minutes minutes.OR OR Incorporated site-specific instrumentation

b. cannot be monitored with b. Reactor vessel level cannot be noun name -Reactor Vessel Level indication of core uncovery for > monitored with indication of core Instrumentation System (RVLIS). RVLIS 30 minutes as evidenced by one uncovery for > 30 minutes as value is included per the generic EAL or more of the following:

evidenced by any combination of requirements and basis discussion.

Containment High Range the following:

Radiation Monitor reading > o RM-6535A-1 (Manipulator Crane) Because Seabrook's Containment High{site-specific}

setpoint off-scale high Range Radiation Monitors do not "see" the Erratic Source Range Monitor o RM-6535B-1 (Manipulator Crane) reactor cavity, the Containment Indication off-scale high Manipulator Crane Monitors are specified.

Other {site-specific}

indications

Erratic source range monitor These monitors have an upper end readings reading of 10 R/hr, and are expected to be* Visual observation (e.g., closed "off-scale high" prior to the uncovery of circuit TV) irradiated fuel.AND AND Page 29 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation 3. {Site specific}

indication of 3. CONTAINMENT integrity is challenged CONTAINMENT challenged as as indicated by one or more of the Replaced term "CONTAINMENT indicated by one or more of the following:

CLOSURE" with site-specific procedure following:

Containment integrity is not reference "Containment integrity is not" Explosive mixture inside established as tracked by established as tracked by Procedure containment Procedure OS1056.03, OS1056.03, Containment Penetrations."* Pressure above {site specific}

Containment Penetrations.

value

Containment pressure > 52 psig Included site-specific values for extreme" CONTAINMENT CLOSURE not

Containment H 2 concentration

> containment challenge (per basis established 6% discussion).

The intent and meaning of the IC and EALs are not altered.Page 30 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/

T Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Gua)c nDeviation Initiating Condition E-HUI Initiating Condition E-HU1 Damage to a loaded cask CONFINEMENT Damage to a loaded cask CONFINEMENT Difference T The Operating Mode applicability was BOUNDARY.

BOUNDARYI changed to "All" to maintain consistency Op. Modes: N/A Op. Modes: All with other IC descriptions.

Emergency Action Level(s) Emergency Action Level(s)1. Natural phenomena events affecting a 1. Any indication that the Difference The Seabrook Station Dry Cask Storage loaded cask CONFINEMENT CONFINEMENT BOUNDARY of a Area will be located approximately 1,500'BOUNDARY.

loaded dry cask storage container from the Protected Area boundary.

See has been lost. Note 1.(site-specific list)OR Generic EAL #1 is subsumed by IC HU1.2. Accident conditions affecting a loaded

Seismic activity affecting the Dry Cask cask CONFINEMENT BOUNDARY.

Storage area would also affect the Protected Area, and would be classified (site-specific list) under HU1.OR 9 High wind conditions affecting the Dry 3. Any condition in the opinion of the Cask Storage area would also affect the Emergency Director that indicates loss Protected Area, and would be classified of loaded fuel storage cask under HU1.CONFINEMENT BOUNDARY.All other events that could cause a loss of a cask CONFINEMENT BOUNDARY (e.g., fire, explosion, missile impact, dropping, tipping, etc.) would be assessed against EAL #1. The reworded EAL encompasses any initiating event affecting a loaded cask.The intent and meaning of the IC and EALs are not altered.NOTE 1 -Seabrook Station will be implementing Dry Cask Storage in 2008. This IC/EAL will become effective at that time.Page 31 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition E-HU2 Initiating Condition E-HU2 Confirmed Security Event with potential N/A Deviation This IC and EAL was superceded by loss of level of safety of the ISFSI. information promulgated in NRC Bulletin Op. Modes: N/A 2005-02. Attachment 2 of BL 2005-02 directed that E-HU2 be deleted because it is replaced by either HOSTILE ACTION EAL HA8 or Site Attack EAL HS4.Emergency Action Level(s) Emergency Action Level(s) ......; 1. Security Event as determined from N/A Deviation See above.(site-specific)

Security Plan and reported by the (site-specific) security shift supervision.

Page 32 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Fission Product Barrier Degradation Fission Product Barrier Degradation Difference Different wording; no intent or meaning Initiating Condition Matrix Matrix change.Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 FUL1 -ANY Loss or Potential Loss of FUL1 -ANY Loss or Potential Loss of Difference Added "Barrier" and "Barriers" to FU1 and Containment Containment Barrier FA1, respectively.

FA1 -ANY Loss or Potential Loss of FA1 -ANY Loss or Potential Loss of The intent and meaning of the ICs are not EITHER Fuel Clad OR RCS EITHER Fuel Clad or RCS Barriers altered.FS1 -Loss or Potential Loss of ANY Two FS1 -Loss or Potential Loss of ANY Two Barriers Barriers FG1 -Loss of ANY Two Barriers AND FG1 -Loss of ANY Two Barriers AND Loss or Potential Loss of Third Loss or Potential Loss of Third Barrier Barrier Page 33 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION.

SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Fission Product Barrier Reference Table Thresholds for LOSS or POTENTIAL LOSS of Barriers.C, ,f t-l1- l 0 -;-r 1 %00 Fission Product Barrier Degradation Matrix Difference Different terminology; no intent change.Imergency Action Level(s)Critical Safety Function Status Core-Cooling Red CSF Status Core Cooling Red Used abbreviation of terms and synonymous terms.OR Primary Coolant Activity Level Coolant Activity GREATER THAN (site-specific)

Value OR Core Exit Thermocouple Readinqs GREATER THAN (site-specific) degree F OR Containment Radiation Monitoring Containment rad monitor reading GREATER THAN (site-specific)

R/hr OR Other (Site-Specific)

Indications (Site specific ) as applicable OR OR RCS Activity RCS activity > 300 uCi/gm Dose Equivalent 1-131 (as determined per Procedure CS0925.01, Reactor Coolant Post Accident Sampling)OR Core Exit TCs Core Exit TCs > 1,1000 F OR Containment Radiation Monitor Post-LOCA Radiation Monitors RM-6576A-1 or RM-6576B-1

> 95 R/hr OR Not used Used 300 uCi/gm DEl-1 31 from basis and referenced site-specific procedure for post-accident RCS sample analysis."> 1,1000 F" is the site-specific value for determining an inadequate core cooling condition, i.e., Core Cooling Red.Added site-specific equipment identification; RM-6576A-1 and RM-6576B-1 are the post-LOCA containment radiation monitors.

Included radiation monitor reading per basis discussion.

No additional site-specific indications were identified.

OR Page 34 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Emer.qency Director Judgment STED/SED Judgqment Substituted site-specific term: "STED/SED" Any condition in the opinion of the Any condition in the opinion of the for "Emergency Director".

Pulled in Emergency Director that indicates Loss or STED/SED that indicates a Loss of the information from basis section, i.e., inability Potential Loss of the Fuel Clad Barrier Fuel Clad Barrier (consider inability to to monitor barrier status. The STED is the monitor barrier).

Short Term Emergency Director (a.k.a. the Shift Manager).

The SED is the Site Emergency Director (the lead manager in the TSC). These are the two individuals who may make emergency declarations.

The SED relieves the STED of this function.Under judgment -this set of EALs covers"LOSS". An analogous judgment EAL is included in the "POTENTIAL LOSS" EALs.The intent and meaning of the EALs are not altered.Page 35 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Fission Product Barrier Reference Table Fission Product Barrier Degradation Matrix Difference Different terminology; no intent change.Thresholds for LOSS or POTENTIAL LOSS of Barriers Fuel Clad Barrier -POTENTIAL LOSS Fuel Clad Barrier -POTENTIAL LOSS Emergency Action Level(s) Emergency Action Level(s) -, Critical Safety Function Status CSF Status Difference Used abbreviation of terms and Core-Cooling Orange OR Heat Sink-Red Core Cooling Orange or Heat Sink Red synonymous terms.OR OR Core Exit Thermocouple Readings Core Exit TCs GREATER THAN (site-specific) degree F Core Exit TCs > 7250 F "> 7250 F" is the site-specific value for determining a degraded core cooling condition, i.e., Core Cooling Orange.OR OR Reactor Vessel Water Level Reactor Vessel Level Level LESS than (site-specific) value RVLIS dynamic head Used site-specific term -Reactor Vessel* -< 44% with 4 RCPs running Level Instrumentation System (RVLIS).0 < 30% with 3 RCPs running The site-specific RVLIS values are those 0 -< 20% with 2 RCPs running used for determining a degraded core* < 13% with 1 RCP running, or cooling condition, i.e., Core Cooling RVLIS full range level Orange.* < 40% with no RCP running OR OR Other (Site-Specific)

Indications Not used No additional site-specific indications were (Site specific ) as applicable identified.

OR OR Page 36 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s), Site-Specific IC and EAL(s) Deviation Emergency Director Judqment STED/SED Judgment Substituted site-specific term: "STED/SED" Any condition in the opinion of the Any condition in the opinion of the for "Emergency Director".

Pulled in Emergency Director that indicates Loss or STED/SED that indicates a Potential Loss information from basis section, i.e., inability Potential Loss of the Fuel Clad Barrier of the Fuel Clad Barrier (consider inability to monitor barrier status. The STED is the to monitor barrier).

Short Term Emergency Director (a.k.a. the Shift Manager).

The SED is the Site Emergency Director (the lead manager in the TSC). These are the two individuals who may make emergency declarations.

The SED relieves the STED of this function.Under judgment -this set of EALs covers"POTENTIAL LOSS". An analogous judgment EAL is included in the "LOSS" EALs.The intent and meaning of the EALs are not altered.Page 37 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Fission Product Barrier Reference Table Fission Product Barrier Degradation Matrix Difference Different terminology; no intent change.Thresholds for LOSS or POTENTIAL LOSS of Barriers RCS Barrier -LOSS RCS Barrier -LOSS Emergency Action Level(s) Emergency Action Level(s)RCS Leak Rate RCS Leakaqe Difference Included site-specific EOP value indicative GREATER THAN available makeup RCS subcooling

< 40°F due to an RCS of a loss of subcooling.

Substituted the capacity as indicated by a loss of RCS leak phrase "due to an RCS leak" for subcooling "GREATER THAN available makeup capacity" to better align EAL wording with IC and basis discussion.

The operative criterion remains the loss of RCS subcooling.

OR OR SG Tube Rupture S/G Rupture or Fault Used entry into Procedure E-3 per basis SGTR that results in an ECCS (SI) Entry into Procedure E-3. discussion.

Actuation OR OR Containment Radiation Monitorinq Containment Radiation Monitor Added site-specific equipment Containment rad monitor reading Post-LOCA Radiation Monitors identification; RM-6576A-1 and RM-GREATER THAN (site-specific)

R/hr RM-6576A-1 or RM-6576B-1

> 16 R/hr 6576B-1 are the post-LOCA containment radiation monitors.

Included radiation monitor reading per basis discussion.

OR OR Other (Site-Specific)

Indications Not used No additional site-specific indications were (Site specific ) as applicable identified.

OR OR Page 38 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Emerqency Director Judgqment STED/SED Judqment Substituted site-specific term: "STED/SED" Any condition in the opinion of the Any condition in the opinion of the for "Emergency Director".

Pulled in Emergency Director that indicates Loss or STED/SED that indicates a Loss of the information from basis section, i.e., inability Potential Loss of the RCS Barrier RCS Barrier (consider inability to monitor to monitor barrier status. The STED is the barrier).

Short Term Emergency Director (a.k.a. the Shift Manager).

The SED is the Site Emergency Director (the lead manager in the TSC). These are the two individuals who may make emergency declarations.

The SED relieves the STED of this function.Under judgment -this set of EALs covers"LOSS". An analogous judgment EAL is included in the "POTENTIAL LOSS" EALs.The intent and meaning of the EALs are I not altered.Page 39 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Fission Product Barrier Reference Table Thresholds for LOSS or POTENTIAL LOSS of Barriers RCS Barrier -POTENTIAL LOSS Emergency Action Level(s)Fission Product Barrier Degradation Matrix Difference Different terminology; no intent change.Critical Safety Function Status RCS Integrity-Red OR Heat Sink-Red OR RCS Leak Rate Unisolable leak exceeding the capacity of one charging pump in the normal charging mode.OR Other (Site-Specific)

Indications (Site specific ) as applicable OR* Emergency Director Judgment Any condition in the opinion of the Emergency Director that indicates Loss or Potential Loss of the RCS Barrier CSF Status RCS Integrity Red (w/ RCS press > 300 psig) or Heat Sink Red OR UOUU dUUI UVIdlIUIU I VI LVI Ib 1 i IU Oyl IU liyi I IUUO terms. At Seabrook Station, an RCS Integrity Red CSFST with RCS pressure a 300 psig is not considered valid. The technical basis for this position can be found in Westinghouse Direct Work No. DW-92-032.

RCS Leakage Unisolable leak > the capacity of one centrifugal charging pump in the normal charging mode.OR Not used OR STED/SED Judgment Any condition in the opinion of the STED/SED that indicates a Potential Loss of the RCS Barrier (consider inability to monitor barrier).Specified "centrifugal" charging pump to be consistent with basis discussion and station operating procedures (i.e., run with one centrifugal charging pump operating to supply normal charging flow).No additional site-specific indications were identified.

Substituted site-specific term: "STED/SED" for"Emergency Director".

Pulled in information from basis section, i.e., inability to monitor barrier status. The STED is the Short Term Emergency Director (a.k.a. the Shift Manager).The SED is the Site Emergency Director (the lead manager in the TSC). These are the two individuals who may make emergency declarations.

The SED relieves the STED of this function.Under judgment -this set of EAL's covers"POTENTIAL LOSS". An analogous judgment EAL is included in the "LOSS" EALs.The intent and meaning of the EALs are not altered.___________________________________________

.1 ___________________________________________

L Page 40 10/17/07 Page 40 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Fission Product Barrier Reference Table Fission Product Barrier Degradation Matrix Difference Different terminology; no intent change.Thresholds for LOSS or POTENTIAL LOSS of Barriers Containment Barrier -LOSS Containment Barrier -LOSS Emergency Action Level(s) Emergency Action Level(s)N/A CSF Status Difference Seabrook Station has implemented a Emergency Coolant Recirculation Orange CSFST for Emergency Coolant OR OR Recirculation (referred to as the F tree).Containment Pressure Containment Pressure As presented in the F tree, a severe Rapid unexplained decrease following Rapid unexplained pressure decrease challenge to this safety function occurs initial increase following initial increase when the criterion "RWST and OR OR Containment levels in expected region" is Containment pressure or sump level Containment pressure response not not met. If this occurs, the F tree is response not consistent with LOCA consistent with LOCA conditions evaluated as ORANGE. An F ORANGE conditions path is equivalent to the NEI 99-01 generic OR OR .EAL guidance of containment "sump level SG Secondary Side Release with P-to-S S/G Rupture or Fault response not consistent with LOCA Leakage conditions".

RUPTURED S/G is also FAULTED outside RUPTURED S/G is also FAULTED outside of containment, of containment.

Under Containment Pressure, changed OR OR "unexplained decrease" to "unexplained Primary-to-Secondary leakrate greater Primary-to-Secondary leak rate > 10 gpm pressure decrease" to improve readability.

than 10 gpm with nonisolable steam with nonisolable steam release from release from affected S/G to the affected S/G to the environment.

Under "Containment Pressure" EALs, environment.

struck the term "sump level" from EAL #2 OR OR since this parameter is assessed by the F CNMT Isolation Valves Status After CNMT Containment Isolation Valves Orange condition (as discussed above).Isolation Cnmt. Isolation Valve(s) not closed AND Valve(s) not closed AND downstream direct pathway to the environment exists Refer to EAL FAQ #2006-020 concerning pathway to the environment exists after Cnmt. Isolation signal difference for "Cnmt Isolation Valve(s)".

OR OR Other (Site-Specific)

Indications Not used No additional site-specific indications were (Site specific ) as applicable identified.

Page 41 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Emerqency Director Judgqment STED/SED Judqment Substituted site-specific term: "STED/SED" Any condition in the opinion of the Any condition in the opinion of the for "Emergency Director".

Pulled in Emergency Director that indicates Loss or STED/SED that indicates a Loss of the information from basis section, i.e., inability Potential Loss of the Containment Barrier Containment Barrier (consider inabilityto to monitor barrier status. The STED is the monitor barrier).

Short Term Emergency Director (a.k.a. the Shift Manager).

The SED is the Site Emergency Director (the lead manager in the TSC). These are the two individuals who may make emergency declarations.

The SED relieves the STED of this function.Under judgment -this set of EALs covers"LOSS". An analogous judgment EAL is included in the "POTENTIAL LOSS" EALs.The intent and meaning of the EALs are not altered.Page 42 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Fission Product Barrier Reference Table Fission Product Barrier Degradation Matrix Difference Different terminology; no intent change.Thresholds for LOSS or POTENTIAL LOSS of Barriers Containment Barrier -POTENTIAL LOSS Containment Barrier -POTENTIAL LOSS Emergency Action Level(s) Emergency Action Level(s)Critical Safety Function Status CSF Status Difference Used abbreviation of terms and Containment-Red Containment Red synonymous terms.OR OR Containment Pressure Containment Pressure Included site-specific values/setpoints per (Site-specific)

PSIG and increasing

1. Cnmt. pressure > 52 psig and basis discussion.

OR increasing Explosive mixture exists OR OR 2. Cnmt. hydrogen concentration

> 6%Pressure greater than containment OR depressurization actuation setpoint with 3. a. Cnmt. pressure > 18 psig less than one full train of depressurization AND equipment operating

b. No Cnmt. Building Spray (CBS)OR OR Core Exit Thermocouple Reading Core Exit TCs For Core Exit TCs EALs 1 .a, 2.a and 2.b, Core exit thermocouples in excess of 1200 1. a. Core Exit TCs > 1,1000 F the site-specific parameters for reaching a degrees and restoration procedures not AND Core Cooling (C) Red Path (i.e., effective within 15 minutes; or, core exit b. FR-C.1 not effective within 15 Inadequate Core Cooling) are listed below: thermocouples in excess of 700 degrees minutes. 0 Core Exit TCs > 1,1000 F, OR with reactor vessel level below top of OR

Core Exit TCs 7250 F, and active fuel and restoration procedures not 2. a. Core Exit TCs > 7250 F RVLIS full range level < 40%effective within 15 minutes AND b. RVLIS full range level < 40% For EALs 1 .b and 2.c, Functional AND Restoration Procedure FR-C.1, Response c. FR-C.1 not effective within 15 to Inadequate Core Cooling, is minutes. implemented in response to a Core Cooling Red Path.OR OR Page 43 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Significant Radioactive Inventory in Containment Radiation Monitor Added site-specific equipment Containment Post-LOCA Radiation Monitors identification; RM-6576A-1 and RM-Containment rad monitor reading RM-6576A-1 or RM-6576B-1

> 1,305 R/hr 6576B-1 are the post-LOCA containment GREATER THAN (site-specific)

R/hr radiation monitors.

Included radiation monitor reading per basis discussion.

OR OR Other (Site-Specific)

Indications Not used No additional site-specific indications were (Site specific ) as applicable identified.

OR OR Emergency Director Judqment STED/SED Judgment Substituted site-specific term: "STED/SED" Any condition in the opinion of the Any condition in the opinion of the for "Emergency Director".

Pulled in Emergency Director that indicates Loss or STED/SED that indicates a Potential Loss information from basis section, i.e., inability Potential Loss of the Containment Barrier of the Containment Barrier (consider to monitor barrier status. The STED is the inability to monitor barrier).

Short Term Emergency Director (a.k.a. the Shift Manager).

The SED is the Site Emergency Director (the lead manager in the TSC). These are the two individuals who may make emergency declarations.

The SED relieves the STED of this function.Under judgment -this set of EALs covers"POTENTIAL LOSS". An analogous judgment EAL is included in the "LOSS" EALs.The intent and meaning of the EALs are not altered.Page 44 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATIONEMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/G Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition HUI Natural and Destructive Phenomena Affecting the PROTECTED AREA.n' AA-,, -,. All Initiating Condition HUI Natural and destructive phenomena affecting the PROTECTED AREA (n AA-Af- All Verbatim N/A iergency Action Level(s)(Site-Specific) method indicates felt earthquake.

LVVq a. Vibratory ground motion is felt and recognized as an earthquake based on a consensus of control room operators on duty at the time.OR rUIIeU U bi WYKl 1 II LU -/MLb I.d C1l1 U I U, i.e., "Method of detection can be based on instrumentation, validated by a reliable source [EAL 1 .b], or operator assessment

[EAL 1.a]." b. Vibratory ground motion detected by seismic monitoring instrumentation is validated as an earthquake.

1) The yellow "EVENT" light is lit on seismic monitoring control panel 1 -SM-CP-58.

AND 2) The occurrence of an earthquake is confirmed with the National Earthquake Information Center (or other source deemed reliable by the Shift Manager).OR 2. a. Report by plant personnel of tornado within PROTECTED AREA boundary.OR b. Winds speeds > 100 mph as indicated by site meteorological instrumentation (or other source deemed reliable by the Shift Manager).OR OR 2. Report by plant personnel of tornado or high winds greater than (site-specific) mph striking within PROTECTED AREA boundary.OR Included site-specific equipment identification.

1-SM-CP-58 is the seismic monitoring control panel located in the Control Room.Contact with the National Earthquake Information Center is directed by seismic event response procedure.

The design basis wind velocity for Category I structures is 110 mph. The range of the installed wind speed translator associated with the station meteorological tower is 0 to 100 mph, i.e., current station meteorological instrumentation supports a maximum readout value for wind speed of 100 mph. For EAL 2b, the EAL value is set at 100% of the maximum readout value, i.e., 100 mph. This is conservative in that the assigned value is less than the structural design limit of 110 mph.Difference Page 45 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation 3. Vehicle crash into plant structures or systems within PROTECTED AREA boundary.OR 4. Report by plant personnel of an unanticipated EXPLOSION within PROTECTED AREA boundary resulting in VISIBLE DAMAGE to permanent structure or equipment.

OR 5. Report of turbine failure resulting in casing penetration or damage to turbine or generator seals.OR 6. Uncontrolled flooding in (site-specific) areas of the plant that has the potential to affect safety related equipment needed for the current operating mode.3. Vehicle crash that causes VISIBLE DAMAGE to plant structures within PROTECTED AREA boundary that contain functions and systems required for safe shutdown of the plant.OR 4. Report by plant personnel of an unanticipated EXPLOSION within PROTECTED AREA boundary resulting in VISIBLE DAMAGE to permanent structure or equipment.

OR 5. Report of main turbine rotating component failure resulting in VISIBLE DAMAGE to the turbine casing or to the generator seals.OR 6. Uncontrolled flooding in any of the following areas of the plant that has the potential to affect safety-related equipment needed for the current operating mode." Condensate Storage Tank Enclosure" Containment" Control Building" Cooling Tower" Diesel Generator Building" Emergency Feedwater Pump House" Equipment Vault" Fuel Storage Building" Primary Auxiliary Building" Service Water Pump House" Steam and Feedwater Pipe Chases" North Tank Farm" Turbine Buildina Difference Verbatim Difference Difference Pulled basis information into EAL, i.e., a crash that causes "significant damage to plant structures containing functions and systems required for safe shutdown of the plant." Replaced "significant damage" with the defined term "Visible Damage".N/A Pulled in basis information into EAL. Used defined term VISIBLE DAMAGE to replace"observable damage".Included site-specific plant areas where uncontrolled flooding could affect safety-related equipment.

Page 46 10/17/07 Page'46 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim!Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation OR OR 7. (Site-Specific) occurrences affecting

7. The National Weather Service has Difference Added a site-specific occurrence that the PROTECTED AREA. issued a Hurricane Warning for areas meets the definition of an Unusual Event.that include the Town of Seabrook.The intent and meaning of the EALs are not altered.Page 47 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition HU2 Initiating Condition HU2 __FIRE Within PROTECTED AREA FIRE within PROTECTED AREA boundary Verbatim N/A Boundary Not Extinguished Within 15 not extinguished within 15 minutes of Minutes of Detection.

detection Op. Modes: All Op. Modes: All Emergency Action Level(s) Emergency Action Level(s)1. FIRE in buildings or areas contiguous

1. FIRE in the PROTECTED AREA. Difference Seabrook Station has a'relatively small to any of the following (site-specific)

PROTECTED AREA footprint.

All plant areas not extinguished within 15 VITAL AREAs are contiguous (in actual minutes of control room notification or contact with or immediately adjacent) with verification of a control room alarm: PROTECTED AREA buildings and areas.Given the footprint size and physical (Site-specific) list arrangements, any fire in the PROTECTED AREA lasting more than 15 AND minutes warrants an Unusual Event 2. FIRE not extinguished within 15 declaration.

minutes of control room notification or verification of a control room alarm. Broke out the multiple decision-making criteria contained in the generic EAL into two "AND" EAL statements.

This will improve readability and application.

The intent and meaning of the EAL are not altered.Page 48 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation) IDeviation Initiating Condition HU3 Initiating Condition HU3 ______......

Release of Toxic or Flammable Gases Release of toxic, corrosive, asphyxiant or Difference Included "corrosive" and "asphyxiant" Deemed Detrimental to Normal Operation flammable gases deemed detrimental to gasses in IC and EAL to be consistent with of the Plant. normal operation of the plant discussion of hazardous gases in 29 CFR Op. Modes: All Op. Modes: All 1910.120.

Also refer to EAL FAQ #2006-023.Emergency Action Level(s) Emergency Action Level(s)1. Report or detection of toxic or 1. a. Report or detection of an Difference Used site-specific terminology

-substituted flammable gases that has or could uncontrolled release of toxic, "Owner Controller Area" for "site area enter the site area boundary in corrosive,.asphyxiant or boundary".

amounts that can affect NORMAL flammable gases that could enter PLANT OPERATIONS.

or has entered the Owner Broke out the multiple decision-making Controlled Area. criteria contained in generic EAL #1 into two "AND" EAL statements

[Seabrook AND EALs #1 .a and 1 .b]. This will improve b. An abnormal or emergency readability and application.

operating procedure has been OR entered, or a deviation from Pulled information from basis section and normal security or radiological term definitions into EAL, i.e., EAL #1 .b controls posture has occurred.

uses the definition of "Normal Plant OR Operations".

Also added "uncontrolled" to 2. Report by Local, County or State 2. Report by Local, County orState EAL #1 .a per basis discussion.

Officials for evacuation or sheltering of Officials for evacuation or sheltering site personnel based on an offsite of site personnel based on an offsite The intent and meaning of the EALs are event, event, not altered.Page 49 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCYCLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition HU4 Initiating Condition HU4 --Confirmed Security Event Which Indicates Confirmed security event which indicates a Verbatim N/A a Potential Degradation in the Level of potential degradation in the level of safety Safety of the Plant. of the plant Op. Modes: All Op. Modes: All Emergency Action Level(s) Emergency Action Level(s)1. Security events as determined from 1. A Code Yellow is reported by security Difference Included site-specific terminology

-a (site-specific)

Safeguards Contingency shift supervision. "Code Yellow" is a security event within or Plan and reported by the (site-specific) near the station boundary that may present security shift supervision.

a threat escalation to the Protected Area.OR OR These types of events align with the 2. A credible site-specific security threat 2. A credible, site specific security threat definition of an Unusual Event.notification.

notification.

OR OR EAL #3 was not included in NEI 99-04, 3. A validated notification from NRC 3. A validated notification from the NRC Rev. 4, when originally issued. This EAL providing information of an aircraft providing information of an aircraft was subsequently incorporated into NEI threat. threat. 99-01, Rev. 4, by NRC Bulletin 2005-02.Also see NEI paper Enhancements to Emergency Preparedness Programs For Hostile Action, May 2005 (Revised November 18, 2005)The intent and meaning of the EALs are not altered.Page 50 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition HU5 Initiating Condition HU5 # .H!V Other Conditions Existing Which in the Other conditions existing which in the Difference Substituted site-specific terms: Judgment of the Emergency Director judgment of the STED/SED warrant "STED/SED" for "Emergency Director" and Warrant Declaration of a NOUE. declaration of an UNUSUAL EVENT "Unusual Event" for "NOUE" (See Note Op. Modes: All Op. Modes: All below). The intent and meaning of the IC is not altered.Emergency Action Level(s) Emergency Action Level(s)1. Other conditions exist which in the 1. Other conditions exist which in the Difference Incorporated revised Unusual Event judgment of the Emergency Director judgment of the STED/SED indicate definition per NRC Bulletin 2005-02 and indicate that events are in process or that events are in process or have related NEI White Paper.have occurred which indicate a occurred which indicate a potential potential degradation of the level of degradation of the level of safety of Substituted site-specific term: "STED/SED" safety of the plant. No releases of the plant or indicate a security threat for "Emergency Director".

radioactive material requiring offsite to facility protection has been response or monitoring are expected initiated.

No releases of radioactive The intent and meaning of the IC and EAL unless further degradation of safety material requiring offsite response or are not altered.systems occurs. monitoring are expected unless further degradation of safety systems NOTE -the STED is the Short Term occurs. Emergency Director (a.k.a. the Shift Manager).

The SED is the Site Emergency Director (the lead manager in the TSC). These are the two individuals who may make emergency declarations.

The SED relieves the STED of this function.Page 51 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition HA I Initiating Condition HA I ____________

Natural and Destructive Phenomena Natural and destructive phenomena Verbatim N/A Affecting the Plant VITAL AREA. affecting the plant VITAL AREA Op. Modes: All Op. Modes: All Emergency Action Level(s) Emergency Action Level(s) ________________________

1. (Site-Specific) method indicates

1. a. The yellow "EVENT" light is lit on Difference Included site-specific equipment Seismic Event greater than Operating seismic monitoring control panel identification.

1-SM-CP-58 is the seismic Basis Earthquake (OBE). 1 -SM-CP-58.

monitoring control panel located in the AND Control Room.b. The red "OBE" light is lit on seismic monitoring control panel Included EAL 1 .c as a validation check to 1 -SM-CP-58.

the seismic monitoring alarms. Building AND motion/shaking would be felt by operators c. Vibratory ground motion is felt during an OBE event (which at Seabrook and recognized as an earthquake is >0.12g lateral acceleration).

based on a consensus of control room operators on duty at the The intent and meaning of the EAL are not time. altered.OR OR I II Page 52 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Generic Guidance IC and EAL(s)Seabrook Station Site-Specific IC and EAL(s)Verbatim/Difference/

Deviation Difference

2. Tornado or high winds greater than (site-specific) mph within PROTECTED AREA boundary and resulting in VISIBLE DAMAGE to any of the following plant structures

/equipment or Control Room indication of degraded performance of those systems.* Reactor Building" Intake Building* Ultimate Heat Sink* Refueling Water Storage Tank* Diesel Generator Building* Turbine Building* Condensate Storage Tank* Control Room" Other (Site-Specific)

Structures.

2. Tornado or high winds > 100 mph within PROTECTED AREA boundary resulting in 1) VISIBLE DAMAGE to any of the following buildings and areas, or 2) Control Room indication of degraded performance of safety-related systems within these buildings and areas." Condensate Storage Tank Enclosure" Containment Control Building* Cooling Tower* Diesel Generator Building* Emergency Feedwater Pump House* Equipment Vault* Fuel Storage Building* Primary Auxiliary Building* Service Water Pump House* Steam and Feedwater Pipe Chases* North Tank Farm* Turbine Building OR Basis for Difference or Deviation The design basis wind velocity for Category I structures is 11.0 mph (UFSAR Section 3.3.1.1).

The range of the installed wind speed translator associated with the station meteorological tower is 0 to 100 mph, i.e., current station meteorological instrumentation supports a maximum readout value for wind speed of 100 mph. For EAL 2, the EAL value is set at 100% of the maximum readout value, i.e., 100 mph. This is conservative in that the assigned value is less than the structural design limit of 110 mph.Pulled information from basis into EAL -the "systems and functions required for safe shutdown of the plant" was shortened to "safety-related systems".Included site-specific list of plant structures or areas that contain systems and functions required for safe shutdown of the plant.The intent and meaning of the EAL are not altered.OR Page 53 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation 3. Vehicle crash within PROTECTED

3. Vehicle crash within PROTECTED Difference Pulled information from basis into EAL -AREA-boundary and resulting in AREA boundary resulting in the "systems and functions required for VISIBLE DAMAGE to any of the 1) VISIBLE DAMAGE to any of the safe shutdown of the plant" was shortened following plant structures or equipment following buildings and areas, or to "safety-related systems".therein or control indication of 2) Control Room indication of degraded performance of those degraded performance of safety- Included site-specific list of plant structures systems: related systems within these or areas that contain systems and buildings and areas. functions required for safe shutdown of the* Reactor Building plant.* Intake Building

Condensate Storage Tank* Ultimate Heat Sink Enlosure The intent and meaning of the EAL are not* Refueling Water Storage Tank M Containment altered.* Diesel Generator Building 0 Control Building" Turbine Building

Cooling Tower" Condensate Storage Tank 0 Diesel Generator Building SControl Room E Emergency Feedwater Pump* CotrolRoomHouse

Other (Site-Specific)

H Equipment Vault Structures.EqimnVal S Fuel Storage Building E Primary Auxiliary Building E Service Water Pump House N Steam and Feedwater Pipe Chases 0 North Tank Farm-Turbine Building OR OR Page 54 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation 4. Turbine failure-generated missiles 4. Turbine failure-generated missiles Difference Included site-specific list of plant structures result in any VISIBLE DAMAGE to or resulting in VISIBLE DAMAGE to or or areas that contain systems and penetration of any of the following penetration of any of the following functions required for safe shutdown of the plant areas: (site-specific) list. buildings and areas. plant." Condensate Storage Tank The intent and meaning of the EAL are not Enclosure altered." Containment" Control Building" Cooling Tower" Diesel Generator Building" Emergency Feedwater Pump House" Equipment Vault" Fuel Storage Building" Primary Auxiliary Building" Service Water Pump House" Steam and Feedwater Pipe Chases" North Tank Farm" Turbine Building OR OR Page 55 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/I Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation 5. Uncontrolled flooding in (site-specific) areas of the plant that results in degraded safety system performance as indicated in the control room or that creates industrial safety hazards (e.g., electric shock) that precludes access necessary to operate or monitor safety equipment.

OR 6. (Site-Specific) occurrences within PROTECTED AREA boundary and resulting in VISIBLE DAMAGE to plant structures containing equipment necessary for safe shutdown, or has caused damage as evidenced by control room indication of degraded performance of those systems.5. Uncontrolled flooding in any of the following areas of the plant that results in 1) degraded safety system performance as indicated in the control room, or 2) creates industrial safety hazards (e.g., electric shock) that precludes access necessary to operate or monitor safety equipment." Condensate Storage Tank Enclosure" Containment" Control Building" Cooling Tower" Diesel Generator Building" Emergency Feedwater Pump House" Equipment Vault" Fuel Storage Building" Primary Auxiliary Building" Service Water Pump House" Steam and Feedwater Pipe Chases" NorthTank Farm" Turbine Building Not used.Difference Included site-specific list of plant structures or areas that contain systems and functions required for safe shutdown of the plant.The intent and meaning of the EAL are not altered.No additional site-specific occurrences were identified for inclusion as a separate EAL.Page 56 10/17/07 Page 56 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition HA2 Initiating Condition HA2 ___FIRE or EXPLOSION Affecting the FIRE or EXPLOSION affecting the Verbatim N/A Operability of Plant Safety Systems operability of plant safety systems required Required to Establish or Maintain Safe to establish or maintain safe shutdown Shutdown.Op. Modes: All Op. Modes: All Emergency Action Levell's)

Emergency Action Level(s)_______

2V.i 1. FIRE or EXPLOSION in any of the 1. FIRE or EXPLOSION in any Of the Difference Included site-specific areas containing following (site-specific) areas: following areas: functions and systems required for the safe shutdown of the plant.(Site-specific) list a Condensate Storage Tank Enclosure Reworded EAL #2 to improve readability a Containment and application.

0 Control Building 0 Cooling Tower Incorporated reference to "safety-related 0 Diesel Generator Building systems" in EAL 2 per basis discussion 0 Emergency Feedwater Pump and to maintain consistency with IC House statement.

0 Equipment Vault 0 Fuel Storage Building The intent and meaning of the EAL are not E Primary Auxiliary Building altered.E Service Water Pump House M Steam and Feedwater Pipe Chases 0 North Tank Farm-Turbine Building AND AND Affected system parameter indications

2. Plant personnel report VISIBLE show degraded performance or plant DAMAGE to permanent structures or personnel report VISIBLE DAMAGE to equipment within the affected area, or permanent structures or equipment Control Room indication of degraded within the specified area. performance of safety-related systems within the area.Page 57 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition HA3 Release of Toxic or Flammable Gases Within or Contiguous to a VITAL AREA Which Jeopardizes Operation of Systems Required to Maintain Safe Operations or Establish or Maintain Safe Shutdown.Initiating Condition HA3 Release of a toxic, corrosive, asphyxiant or flammable gas within or contiguous to a VITAL AREA affecting equipment required to maintain safe operations, or establish or maintain safe shutdown Difference Included "corrosive" and "asphyxiant" gasses in IC and EAL to be consistent with the definition of a dangerous (IDLH)atmosphere as presented in 29 CFR 1910.120.

Also refer to EAL FAQ #2006-024. Replaced "which jeopardizes operation of systems" with "affecting equipment" for clarity.Op. Modes: All OD. Modes: All Emergency Action Level(s) Emergency Action Level(s) 2 1. Report or detection of toxic gases within or contiguous to a VITAL AREA in concentrations that may result in an atmosphere IMMEDIATELY DANGEROUS TO LIFE AND HEALTH (IDLH).OR 2. Report or detection of gases in concentration greater than the LOWER FLAMMABILITY LIMIT within or contiguous to a VITAL AREA.1. Report or detection of a toxic, corrosive, asphyxiant or flammable gas release within a VITAL AREA, or areas contiguous (in actual contact with or immediately adjacent) to a VITAL AREA.AND 2. a. The operability of safety-related equipment is compromised due to personnel access restrictions.

OR b. The operability of safety-related equipment is compromised due to potential or actual effects from the gas.Difference Pulled in additional definitior area from the basis section.n of a "contiguous" Included both gas types from generic EALs #1 and #2 in Seabrook EAL #1.The IDLH and Lower Flammability Limit criteria were not used since determination of these levels requires air sampling (as is implied in the basis information).

It is not likely that~air sampling and subsequent analysis would be completed in time to support a timely emergency declaration.

The IC and basis descriptions are both focused on events affecting safe operation or safe shutdown.

This focus is maintained in Seabrook EALs #2.a and #2.b. These EALs address the loss or impairment of safety-related equipment caused by either personnel access restrictions, or the potential or actual effects from the gas (on the equipment).

Either EAL can be readily evaluated by the Control Room.The intent and meaning of the ICs and EALs are not altered._________________________________________

L _________________________________________

L ______________

C Page 58 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition HA4 Initiating Condition HA4 _,__ _ _ _ _ _ _ _ _ _ __;_ _ _Confirmed security event in a plant Confirmed security event in a plant Verbatim N/A PROTECTED AREA. PROTECTED AREA SOp. Modes: All Op. Modes: All Emergency Action Level(s) Emergency Action Level(s) ... .1. INTRUSION into the plant 1. Security shift supervision reports one Deviation Generic EAL #1 was originally included in PROTECTED AREA by a HOSTILE of the following events. (generic EAL NEI 99-04, Rev. 4, when issued. This EAL FORCE. #1) was subsequently superceded by a. Explosive device (bomb) found information contained in NRC Bulletin OR inside the Protected Area. 2005-02. BL 2005-02 stated, "Delete.OR , existing EALS as follows: 1. HA4 EAL1 2. Other security events as determined

b. An act of Radiological Sabotage Difference (INTRUSION into the PROTECTED AREA from (site-specific)

Safeguards has occurred. (generic EAL by a HOSTILE FORCE) because it is Contingency Plan and reported by the #2) replaced by the new HOSTILE ACTION (site-specific) security shift supervision Radiological Sabotage means any EAL HA8." deliberate act directed against the plant, or against a component of Included selected events from station the plant, which could directly or security plans and procedures that aligned indirectly endanger the public with the definition of an Alert and the health and safety by exposure to criteria discussed in the basis section.radiation.

The definition of radiological sabotage is derived from 10 CFR 73.2 The intent and meaning of the EALs are not altered.Page 59 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition HA5 Initiating Condition HA5 _ .__________

Control Room Evacuation Has Been Control Room evacuation has been Verbatim N/A Initiated.

initiated Op. Modes: All Op. Modes: All Emergency Action Level(s) Emergency Action Level(s) , 1. Entry into (site-specific) procedure for 1. Entry into Procedure OS1 200.02 for Difference Included site-specific procedure reference.

control room evacuation, control room evacuation.

The intent and meaning of the EAL are not altered.Page 60 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition HA6 Initiating Condition HA6 ...._..______Other Conditions Existing Which in the Other conditions existing which in the Verbatim Substituted site-specific term: "STED/SED" Judgment of the Emergency Director judgment of the STED/SED warrant for "Emergency Director" (See Note Warrant Declaration of an Alert. declaration of an Alert below).Op. Modes: All Op. Modes: All Emergency Action Level(s) Emergency Action Level(s)1. Other conditions exist which in the 1. Other conditions exist which in the Difference Incorporated revised Alert definition per judgment of the Emergency Director judgment of the STED/SED indicate NRC Bulletin 2005-02 and related NEI indicate that events are in process or that events are in process or have White Paper.have occurred which involve actual or occurred which involve an actual or likely potential substantial degradation potential substantial degradation of the Substituted site-specific term: "STED/SED" of the level of safety of the plant. Any level of safety of the plant or a security for "Emergency Director".

releases are expected to be limited to event that involves probable life small fractions of the EPA Protective threatening risk to site personnel or The intent and meaning of the IC and EAL Action Guideline exposure levels, damage to site equipment because of are not altered.HOSTILE ACTION. Any releases are expected to be limited to small NOTE -the STED is the Short Term fractions of the EPA Protective Action Emergency Director (a.k.a. the Shift Guideline exposure levels. Manager).

The SED is the Site Emergency Director (the lead manager in the TSC). These are the two individuals who may make emergency declarations.

The SED relieves the STED of this function.Page 61 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Deviation Initiating Condition HA 7 Initiating Condition HA 7 :___i Notification of an Airborne Attack Threat. Notification of an airborne attack threat Deviation Initiating Condition HA7 was not included Op. Modes: All Op. Modes: All in NEI 99-04, Rev. 4, when originally issued. This IC and the associated EAL were subsequently incorporated into the NEI 99-01 scheme by NRC Bulletin 2005-02.Emergency Action Level(s) Emergency Action Level(s) *___1. A validated notification from the NRC 1. A validated notification from the NRC Deviation See above.of an airliner attack threat less than 30 of an airliner attack threat < 30 minutes away. minutes away.Page 62 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/NEI9901,Re.

4Sebrok tatonDifference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition HA8 Initiating Condition HA8 Notification of HOSTILE FORCE within the Notification of HOSTILE ACTION within Deviation Initiating Condition HA8 was not included OCA. the OCA in NEI 99-04, Rev. 4, when originally Op. Modes: All Op. Modes: All issued. This IC and the associated EAL were subsequently incorporated into the NEI 99-01 scheme by NRC Bulletin 2005-02.Changed "HOSTILE FORCE" to"HOSTILE ACTION" to align IC wording with EAL and basis discussion.

This change does not affect meaning or intent.Emergency Action Level(s) Emergency Action Level(s)________Y

1. A notification from the site security 1. A notification from the site security Deviation See above.force that an armed attack, explosive force that an armed attack, explosive attack, airliner impact or other attack, airliner impact or other HOSTILE ACTION is occurring or has HOSTILE ACTION is occurring or has occurred within the OCA. occurred within the OCA.Page 63 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition HS1 Initiating Condition HSI 4K7 Confirmed Security Event in a Plant VITAL Not used Deviation NRC Bulletin 2005-02 directed deletion of AREA HS1 EAL 1 (INTRUSION into the plant VITAL AREA by a HOSTILE FORCE)because it is replaced by the new HOSTILE ACTION EAL HS4. The events covered by EAL 2 are subsumed within IC HS4. With the inclusion of IC HS4, IC HS1 is not required.Emergency Action Level(s) Emergency Action Level(s) .....1. INTRUSION into plant VITAL AREA Not used Deviation See above.by a HOSTILE FORCE.OR EAL #1 was originally included in NEI 99-2. Other security events as determined 04, Rev. 4, when issued. This EAL was from (site-specific)

Safeguards subsequently superceded by information Contingency Plan and reported by the contained in NRC Bulletin 2005-02.(site-specific) security shift supervision.

No site-specific events were identified per EAL #2 that were not already covered by IC HS4.Page 64 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/i Basis for Difference or Deviation Deviation Initiating Condition HS2 Initiating Condition HS2 Control Room Evacuation Has Been Control Room evacuation has been Verbatim N/A Initiated and Plant Control Cannot Be initiated and plant control cannot be Established.

established Op. Modes: All Op. Modes: All Emergency Action Level(s) Emergency Action Level(s) K K.1. Control room evacuation has been 1. Control room evacuation has been Difference Included site-specific procedure reference.

initiated, initiated.

AND AND Used the 15-minute value as discussed in Control of the plant cannot be 2. Control of the plant cannot be the basis section.established per (site-specific) established per Procedure procedure within (site-specific)

OS1200.02 within 15 minutes. The intent and meaning of the EALs are minutes. not altered.Page 65 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition HS3 Initiating Condition HS3 Other Conditions Existing Which in the Other conditions existing which in the Difference Substituted site-specific term: "STED/SED" Judgment of the Emergency Director judgment of the STED/SED warrant for "Emergency Director" (See Note Warrant Declaration of Site Area declaration of Site Area Emergency below).Emergency.

Op. Modes: All O~p. Modes: All Emergency Action Level(s) Emergency Action Level(s) : : : : ; ,1 , ; ;, : 1 .Other conditions exist which in the 1 .Other conditions exist which in the Difference Incorporated revised Site Area Emergency judgment of the Emergency Director judgm 'ent of the STED/SED indicate definition per NRC Bulletin 2005-02 and indicate that events are in process or that events are in process or have related NEI White Paper.have occurred which involve actual or occurred which involve an actual or likely major failures of plant functions likely major failures of plant functions Substituted site-specific term: "STED/SED" needed for protection of the public, needed for protection of the public or for "Emergency Director".

Any releases are not expected to HOSTILE ACTION that results in result in exposure levels which exceed intentional damage or malicious acts; The intent and meaning of the IC and EAL EPA Protective Action Guideline (1) toward site personnel or equipment are not altered.exposure levels beyond the site that could lead to the likely failure of boundary.

or; (2) that prevent effective access to NOTE -the STED is the Short Term equipment needed for the protection of Emergency Director (a.k.a. the Shift the public. Any releases are not Manager).

The SED is the Site expected to result in exposure levels Emergency Director (the lead manager in which exceed EPA Protective Action the TSC). These are the two individuals Guideline exposure levels beyond the who may make emergency declarations.

site boundary.

The SED relieves the STED of this function.Page 66 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/'NE 9901,Rev 4 eabookStaionDifference/.

L EBasis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition HS4 Initiating Condition HS4 i <!j Site Attack. Notification of HOSTILE ACTION within Deviation Initiating Condition HS4 was not included Op. Modes: All the PROTECTED AREA in NEI 99-04, Rev. 4, when originally Op. Modes: All issued. This IC and the associated EAL were subsequently incorporated into the NEI 99-01 scheme by NRC Bulletin 2005-02.Pulled information from EAL and basis into IC statement, i.e., the IC deals with a Hostile Action within the Protected Area.The intent and meaning of the IC is not altered.Emergency Action Level(s) Emergency Action Le vel(s) : 1. A notification from the site security 1. A notification from the site security Deviation See above.force that an armed attack, explosive force that an armed attack, explosive attack, airliner impact, or other attack, airliner impact, or other HOSITLE ACTION is occurring or has HOSITLE ACTION is occurring or has occurred within the PROTECTED occurred within the PROTECTED AREA. AREA.Page 67 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition HG 1 Initiating Condition HG1 _Security Event Resulting in Loss Of Security event resulting in loss of physical Verbatim N/A Physical Control of the Facility.

control of the facility Op. Modes: All Op.. Modes: All Emergency Action Level(s) Emergency Action Level(s) <' :,. '1. A HOSTILE FORCE has taken control 1. A HOSTILE FORCE has taken Verbatim N/A of plant equipment such that plant control of plant equipment such that personnel are unable to operate plant personnel are unable to operate equipment required to maintain safety equipment required to maintain safety functions.

functions.

Page 68 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition HG2 Initiating Condition HG2 Other Conditions Existing Which in the Other conditions existing which in the Difference Substituted site-specific term: "STED/SED" Judgment of the Emergency Director judgment of the STED/SED warrant for "Emergency Director" (See Note Warrant Declaration of General declaration of General Emergency below).Emergency.

Op. Modes: All Op. Modes: All Emergency Action Level(s) Emergency Action Level(s)1. Other conditions exist which in the 1. Other conditions exist which in the Difference Incorporated revised General Emergency judgment of the Emergency Director judgment of the STED/SED indicate definition per NRC Bulletin 2005-02 and indicate that events are in process or that events are in process or have related NEI White Paper.have occurred which involve actual or occurred which involve actual or imminent substantial core degradation imminent substantial core degradation Substituted site-specific term: "STED/SED" or melting with potential for loss of or melting with potential for loss of for "Emergency Director".

containment integrity.

Releases can be containment integrity or HOSTILE reasonably expected to exceed EPA ACTION that results in an actual loss The intent and meaning of the IC and EAL Protective Action Guideline exposure of physical control of the facility, are not altered.levels offsite for more than the Releases can be reasonably expected immediate site area. to exceed EPA Protective Action NOTE -the STED is the Short Term Guideline exposure levels offsite for Emergency Director (a.k.a. the Shift more than the immediate site area. Manager).

The SED is the Site Emergency Director (the lead manager in the TSC). These are the two individuals who may make emergency declarations.

The SED relieves the STED of this function.Page 69 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM Verbatim/NEI 99-01, Rev. 4 Seabrook StationVebtm NEI9901,Re.

4Sebrok tatonDifference!

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition SUI Initiating Condition SUI Loss of All Offsite Power to Essential Loss of all offsite power to AC emergency Difference Included site-specific noun name;Buses for Greater Than 15 Minutes. buses for > 15 minutes Seabrook procedures refer to these buses Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 as "AC emergency", not "essential".

Refer_to EAL FAQ #2006-002.

Emergency Action Level(s) Emergency Action Level(s) &. K 1. Loss of power to (site-specific)

1. Both AC emergency busses E5 AND Difference Changed EAL #1 to evaluate the status of transformers for greater than 15 E6 are not powered from an offsite AC emergency buses instead of their minutes. source for > 15 minutes. associated transformers.

This aligns the EAL wording and the IC intent/wording, AND AND and with steps and terminology used in At least (site-specific) emergency

2. Power restored to at least one AC station procedures.

It focuses the generators are supplying power to emergency bus (E5 OR E6) from an classification on the loss of bus power emergency buses. emergency diesel generator or rather than the status of one or more SEPS. transformers that may or may not be capable of powering an emergency bus.NOTE -If only one power source is This change is consistent with the IC basis available to energized bus or buses, description and EAL FAQ #2006-002.

refer to IC SA5.Included site-specific equipment identification.

Bus E5 and E6 are the AC emergency buses that supply ECCS and other safety-related loads. SEPS is the Supplemental Emergency Power System.The intent and meaning of the IC and EALs is not altered, i.e., an Unusual Event will be required if all offsite power is lost to AC emergency buses, and one or both AC emergency buses is/are powered by their respective emergency diesel generator or SEPS.Page 70 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/

T Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition SU2 Initiating Condition SU2 T 'Inability to Reach Required Shutdown Inability to reach required shutdown within Verbatim N/A Within Technical Specification Limits. Technical Specification limits Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergenc Action Level S 1. Plant is not brought to required 1. The plant is not brought to a required Difference Wording changes to improve readability.

operating mode within (site-specific) operating mode within the time Technical Specifications LCO Action specified by a Technical Specification The intent and meaning of the EAL are not Statement Time. LCO Action Statement.

altered. If the plant is not brought to a required operating mode within a Technical Specifications LCO Action Statement Time, then an Unusual Event declaration will be required.Page 71 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition SU3 Initiating Condition SU3 UNPLANNED Loss of Most or All Safety UNPLANNED loss of most or all safety Difference Used mathematical symbol instead of text System Annunciation or Indication in The system annunciation or indication in the for value comparison.

Control Room for Greater Than 15 Minutes Control Room for > 15 minutes Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s) _;_________

__________________________________

1. UNPLANNED loss of most or all (site- 1. UNPLANNED loss of approximately Difference Included site-specific noun names. The specific) annunciators or indicators 75% or more of UA annunciators for > "UA annunciators" monitor essential plant associated with safety systems for 15 minutes. parameters (EAL 1). The Main Control greater than 15 minutes. Board contains the indications referred to OR in Abnormal and Emergency Operating 2. UNPLANNED loss of approximately Procedures.

These indications would be 75% or more of Main Control Board used to monitor changing plant conditions indications for > 15 minutes. (EAL 2).OR 3. UNPLANNED loss of approximately Pulled "75% or more" criteria and loss of 75% or more of radiation monitor radiation monitor indications (EAL 3) from indications for > 15 minutes. basis section into EALs.Broke out the multiple decision-making criteria in generic EAL 1 into Seabrook EALs #1 .a and 1 .b.The intent and meaning of the EAL are not altered.Page 72 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/

T NEI99-1, ev.4 Sabrok tatonDifference/l Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation j ...Initiating Condition SU4 Initiating Condition SU4 _________" Fuel Clad Degradation.

Fuel clad degradation Verbatim N/A Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s)1. (Site-specific) radiation monitor 1. VALID reading > 2,670 mR/hr on the Difference In EAL #1, included VALID so that other readings indicating fuel clad letdown radiation monitor, RM-6520-1.

indications could be used to validate the degradation greater than Technical monitor's accuracy and operability.

Added Specification allowable limits, site-specific radiation monitor noun name OR OR and number, and reading.2. (Site-specific) coolant sample activity 2. Any RCS activity value > Technical value indicating fuel clad degradation Specification allowable limits as Wording changes in EAL #2 to improve greater than Technical Specification indicated by Chemistry Department readability and promote consistent allowable limits, sampling results. application (reference to Chemistry Department sampling results).The intent and meaning of the EALs are not altered.Page 73 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/NEI99-1, ev.4 Sabrok tatonDifference!.

Basis for Difference or Deviation

, Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation

........Initiating Condition SU5 Initiating Condition SU5 _____ TWAL r RCS Leakage. RCS leakage Verbatim N/A-Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s) _..........................._-_______

1. Unidentified or pressure boundary 1. RCS unidentified or pressure boundary Difference Inserted "RCS" into EALs 1 and 2 to leakage greater than 10 gpm. leakage > 10 gpm. improve clarity and maintain consistency OR OR with IC wording.2. Identified leakage greater than 25 2. RCS identified leakage > 25 gpm.gpm. The intent and meaning of the EALs are not altered.Page 74 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition SU6 Initiating Condition SU6 UNPLANNED Loss of All Onsite or Offsite UNPLANNED loss of all onsite or offsite Verbatim N/A Communications Capabilities.

communications capabilities Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3,4 SEmergency Action Level(s) Emergency Action Level(s) .> .1. Loss of all (site-specific list) onsite 1. Loss of all of the following onsite Difference Added site-specific equipment to EALs.communications capability affecting communications capabilities affecting the ability to perform routine the ability to perform routine operations.

The intent and meaning of the EALs are operations.

not altered." Telephones" Gai-Tronics" Plant Radio System OR OR 2. Loss of all (site-specific list) offsite 2. Loss of all of the following offsite communications capability, communications capabilities.

N Nuclear Alert System (NAS)E Backup NAS (Zetron/Nextel unit)N Emergency Notification System (ENS)0 Telephones Page 75!10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition SU8 Initiating Condition SU8 __,_____Inadvertent Criticality.

Inadvertent criticality Verbatim N/A Op Modes: 3, 4 Op Modes: 3, 4 Emergency Action Level(s) Emergency Action Level(s) 1. An UNPLANNED extended positive 1. An UNPLANNED sustained positive Difference The EAL containing "positive period" period observed on nuclear startup rate observed on nuclear (generic EAL #1) was not used as this instrumentation.

instrumentation, term is not consistent with Seabrook OR Station operating procedures.

Operators 2. An UNPLANNED sustained positive use "startup rate" to monitor criticality and startup rate observed on nuclear the Seabrook Station EAL using "startup instrumentation.

rate" adequately addresses events involving an inadvertent criticality.

The intent and meaning of the EAL are not altered.Page 76 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition SA2 Initiating Condition SA2 __________________________

Failure of Reactor Protection System ATWS and manual trip from the MCB was Difference Station EOPs refer to this type of event as Instrumentation to Complete or Initiate an successful an Anticipated Transient Without Scram Automatic Reactor Scram Once a Reactor (ATWS). Used this term to align IC Protection System Setpoint Has Been description with station EOPs. Pulled in Exceeded and Manual Scram Was criteria for a manual trip from the Main Successful.

Op. Modes: 1, 2, 3 Control Board (MCB) from the basis Op. Modes: 1, ta 3 discussion.

Emergency Action Level(s) Emergency Action Level(s) ,i 1. Indication(s) exist that indicate that 1 .Indication(s) exist that a reactor trip Difference Substituted "trip" for "scram" to reflect reactor protection system setpoint was setpoint has been exceeded.

station terminology.

exceeded and automatic scram did not occur, and a successful manual scram Broke out the multiple decision-making occurred.

criteria contained in the generic EAL into AND three "AND" EAL statements.

This will 2. An automatic reactor trip did not improve readability and application.

occur.AND Included site-specific term "MCB" -Main 3. A manual reactor trip from the MCB Control Board -to align EAL with basis was successful as indicated by information.

neutron flux < 5%.Included definition of a "successful" trip that aligns with a station EOP setpoint, i.e.,"neutron flux < 5%".The intent and meaning of the IC and EAL are not altered.Page 77 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition SA4 Initiating Condition SA4 TK: <UNPLANNED Loss of Most or All Safety UNPLANNED loss of most or all safety Verbatim N/A System Annunciation or Indication in system annunciation or indication in Control Room With Either (1) a Control Room with either (1) a SIGNIFICANT TRANSIENT in Progress, or SIGNIFICANT TRANSIENT in progress, or (2) Compensatory Non-Alarming Indicators (2) compensatory non-alarming indicators are Unavailable.

are unavailable Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s) ' =1. UNPLANNED loss of most or all (site- 1. a. UNPLANNED loss of approximately Difference Included site-specific noun names. The specific) annunciators or indicators 75% or more of UA annunciators "UA annunciators" monitor essential plant associated with safety systems for for > 15 minutes. parameters (EAL 1 .a). The Main Control greater than 15 minutes. Board contains the indications referred to OR in Abnormal and Emergency Operating b. UNPLANNED loss of approximately Procedures.

These indications would be 75% or more of Main Control Board used to monitor changing plant conditions indications for > 15 minutes. (EAL 1 .b).OR c. UNPLANNED loss of approximately Pulled "75% or more" criteria and loss of 75% or more of radiation monitor radiation monitor indications (EAL 1 .c)indications for > 15 minutes. from basis section into EALs.AND AND Either of the following: (a or b) 2. Either of the following: (a or b) Broke out the multiple decision-making

a. A SIGNIFICANT TRANSIENT is in a. A SIGNIFICANT TRANSIENT is in criteria in generic EAL 1 into Seabrook progress.

progress.

EALs #1 .a and 1 .b.OR OR b. Compensatory non-alarming

b. Compensatory non-alarming The intent and meaning of the EAL are not indications are unavailable, indications are unavailable.

altered.Page 78 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation

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

Initiating Condition SA5 AC power capability to essential buses reduced to a single power source for greater than 15 minutes such that any additional single failure would result in station blackout.AA-.,4-c,-

"4 0 A Initiating Condition SA5 Power to AC emergency buses reduced to a single power source for > 15 minutes such that any additional single failure would result in station blackout Difference Changed wording to improve readability.

Included site-specific noun name;Seabrook procedures refer to these buses as "AC emergency", not "essential".

This is consistent with the resolution for EAL CAfn 4#')AA~ IV)) M1-4 0A~1 AC power capability to site-specific essential buses reduced to a single power source for greater than 15 minutes.AND Any additional single failure will result in station blackout.C11viu llf'y ,iuluu, LCruwgp/1. At least one AC emergency bus is energized

-Bus E5 AND/OR Bus E6.AND 2. Only one power source is available to the energized bus/buses such that the loss of this source would result in a station blackout.AND 3. 15 minutes has elapsed with only one power source available.

,11LAuue b1Lte-Z5pt::L11; equipientil identification.

Bus E5 and E6 are the AC emergency buses that supply ECCS and other safety-related loads.Broke out information in generic EAL #1 to Seabrook Station EALs #1 and #3 to improve readability.

The wording in EAL #1 and #2 accommodates

1) a single power source for both buses (e.g., one offsite power line), and 2) a single power source for one bus (e.g., an emergency diesel generator or the Supplemental Emergency Power System).The intent of the IC and EALs is not altered, i.e., an Alert will be required if AC power capability to an emergency bus(es)is reduced to a single power source for greater than 15 minutes such that any additional single failure would result in station blackout.Page 79 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM Verbatim/NEI 99-01, Rev. 4 Seabrook StationVebtm Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition SSI Initiating Condition SS1 -K>:<Loss of All Offsite Power and Loss of All Loss of both AC emergency buses for > 15 Difference Included site-specific noun name; Seabrook Onsite AC Power to Essential Buses. minutes procedures refer to these buses as "AC Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Buses", not "Essential Buses".Refer to EAL FAQ #2006-003.

Used synonymous wording; the loss of an AC emergency bus implies that all "Offsite" and"Onsite" power sources are lost. Pulled in "15 minutes" per the basis discussion.

Emergency Action Level(s) EmergenyActin Levels..(s)__.___..____

1. Loss of power to (site-specific)

1. BOTH AC emergency buses E5 AND' Difference Changed EAL #1 to evaluate the status of AC transformers.

E6 are de-energized.

emergency buses instead of their associated AND AND transformers.

This aligns the EAL wording with Failure of (site-specific) emergency

2. 15 minutes has elapsed with BOTH the IC intent/wording, and with steps and terminology used in station procedures.

It generators to supply power to AC emergency buses E5 AND E6 de- focuses the classification on the loss of bus emergency buses. energized.

power rather than the status of one or more AND transformers that may or may not be capable of Failure to restore power to at least one powering an emergency bus. This change is emergency bus within (site-specific) consistent with the IC basis description and minutes from the time of loss of both EAL FAQ #2006-003.

offsite and onsite AC power. Included site-specific equipment identification.

Bus E5 and E6 are the AC emergency buses that supply ECCS and other safety-related loads.Generic EAL 1 .b is subsumed by EAL #1 (de-energized means no emergency generator).

Used term "de-energized" instead of "loss" to be consistent with station procedures.

Used 15 minutes per basis discussion.

The intent and meaning of the IC and EALs is not altered, i.e., a Site Area Emergency will be required if all power sources are lost to AC emergency buses for greater than 15 minutes.Page 80 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/

Basis for Difference or Deviation Deviation Initiating Condition SS2 Initiating Condition SS2 7:7 .... ,, ,: .,"ti ,.Failure of Reactor Protection System ATWS and manual trip from the MCB was Difference Station EOPs refer to this type of event as Instrumentation to Complete or Initiate an NOT successful an Anticipated Transient Without Scram Automatic Reactor Scram Once a Reactor (ATWS). Used this term to align IC Protection System Setpoint Has Been description with station EOPs. Pulled in Exceeded and Manual Scram Was NOT criteria for a manual trip from the Main Successful.

Op. Modes: I and 2 Control Board (MCB) from the basis Op. Modes: 1 and 2 discussion.

Emergency Action Level(s) Emergency Action Level(s)1. Indication(s) exist that automatic and 1. Indication(s) exist that a reactor trip Difference Substituted "trip" for "scram" to reflect manual scram were not successful.

setpoint has been exceeded.

station.terminology.

AND 2. An automatic reactor trip did not Broke out the multiple decision-making occur. criteria contained in the generic EAL into AND three "AND" EAL statements.

This will 3. A manual reactor trip from the MCB improve readability and application.

was NOT successful as indicated by neutron flux > 5%. Included site-specific term "MCB" -Main Control Board -to align EAL with basis information.

Included definition of a "not successful" trip that aligns with a station EOP setpoint, i.e.,"neutron flux > 5%".The intent and meaning of the IC and EAL are not altered.Page 81 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/NEI9901,Re.

4Sebrok tatonDifference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition SS3 Initiating Condition SS3 Loss of All Vital DC Power. Loss of all vital DC power for > 15 minutes Difference Pulled "15 minute" criteria from EAL and Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 bass information into IC statement.

Emergency Action Level(s) Emergency Action Level(s)1. Loss of All Vital DC Power based on 1 Voltage indications are < 105V on all Difference Added site-specific equipment (site-specific) bus voltage indications vital DC buses (11 A, 11 B, 11 C and identification.

11 A, 11 B, 11 C and 11D are for greater than 15 minutes. 11 D) for > 15 minutes. the vital DC power buses.Included site-specific DC bus voltage reading at the low end of the operability range, i.e., a DC bus is considered lost if bus voltage is less than 105V.The intent and meaning of the EALs are not altered.Page 82 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition SS4 Initiating Condition SS4 Complete Loss of Heat Removal Not used Deviation This IC and EAL are redundant with an IC Capability.

and EALs contained in the Fission Product Op. Modes: 1, 2, 3, 4 Barrier Degradation Matrix. Specifically, a C Red (loss of core cooling) is an EAL for Loss of the Fuel Clad Barrier. An H Red (loss of heat sink) is an EAL for Potential Loss of the RCS Barrier. In accordance with IC FS1, Loss or Potential Loss of ANY Two Barriers, the simultaneous occurrence of a C Red and an H Red would be classified as a Site Area Emergency.

This is the same classification required by IC SS4. IC SS4 was not utilized because it is redundant with IC FS1 for the stated EAL conditions.

Emergency Action Level(s) Emergency Action Level(s) I 1. Loss of core cooling and heat sink Not used Deviation See above.(PWR).Page 83 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition SS6 Initiating Condition SS6 Inability to Monitor a SIGNIFICANT Inability to monitor a SIGNIFICANT Verbatim I N/A TRANSIENT in Progress.

TRANSIENT in progress I Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s)1. a. Loss of most or all (site-specific)

1. a. Loss of approximately 75% or Difference Included site-specific noun names. The annunciators associated with safety more of UA annunciators. "UA annunciators" monitor essential plant systems. parameters (EAL 1.a). The Main Control OR Board contains the indications referred to b. Loss of approximately 75% or in Abnormal and Emergency Operating more of Main Control Board Procedures.

These indications would be indications.

used to monitor changing plant conditions OR (EAL 1.b).c. Loss of approximately 75% or more of radiation monitor Pulled '75% or more" criteria and loss of indications, radiation monitor indications (EAL 1.c)AND AND from basis section into EALs.b. Compensatory non-alarming

2. Compensatory non-alarming indications are unavailable.

indications are unavailable.

Reworded generic EAL 1.c to EAL 3 based AND AND on basis discussion.

As used at Seabrook, c. Indications needed to monitor (site- 3. Complete loss of the ability to monitor the Critical Safety Functions monitor specific) safety functions are all Critical Safety Functions.

Subcriticality, Core Cooling, Heat Sink, unavailable.

RCS Integrity, Containment, RCS AND AND Inventory, Emergency Coolant d. SIGNIFICANT TRANSIENT in 4. SIGNIFICANT TRANSIENT in Recirculation and RDMS (normal gaseous progress.

progress.

effluent pathways).

The intent and meaning of the EAL are not altered.Page 84 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/G Difference/

Basis for Difference or Deviation Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Deviation Initiating Condition SG I Prolonged Loss of All Offsite Power and Prolonged Loss of All Onsite AC Power to Essential Buses.Op. Modes: 1, 2, 3 and 4 Initiating Condition SG I Prolonged loss of both AC emergency buses Op. Modes: 1, 2, 3 and 4 Difference Included site-specific noun name; Seabrook EOPs refer to these buses as "AC Emergency Buses", not "Essential Buses". Refer to EAL FAQ #2006-016.

Used synonymous wording;the loss of an AC emergency bus-implies that all "Offsite" and "Onsite" power sources are Emeraencv Action Level(s)Emeraencv Action Level(s)+ -, .. 4 1. Loss of power to (site-specific) transformers.

AND Failure of (site-specific) emergency diesel generators to supply power to emergency buses.AND Either of the following: (a or b)a. Restoration of at least one emergency bus within (site-specific) hours is not likely OR b. (Site-Specific)

Indication of continuing degradation of core cooling based on Fission Product Barrier monitoring.

1. BOTH AC emergency buses E5 AND E6 are de-energized.

AND 2. One or more of the following conditions exist: (a or b or c)a. Restoration of at least one bus (E5 or E6) within four (4) hours is not likely.OR b. Core Cooling ORANGE path.OR c. Core Cooling RED path.Difference Changed EAL #1 to evaluate the status of AC emergency buses instead of their associated transformers.

This aligns the EAL wording with the IC intent/wording, and with steps and terminology used in station EOPs. It focuses the classification on the loss of bus power rather than the status of one or more transformers that may or may not be capable of powering an emergency bus. This change is consistent with the IC basis description and EAL FAQ #2006-016.

Included site-specific equipment identification.

Bus E5 and E6 are the AC emergency buses that supply ECCS and other safety-related loads. Per UFSAR Section 8.4, Seabrook has a four (4) hour coping period for a station blackout.A Core Cooling ORANGE and RED path represents a severe and extreme challenge to core cooling, respectively.

These conditions would indicate a "continuing degradation of core cooling".The intent and meaning of the IC and EAL are not altered.Page 85 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM NEI 99-01, Rev. 4 Seabrook Station Verbatim/

T Generic Guidance IC and EAL(s) Site-Specific IC and EAL(s) Difference/l Basis for Difference or Deviation Deviation 4Initiating Condition SG2 Failure of the Reactor Protection System to Complete an Automatic Scram and Manual Scram was NOT Successful and There is Indication of an Extreme Challenge to the Ability to Cool the Core.Op. Modes: 1 and 2 Initiating Condition SG2 ATWS and manual trip from the MCB was NOT successful, AND extreme challenge to Core Cooling or Heat Sink Op. Modes: I and 2 Difference Station EOPs refer to this type of event as an Anticipated Transient Without Scram (ATWS). Used this term to align IC ,description with station EOPs. Pulled criteria for a manual trip from the Main Control Board (MCB), and "Core Cooling" and "Heat Sink" criteria, from EAL and Emergency Action Level(s)1. Indications exist that automatic and manual scram were not successful.

AND Either of the following: (a or b)a. Indication(s) exists that the core cooling is extremely challenged.

OR b. Indication(s) exists that heat removal is extremely challenged.

Emergency Action Level(s)1. Indication(s) exist that a reactor trip setpoint has been exceeded.AND 2. An automatic reactor trip did not occur.AND 3. A manual reactor trip from the MCB was NOT successful as indicated by neutron flux > 5%.AND 4. Either of the following: (a or b)a. Core Cooling RED path.OR b. Heat Sink RED path.Difference Substituted "trip" for "scram" to reflect station terminology.

Broke out the multiple decision-making criteria contained in generic EAL 1 into three "AND" EAL statements.

This will improve readability and application.

NEI 99-01 EAL #1 .a is equivalent to SS EAL #4.a. WOG guidance defines a Core Cooling RED path as an extreme challenge to core cooling. NEI 99-01 EAL#1 .b is equivalent to SS EAL #4.b. WOG guidance defines a Heat Sink RED path as an extreme challenge to heat removal.Included site-specific term "MCB" -Main Control Board to align EAL with basis information.

Included definition of a "not successful" trip that aligns with a station EOP setpoint, i.e., "neutron flux is > 5%".The intent and meaning of the IC and EAL are not altered.Page 86 10/17/07 Page 86 10/17/07 COMPARISON MATRIX OF NEI 99-01, REV. 4, GENERIC GUIDANCE TO PROPOSED SEABROOK STATION EMERGENCY CLASSIFICATION SYSTEM Page 87 10/17/07 CATEGORY F -FISSION PRODUCT BARRIER DEGRADATION MATRIX Modes 1, 2, 3 and 4 Fuel Clad Barrier Reactor Coolant System Barrier Containment Barrier Sub-Category Potential Loss Loss Potential Loss Loss Potential Loss Loss Core Cooling Orange RCS Integrity Red (W RCS press 300 psig)1. CSF Status OR Core Cooling Red OR Containment Red Emergency Coolant Recirculation Orange Heat Sink Red Heat Sink Red-1. a. Core Exit TCs a ,100* F AND-- b. FR-C.1 not effectiveethin 15iminutes.

OR 2. Core Exit TCs Core Ext TCs- 2725' F Core Exit TCs 1,100' F 2. a. CoreExitTCsn725'F q AND b. RVLlS full range level s40%F-lnt AND FR-C.1 not effective within 15 minutes.*RVLIS dynamic head S4d4% with 4RCPs running 5 530% wth 3 RCPs running 3. Reactor Vessel Level 5 020% with 2 RCPs running.013% wilth 1 RCP running, or* VL'IS tull rangn level 5 040% withno RCP running RCS activity>

300 uCifgm Done Equivalent 1-131 (as determined per Procedure 4. RCS Activily : .CS0925.01, Reactor Coolant Post Accident Stampling)

Unioolahie leak > the capacity o n 5. RCS Leakage centrfugol charging pump in the normal RCS suhcoolig

< 40OF due to an RCS lea charging mode.___________________

1. RUPTURED Sf0 in also FAULTED outside of containment OR 6. Sf0 Rupture or Fault ::Entry into Procedure E-3 ....2. Primary.to-Soondary leak rate> 10 gt with nnnisolahle steam release from 1 COrot. pressure > 02 psig and increasing OR 1. Rapid unexplained pressure decrease 2. Cnmt. hydrogen concentration

?. 6% following initial increase 7. Containment Pressure .OR OR 3. a. Cnmtu pressure,>

10 psig 2. Containment pressure response cot AND consistent with LOCA conditions bh No Cnmt Building Spray (CBS)8. Containment

-.Post-LOCA Radiation Monitom FPot-LOCA Radiation Monitoro Post-LOCA Radiation Monitors .Radiation Monitor RM-6576A-1 orRM-6576B-1 95 Rlhr ' RM-6576A-1 -rRM-65766-1 a16 R/hr RM-6576A-1 orRM-6576B-1>

1.3055R/hr Cnmt. Isolation Valve(s) cot clcosed AND direct 9. Containment Isolaton pah. w.... .....pa ay to the environment exists after Cnmt.Valves .Isolation signal Any condition in the opinion of the STED/SED Any condition in the opinion of the STEDfSED Any condition in the opinion of the STEDfSED Any condition in the opinion of the STED/SED Any condition in the opinion of the STED/SED Any condition in the opinion of the STEDISED 10. STEDfSED that indicates a Potenhal Loss of the Fuel Clad that indicates a Lore of the Fuel Clad Barner that indicates a Potential Loss of the RCS that indicates a Loss of the RCS Barrier that indicates a Potential Lss of The that indicates a Loss of the Containment Judgment Earner). (consider inability to monitor barner). Barrier (consider inability to monitor barrer). (consider inability to monitor barrier).

Conit Bern. Barrier (consider inability to monitor barrier).(cnidrinbliytomnio are(. Brre (osie iaiit o oitrhae( cnIde naiyt oio are monitor barrer).Barrier Status Fuel Clad Potential Loss Outer 14 Fuel Clad Loss Enter / 4 RCS Potential Cor.' RCSLoss .Ee- ... r. 4 Containment Potential Lore Enter 14 Containment Lowr Ener/ a WWI=VEmergency Classification

.4 U. 0 E >Alert I Altrt I &Aleitvi I Alat~t~Enter a checkmark in atl the btanks to the right for each 'Potential Loss" or "Loss" noted above. Whtern alt checkcoarks have been ionterod, note each column that has all blanks checked. Rood up or dowen that column to determine the emergency classification.

ER 1.1 Rev.

ML073110410

Text

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