ML11215A181

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Attachment 5, Salem Generating Stations, EAL Technical Bases Document, EP-SC-111-201
ML11215A181
Person / Time
Site: Salem, Hope Creek  PSEG icon.png
Issue date: 07/30/2010
From:
Public Service Enterprise Group
To:
Office of Nuclear Reactor Regulation
References
Download: ML11215A181 (834)
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{{#Wiki_filter:ATTACHMENT 5 Salem Generating Stations EAL Technical Bases Document (Strike-out Version)

SGS ECG - EAL Technical Bases EP-SC-1 111-200 Nu.cear LLC (moneFOUI*g SUAHOn [Ewaný CýSzz~ 1 uýf©cTh©n Guig EL Emergency Action LeYeM Tsehrkcd Bases Draft E 7/30/2010

SGS ECG - EAL Technical Bases EP-SC-111-200 SALEM EVENT CLASSIFICATION GUIDE (ECG) EMERGENCY ACTION LEVEL (EAL) TECHNICAL BASES TABLE OF CONTENTS ECG - EAL Bases Front-Matter Materials: EP-SC-1 11-200 SGS ECG - EAL Technical Bases Table of Contents EP-SC-1 11-201 Emergency Action Level (EAL) Technical Basis Introduction EP-SC-111-202 ECG Usage ECG EAL Sections - Bases Information: EP-SC-i 11-203 EAL Bases for Category RI - Offsite Rad Conditions EP-SC-111-204 EAL Bases for Category R2 - Onsite Rad Conditions / Fuel Pool Events EP-SC-1 11-205 EAL Bases for Category R3 - CR/CAS Rad EP-SC-1 11-206 EAL Bases for Category E - ISFSI EP-SC-1 11-207 EAL Bases for Category H1 - Hazards - Natural & Destructive Phenomena (Quake, High Winds / Tornado, Turbine Rotating Component Failure, Internal Flooding, River Level, Vehicle Crash / Projectile Impact) EP-SC- 111-208 EAL Bases for Category H2 - Hazards - Fire or Explosion EP-SC- 111-209 EAL Bases for Category H3 - Hazards - Hazardous Gas EP-SC-1 11-210 EAL Bases for Category H4 - Hazards - Security EP-SC-1 11-211 EAL Bases for Category H5 - Hazards - Control Room Evacuation EP-SC-1 11-212 EAL Bases for Category H6 - Hazards - EC Judgment EP-SC-1 11-213 EAL Bases for Category S1 - System Malfunction - Loss of AC Power Salem Page 1 of 3 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-200 SALEM EVENT CLASSIFICATION GUIDE (ECG) EMERGENCY ACTION LEVEL (EAL) TECHNICAL BASES TABLE OF CONTENTS EP-SC-l 11-214 EAL Bases for Category S2 - System Malfunction - Loss of DC Power EP-SC-1 11-215 EAL Bases for Category S3 - System Malfunction - ATWT/Criticality EP-SC-1 11-216 EAL Bases for Category S4 - System Malfunction - Inability to Reach or Maintain Shutdown Conditions EP-SC-1 11-217 EAL Bases for Category S5 - System Malfunction - Loss of Annunciators / Instrumentation EP-SC-1 11-218 EAL Bases for Category S6 - System Malfunction - Communication EP-SC-1 11-219 EAL Bases for Category S7 - System Malfunction - Fuel Clad Degradation EP-SC-1 11-220 EAL Bases for Category S8 - System Malfunction - RCS Leakage EP-SC-1 11-221 EAL Bases for Category F1 - Fission Product Barriers - Fuel EP-SC-1 11-222 EAL Bases for Category F2 - Fission Product Barriers - RCS EP-SC-1 11-223 EAL Bases for Category F3 - Fission Product Barriers - Containment EP-SC-1 11-224 EAL Bases for Category C1 - Cold Shutdown / Refuel System Malfunction 

                - Loss of AC Power EP-SC-1 11-225   EAL Bases for Category C2 - Cold Shutdown / Refuel System Malfunction
                - Loss of DC Power EP-SC-1 11-226   EAL Bases for Category C3 - Cold Shutdown / Refuel System Malfunction
                - RPV Level EP-SC-1 11-227   EAL Bases for Category C4 - Cold Shutdown / Refuel System Malfunction
                - RCS Temperature Salem                              Page 2 of 3                     Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-200 SALEM EVENT CLASSIFICATION GUIDE (ECG) EMERGENCY ACTION LEVEL (EAL) TECHNICAL BASES TABLE OF CONTENTS EP-SC-1 11-228 EAL Bases for Category C5 - Cold Shutdown / Refuel System Malfunction 

                   - Communication EP-SC-1 11-229      EAL Bases for Category C6 - Cold Shutdown / Refuel System Malfunction
                   - Inadvertent Criticality ECG - EAL TechnlcaO Bases Supporting Documents:

EP-SC-1 11-230 - Use of Fission Product Barrier Table (Tab - Attachment 1) EP-SC-1 11-231 - EAL Bases Figures / Drawings (Tab - Attachment 2) EP-SC-1 11-232 - EAL Definitions (Tab - Attachment 3) EP-SC-1 11-233 - Glossary of Abbreviations & Acronyms (Tab - Attachment 4) EP-SC-i 11-234 - SGS-to-NEI 99-01 EAL Cross-reference (Tab - Attachment 5) EP-SC-i 11 -235 - Salem EAL Rad Set-Point Calculation Document (Tab - Attachment 6) Salem Page 3 of 3 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201 Nuclear LLC Salem Generating Station Event Classification Guide (ECG) Emergency Action Level Technical Bases Draft E 7/30/10

SGS ECG - EAL Technical Bases EP-SC- 111-201 TABLE OF CONTENTS Section Paqe

1. P u rp o se ................................................................................................. . ... . 2
2. Emergency Classification Descriptions .......................................................... 2
3. Fission P roduct B arriers ............................................................................. .. 3
4. EA L R elationship to EO Ps ............................................................................. 5
5. Symptom-Based vs. Event-Based Approach ......................... 5
6. E A L O rg a n izatio n ........................................................................................ .. 6
7. O perating Mode A pplicability ......................................................................... 8
8. EAL Technical Bases Organization ............................... 9
9. References ................................................ 11 Salem Page 1 of 11 Rev. 0 (draft E) l trodluction

SGS ECG - EAL Technical Bases EP-SC-1 11 -201

1. PURPOSE This document provides an explanation and rationale for each Salem Generating Station (SGS) Emergency Action Level (EAL). It should be used to facilitate review of the SGS EALs, provide historical documentation for future reference and serve as a training aid. Decision-makers responsible for implementation of the Event Classification Guide (ECG) may use this document as a technical reference in support of EAL interpretation. This information may assist the Emergency Coordinator in making classifications, particularly those involving judgment or multiple events. The information may also be useful in training, for explaining event classifications to offsite officials, and facilitate regulatory review and approval of the classification scheme.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification. This document is controlled pursuant to 10 CFR 50.54(q).

2. Emergency Classification Descriptions The NRC and Federal Emergency Management Agency (FEMA) established four emergency classes for fixed nuclear facilities.

An emergency class is used for grouping off-normal nuclear power plant conditions according to their relative radiological seriousness and the time sensitive onsite and offsite actions needed to respond to such conditions. The four emergency classes are (in order of less severe to most severe): o Unusual Event (UE) o Alert (A) o Site Area Emergency (SAE) o General Emergency (GE) 2.1 Unusual Event Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicates a security threat to facility protection has been initiated. o The lowest level of emergency at the plant, which can usually be handled by the normal operating shift. Salem Page 2 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201 o No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs. Dose consequences in Unrestricted Areas would not reach 20 mRem TEDE. 2.2 Alert Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. o Emergency Response personnel are required in addition to the normal operating shift. The entire emergency response organization is called in. The TSC is activated, and the EOF and ENC are manned and may activate if needed for support. o Any release of radioactive material is expected to be limited to a small fraction of the EPA Protective Action Guideline exposure levels. Dose consequences in Unrestricted Areas would not reach 100 mRem TEDE. 2.3 Site Area Emergency Events are in progress or have occurred which involve an actual or likely failure of plant functions needed for protection of the public or HOSTILE ACTION that result in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. o The entire emergency response organization is activated. o Any release of radioactive material is not expected to exceed EPA Protective Action Guideline exposure levels beyond the plant boundary. Dose consequences in Unrestricted Areas not to exceed 1000 mRem TEDE. 2.4 General Emergency Events are in process or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTIONS that result in an actual loss of physical control of the facility. o The entire emergency response organization is activated. o Release of radioactive material can be expected to exceed EPA Protective Action Guideline exposure levels of 1000 mRem TEDE in Unrestricted Areas.

3. Fission Product Barriers Many of the EALs derived from the NEI 99-01 methodology are fission product barrier based.

That is, the conditions that define the EALs pertain to the loss or potential loss of one or more Salem Page 3 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201 of the three fission product barriers. "Loss" and "Potential Loss" signify the relative damage and threat of damage to the barrier. "Loss" means the barrier no longer assures containment of radioactive materials; "Potential Loss" infers an increased probability of barrier loss and decreased certainty of maintaining the barrier. 3.1 Barrier Descriptions The EAL fission product barriers are: Fuel Clad Barrier (FB): The Fuel Clad barrier consists of the zircalloy or stainless steel fuel bundle tubes that contain the fuel pellets. Reactor Coolant System Barrier (RB): The Reactor Coolant System barrier includes the Reactor Coolant System primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves. Containment (CB): The Containment barrier includes the containment building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve. 3.2 Emergency Classification Based on Fission Product Barrier Degradation The following criteria for event classification relate to fission product barrier loss or potential loss: UNUSUAL EVENT ANY loss or ANY potential loss of Containment ALERT ANY loss or ANY potentialloss of either Fuel Clad or RCS SITE AREA EMERGENCY Loss or potential loss of ANY two barriersOR Potentialloss of 2 barrierswith the loss of the 3 rd barrier GENERAL EMERGENCY Loss of ANY two barriersand loss or potential loss of third barrier Salem Page 4 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201 Discrete threshold values associated with fission product barrier loss and potential loss are given in Attachment 1, Use of Fission Product Barrier Table. The bases for the thresholds are discussed in the following ECG sections: o EP-SC-1 11-221 EAL Bases for Fuel Clad Barrier o EP-SC-1 11-222 EAL Bases for RCS Barrier o EP-SC-1 11-223 EAL Bases for Containment Barrier A point system (described in Attachment 1) is used to determine fission product barrier emergency classification levels as well as Protective Action Recommendations (PARs) if a General Emergency is declared.

4. EAL Relationship to EOPs Where possible, the EALs have been made consistent with and utilize the conditions defined in the SGS Emergency Operating Procedures (EOPs). While the symptoms that drive operator actions specified in the EOPs are not indicative of all possible conditions which warrant emergency classification, they define the symptoms, independent of initiating events, for which reactor plant safety and/or fission product barrier integrity are threatened. When these symptoms are clearly representative of one of the NEI Initiating Conditions, they have been utilized as an EAL. This permits rapid classification of emergency situations based on plant conditions without the need for additional evaluation or event diagnosis. Although some of the EALs presented here are based on- conditions defihed in the EOPs,: classification of emergencies using these EALs is not dependent upon EOP entry or execution. The EALs can be utilized independently or in conjunction with the EOPs.
5. Symptom-Based vs. Event-Based Approach To the extent possible, the EALs are symptom-based; that is, the action level threshold is defined by values of key plant operating parameters that identify emergency or potential emergency conditions. This approach is appropriate because it allows the full scope of variations in the types of events to be classified as emergencies. However, a purely symptom-based approach is not sufficient to address all events for which emergency classification is appropriate. Particular events to which no predetermined symptoms can be ascribed have also been utilized as EALs since they may be indicative of potentially more serious conditions not yet fully realized.

Salem Page 5 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11 -201

6. EAL Organization 6.1 EAL Groups The EAL scheme is divided into three broad groups:

o EALs applicable under all plant operating modes - This group would be reviewed by the EAL-user any time emergency classification is considered. o EALs applicable only under hot operating modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup or Power Operations operating modes. o EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown or Refueling operating modes or when the Reactor Vessel is defueled. The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency. 6.2 EAL Categories and Subcategories Within each EAL group, EALs are assigned to categories/subcategories. Category titles generally align with the EAL Recognition Categories of NEI 99-01. Subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. Subcategories are used as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. Salem Page 6 of 11 Rev. 0 (draft E) Mnt oductdon

SGS ECG - EAL Technical Bases EP-SC-1 11-201 The SGS EAL categories/subcategories and their relationship to NEI Recognition Categories are listed below. SGS EALs Category T Subcategory Group: Any Operatino Mode: R - Abnormal Rad Release / Rad Effluent 1 - Offsite Rad Conditions 2 - Onsite Rad Conditions/Fuel Pool Events 3 - CRICAS Rad E - ISFSI Spent Fuel Transit H - Hazards & Other Conditions Affecting 1- Natural & Destructive Phenomena Plant Safety 2 - Fire or Explosion 3- Hazardous Gas 4 - Security 5- Control Room Evacuation 6 - EC Judgment Group: Hot Conditions: S - System Malfunction 1- Loss of AC Power 2 - Loss of DC Power 3- ATWT / Criticality 4- Inability to Reach or Maintain Shutdown Conditions 5- Instrumentation 6 - Communications 7 - Fuel Clad Degradation 8- RCS Leakage F - Fission Product Barrier Degradation None Group: Cold Conditions: C - Cold Shutdown / Refuel System 1- Loss of AC Power Malfunction 2 - Loss of DC Power 3- RCS Level 4 - RCS Temperature 5 - Communications 6- Inadvertent Criticality Salem Page 7 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201

7. Operating Mode Applicability With the exception of ISFSI (which is not assigned an operating mode), NEI 99-01 assigns one or more operating modes to each EAL. The ISFSI EAL will be applicable in all operating modes at Salem Generating Station; as such, operating mode applicability is N/A for the ISFSI EAL.

7.1 Operating Mode Definitions THERMAL MODE Keff POWER* TAVG

1. Power Operation > 0.99 > 5% > 350 F
2. Startup > 0.99 < 5% > 350'F
3. Hot Standby < 0.99 0 > 350'F
4. Hot Shutdown < 0.99 0 > 200'F & < 350'F
5. Cold Shutdown < 0.99 0 5 200'F
6. Refueling** < 0.95 0 < 140'F Defueled NA NA NA - no fuel in Reactor Vessel
  • Excluding Decay Heat
              **   Fuel in the Reactor Vessel with the head closure bolts less than fully tensioned or with the head removed 7.3    Applicability The plant operating mode that exists at the time that the event occurs (prior to any protective system or operator action is initiated in response to the condition) should be compared to the operating mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the operating mode that existed at the time the event occurred.

For events that occur in Cold Shutdown or Refueling, escalation is via EALs that have Cold Shutdown or Refueling for mode applicability, even if Hot Shutdown (or a higher mode) is entered during any subsequent heat-up. In particular, the fission product barrier EALs are applicable only to events that initiate in Hot Shutdown or higher. Salem Page 8 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11 -201

8. EAL Technical Bases Organization EAL technical bases are provided for each EAL according to:

o EAL category (R, E, H, S, F and C) o EAL subcategory Figures cited in EAL basis discussions are provided in Attachment 2. EAL defined terms and abbreviations and acronyms are listed in Attachments 3 and 4, respectively. For each EAL, the following information is provided: o EAL Category Letter & Title o EAL SubcategorV Number & Title o Initiating Condition Site-specific description of the generic IC given in NEI 99-01. o Operating Mode Applicability One or more of the following operating modes comprise the conditions to which each EAL is applicable: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, D - Defueled, N/A - Not Applicable or All. For Fission Product Barrier Table bases, Operating Mode Applicability is always Operating Modes 1, 2, 3 and 4. For these EALs, the barrier threat (Loss or Potential Loss) is listed. o EAL# and Classification Level (EAL# & Point Value for Fission Product Barrier Table EAL bases): The EAL number is a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel. Four characters define each EAL identifier: Category R, E, H, C and S EALs: (Example: SU7.1)

1. First character (letter) - Corresponds to the EAL category (R, E, H, C or S)
2. Second character (letter) - Emergency classification level: U for Unusual Event, A for Alert, S for Site Area Emergency, or G for General Emergency.
3. Third character (number): Subcategory nu mber within the given category.

Subcategories are sequentially numbered beginning with the number one (1). Salem Page 9 of 11 Rev. 0 (draft E) Sntroduction

SGS ECG - EAL Technical Bases EP-SC-1 11 -201 If a category does not have a subcategory, this character is assigned the number one (1).

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

Selected EALs in Category H have been designated as "Common Site" events. These events are annotated with the phrase "(Common Site)" immediately following the classification level. Category F Fission Product Barrier EALs: (Example CB4-P)

1. First and second characters (letters) identify the barrier to which the EAL applies.

FB: Fuel Clad Barrier RB: Reactor Coolant Barrier CB: Containment Barrier

2. Third character (number) - Sequential number beginning with the number one (1) for the first threshold in the barrier loss or potential loss of the Fission Product Barrier Table (Attachment 1)
3. Last character (letter) preceded by a dash (-) designates if EAL is for a potential loss or loss of the barrier in question.

P: Potential Loss L: Loss 

   " EAL (enclosed in rectangle)

Exact wording of the EAL as it appears in the EAL wallcharts. o Basis The basis discussion applicable to the EAL taken from NEI 99-01. Salem Page 10 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201 

   " Explanation/Discussion/Definitions Description of the site-specific rationale for the EAL.

o EAL Basis Reference(s) Source documentation from which the EAL is derived. The first reference in each list gives the NEI 99-01 IC and example EAL number. A cross-reference of SGS EALs and NEI 99-01 ICs/EALs is given in Attachment 5.

9. REFERENCES 9.1 NEI 99-01 Revision 5, Methodology for Development of Emergency Action Levels, Final, February 2008 (ADAMS Accession Number of ML080450149) 9.2 NRC Regulatory Issue Summary (RIS) 2003-18, Supplement 2, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels Revision 4, Dated January 2003 (December 12, 2005) (ADAMS Accession Number of ML051450482) 9.3 NRC Regulatory Issue Summary (RIS) 2007-02 Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, Dated February 2007 (ADAMS Accession Number of ML062370311) 9.4 Salem EAL Comparison Matrix - NRC submittal document that defines differences between NEI 99-01, Rev. 05 and PSEG submitted Salem EALs Salem Page 11 of 11 Rev. 0 (draft E)
                                                                      ýntroducUcn

SGS ECG - EAL Technical Bases EP-SC-1 11-202 EVENT CLASSIFICATION GUIDE (ECG) USE NOTE It is expected the Shift Manager (SM) always serves at the Emergency Coordinator (EC) during the initiating event even if the SM is out of the control room. The Control Room Supervisor (CRS) assumes operational command and control responsibility for the shift crew but not as the EC. The CRS should ensure that the SM is immediately called back to the control room on any conditions that require ECG assessment. Only if the SM is not able (sick or hurt) may the CRS serve as the EC.

1. EC Judgment The EALs described in the ECG are not all inclusive and will not identify each and every condition, parameter or event which could lead to an event classification. The following guidance should be used by the EC:

IF an EAL has been exceeded, but satisfaction of the Initiating Condition (IC) is in question, THEN CLASSIFY the event lAW the EAL. IF however, it is clear that the EAL has NOT been exceeded (and will not), THEN DO NOT classify the event. IF an IC has been satisfied, but exceeding the specific EAL is in question, THEN CLASSIFY the event lAW the IC. In any case, IF the plant conditions are equivalent to one of the four emergency classes as described in Section 2 of EP-SC-1 11-201, THEN CLASSIFY the event based on EC discretion lAW EALs in Category H.

2. Assessment Time 2.1 Timeliness Assessment of an Emergency Condition should be completed in a timely manner, which is considered to be within 15 minutes of when events are known or should have been known.

If an EAL specifies a duration time (e.g., loss of annunciators for 15 minutes or longer), the assessment time runs concurrently with the EAL duration time and is the same length. Salem Page 1 of 8 Rev. 0 (draft E) Usage

SGS ECG - EAL Technical Bases EP-SC-111-202 2.2 Duration Time Exceeded If an event is recognized or reported and the required duration time is known to have already been exceeded, the duration portion of the EAL should be considered as being satisfied and the assessment time for the remaining portions of the EAL should be within 15 minutes from the time of -recognition.

3. Implementing Actions The ECG is not a stand-alone document. At times, the ECG will refer the user to other attachments or procedures for accomplishment of specific evolutions such as: Accountability, Recovery, development of PARs, etc.

The ECG should be considered an "Implementing Procedure" and used in accordance with the requirements of a Level 2 - Reference Use procedure as defined in HU-AA-104-101, Procedure Use and Adherence. The ECG classification sections allow for judgment and decision making as to whether or not an EAL is exceeded. 

          /.  -NO'TE Compari                                                       and/orr alarms should be used to confirm actual plant conditions.
4. Classification The primary tools for determining the emergency classification level are the EAL wallcharts.

The user of the EAL wallcharts may (but is not required to) consult the EAL Technical Bases in order to obtain additional information concerning the EALs under classification consideration. To use the EAL wallcharts, follow this sequence:

1. Assess the event and/or plant conditions and determine which EAL Group is most appropriate.
2. Review EAL categories and subcategories on the appropriate wallcharts.
3. For each applicable subcategory, review EALs in the subcategory beginning with the highest emergency classification level to the lowest classification level (left to right).
4. If the HOT conditions wallchart is employed, also review the Fission Product Barrier (FPB) Table (Wallchart sheet 3) as follows:
a. Examine the FPB categories in the left column of the table.
b. Select the category that most likely coincides with event conditions.
c. Review all thresholds in this category for each fission product barrier.
d. For each threshold that is exceeded, identify its point value and determine the classification level in accordance with the instructions on the Fission Product Barrier Table (or in EAL Technical Basis, Attachment 1).

Salem Page 2 of 8 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-202 NOTE The Emergency Coordinator should classify and declare an emergency before an Emergency Action Level (EAL) is exceeded if, in the EC's judgment, it is determined that the EAL will be exceeded within 2 hours

5. REVIEW the associated EALs as compared to the event and SELECT the highest appropriate emergency. If identification of an EAL is questionable refer to paragraph 1 above.

If there is any doubt with regard to assessment of a particular EAL, the ECG EAL Technical Basis Document should be reviewed. Words contained in an EAL that appear in uppercase and bold print (e.g., VALID) are defined at the end of the basis for the EAL. Words or numbers contained in an EAL that are in bold print but not uppercase are EAL threshold values (e.g., >_15 minutes).

6. If an EAL has been exceeded, equal level EALs or lower level EALs are not required to be seperately reported as long as the applicable information is communicated to the NRC using ECG Attachment 5, EP-SC-1 11-F5, NRC Data Sheet Completion Reference.
7. When the Shift Manager (SM) is the Emergency Coordinator, the Shift Technical Advisor (STA) is responsible to perform an independent verification of the EAL classification. The STA verification does not alleviate the requirement of the SM to make a timely classification. Should the SM fill the STA role, independent verification of the EAL classification will be delegated to another on-shift SRO, the Independent Assessor.
8. Identify and implement the referenced ECG form based on the Emergency Classification Level.

o Unusual Event Implement EC-SC-1 11-F1 o Alert Implement EC-SC-1 11-F2 o Site Area Emergency Implement EC-SC-111-F3 o General Emergency Implement EC-SC-1 11-F4 o Unusual Event (Common Site) Implement EC-SC-1 11-F8

9. Continue assessment after classification and attachment initiation, by returning to the EAL wallcharts to review EALs that may result in escalation/de-escalation of the emergency level.

Salem Page 3 of 8 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-202

5. Emergency Short Duration Events
1. A Short Duration emergency event is a transitory event that meets or exceeds one or more EALs for less than 15 minutes (i.e., action is taken and the plant returned to a condition in which no EAL applies). For a Short Duration event the Control Room Staff is aware of the event and realizes that an EAL had been exceeded.
2. Short Duration events that occur will be assessed and emergency classification made, if appropriate, within 15 minutes of control room indications or the receipt of the information, indicating that an EAL has or had been exceeded. This classification is to be made even if no EALs are currently being exceeded (i.e., actions have been taken to stabilize the Plant such that no EALs currently apply).
3. For some events, the condition may be corrected before a declaration has been made.

The key consideration in this situation is to determine whether or not further plant damage occurred while the corrective actions were being taken. In some situations, this can be readily determined, in other situations, further analyses (e.g., coolant radiochemistry sampling, may be necessary). Classify the event as indicated and terminate the emergency.once assessment shows that there were no consequences from the event and other termination criteria are met.

4. Guidance for.classifying transient events addresses the period of time.of event recognition and classification (15 minutes). However, in cases when EAL declaration criteria may be met momentarily during the normal expected response of the plant, declaration requirements should not be considered to be met when the conditions are a part of the designed plant response, or result from appropriate Operator actions.
6. Conditions Discovered After-the-Fact There may be cases in which a plant condition that exceeded an EAL was not recognized at the time of occurrence but is identified well after the condition has occurred (e.g., as a result of routine log or record review), and the condition no longer exists. In these cases, an emergency should not be declared. Reporting requirements of 10 CFR 50.72 are applicable and the guidance of NUREG-1 022, Rev. 2, Section 3, should be applied.
1. An After-the-Fact event is defined as an event that exceeded an EAL threshold and was not recognized at the time of occurrence but is identified greater than 1 hour after the condition has occurred (e.g., as a result of a routine log review, record review, post trip review, engineering evaluation) and the condition no longer exists.
2. For an After-the-Fact event the Control Room Staff was either not aware of the event or did not realize that an EAL was exceeded at the time of the occurrence.
3. Plant emergency events that are in progress or have occurred with ongoing adverse consequences/effects should not be considered After-the-Fact events and should therefore be classified and declared as an ongoing emergency event. I Salem Page 4 of 8 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-202

4. EMERGENCY CONDITIONS - After-the-Fact events that occur will be assessed and evaluated to ensure that no EAL currently applies. An emergency declaration is NOT required and a non-emergency, One-Hour Report should be initiated in accordance with non-emergency RALs in the ECG.
7. NRC Communications During An Emergency Guidance
1. Complete and accurate communications with the NRC Operations Center during emergencies is required.and expected. The purpose of notifying the NRC within one-hour of an emergency, is to provide event information when immediate NRC action may be required to protect the public health and safety OR when the NRC needs accurate and timely information to respond to heightened public concern. If the information we provide is not accurate or does not contain sufficient detail, then we hamper the NRC from doing their job.
2. The NRC Data Sheet, along with the Initial Contact Message Form, is the primary vehicle to ensure the NRC is kept informed. General Guidance on completing the event description portion of the NRC Data Sheet is provided in the NRC Data Sheet (ECG Attachment 5).
8. Event Retraction Guidance IF an ENS notification to the NRC was made as directed by the applicable ECG Attachment AND it is later determined that the event or condition is not reportable, THEN the notification may be retracted as follows:
1. OBTAIN both the Operations Shift Manager's and Shift Manager's approval of any proposed retractions. Ensure Reg Assurance is consulted prior to approval to retract an Event.
2. COMPLETE "page 1" of ECG Attachment, EP-SC-1 11 -F5, NRC Datasheet Completion Reference, providing a retraction of the original notification. Event Description Section of NRC Data Sheet should explain the rationale for the retraction.
3. NOTIFY the NRC Operations Center and NRC Resident Inspector.
4. RECORD on the "NRC Data Sheet" the name of the NRC contact that received the retraction information.
5. FORWARD the retraction "NRC Data Sheet" with the rest of the original attachment of the ECG that was implemented when the original notification was made to the Operations Shift Manager.

Salem Page 5 of 8 Rev. 0 (draft E) 

                                                                                       .Usag)(

SGS ECG - EAL Technical Bases EP-SC-1 11-202

9. Common Site Events Guidance
1. Selected EALs in Category H (Unusual Event level only) have been designated as "Common Site" events. These events will be annotated with the words "Common Site" just below the mode applicability line in the wallcharts and next to the classification level in the EAL Bases document.
2. The Common Site UE ECG Attachment 8, EP-SC-111-F8, Declaration of "Common Site" UE, will direct the SM to establish agreement on which SM will declare and report the event. Therefore, either Salem or Hope Creek will report Common Site Unusual Events; but not both.
3. Events classified at an Alert or higher level require plant specific information to be provided to the states of New Jersey and Delaware, the NRC, and to PSEG Emergency Response Facilities and therefore will not be classified as common site events.
10. EAL Classification Considerations
1. Planned evolutions involve preplanning to address the limitations imposed by the condition, the performance of required surveillance testing, and the implementation of specific controls prior to knowingly entering the condition in accordance with the specific requirements of the SGS Technical Specifications. Activities which cause the site to operate beyond that allowed by the SGS Technical Specifications, planned or unplanned, may result in an EAL threshold being met or exceeded. Planned evolutions to test, manipulate, repair, perform maintenance or modifications to systems and equipment that result in an EAL value being met or exceeded are not subject to classification and activation requirements as long as the evolution proceeds as planned and is within the operational limitations imposed by the specific operating license. However, these conditions may be subject to the reporting requirements of 10 CFR 50.72.
2. All classifications are to be based upon VALID indications, reports or conditions.

Indications, reports or conditions are considered VALID when they are verified by (1) an instrument channel check, or (2) indications on related or redundant indications, or (3) by direct observation by plant personnel, such that doubt related to the indication's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment.

3. Although the majority of the EALs provide very specific thresholds, the Emergency Coordinator must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is IMMINENT. If, in the judgment of the Emergency Coordinator, an IMMINENT situation is at hand, the classification should be made as if the threshold has been exceeded. While this is particularly prudent at the higher emergency classification levels (as the early classification may provide for more effective implementation of protective measures), it is nonetheless applicable to all emergency classification levels.

Salem Page 6 of 8 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-202

4. When multiple simultaneous events occur, the emergency classification level is based on the highest EAL reached. For example, two Alerts remain in the Alert category. Or, an Alert and a Site Area Emergency is a Site Area Emergency. Further guidance is provided in RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events.
5. Another important aspect of usable EAL guidance is the consideration of what to do when the risk posed by an emergency is clearly decreasing. A combination approach involving recovery from General Emergencies and some Site Area Emergencies and termination from Unusual Events, Alerts, and certain Site Area Emergencies causing no long term plant damage appears to be the best choice. Downgrading to lower emergency classification levels adds notifications but may have merit under certain circumstances. Refer to procedure NC.EP-EP.ZZ-0405, Emergency Termination -

Reduction - Recovery, for detailed directions.

6. The logic used for the Fission Product Barrier EALs reflects the following considerations:
            " The Fuel Clad Barrier and the RCS Barrier are weighted more heavily than the Primary Containment Barrier. Unusual Events associated with RCS and Fuel Clad Barriers are addressed under EALs in Category S, System Malfunctions.

o The ability to escalate to higher emergency classification levels as an event deteriorates must be maintained. For example, RCS leakage steadily increasing would represent an increasing risk to public health and safety. o The Primary Containment Barrier should not be declared lost or potentially lost based on exceeding Technical Specification action statement criteria, unless there is an event in progress requiring mitigation by the Primary Containment barrier. When no event is in progress (Loss or Potential Loss of either Fuel Clad and/or RCS barrier) the Primary Containment Barrier status is addressed by Technical Specifications.

7. Since Salem is a multi-unit station with shared safety-related system and functions, emergency classification level upgrading must also consider the effects of a loss of a common system on more than one unit (e.g., potential for radioactive release from more than one core). For example, the control panels for both units in close proximity within the same room. Thus, Control Room evacuation most likely would affect both units. There are a number of other systems and functions which may be shared. This must be considered in the emergency classification level declaration.
8. SGS and HCGS share a common ISFSI. Classification of events related to spent fuel stored at the ISFSI appear only in the HCGS EAL scheme. Classification of events related to the transfer of spent fuel from SGS to the ISFSI are addressed in the SGS EAL scheme (EAL EU1.1).

Salem Page 7 of 8 Rev. 0 (draft E) IUsage

SGS ECG - EAL Technical Bases EP-SC-1 11-202 This page intentionally blank Salem Page 8 of 8 Rev. 0 (draft E) usage

EALs for: Abnormal Radioloogical Leve s YESFSI-

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 2 times the ODCM for 60 minutes or longer Mode Applicability: All EAL# & Classification Level: RUI.1 - UNUSUAL EVENT EAL: VALID gaseous monitor reading > Table R-1 column "UE" AND > 60 minutes have elapsed (Note 2) Note 2: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown. Salem Page 1 of 6 Rev. 0 (draft E) EAL#:RUI.]

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Table R-1 Effluent Monitor Classification Thresholds* Release Point Monitor GE SAE ALERT UE u* Plant Vent 1R41D +2R41D ooa Effluent EPetolom Noble OR 8.48E+09 pCi/sec 8.48E+08 pCi/sec 4.84E+07 pCilsec 4.84E+05 pCi/sec 

         ~ GasSPDS combined Unit 1 + Unit 2                         release rate Containment Fan Coil                                 1(2)R13A/B                               ----                                       1.64E+05 cpm             1.64E+03 cpm Process Liquid                                           1R18                                                                                               UI= 5.50E+05 cpm Radwaste                                                                                                                           N/A-

-0 Disposal See EAL RA1.3 'S Process 2R18 U2= 9.90E+05 cpm Steam 1R19A-D UI= 6.40E+05 cpm U1= 6.40E+03 cpm Generator Blowdown Process 2R19A-D U2= 8.30E+05 cpm U2= 8.30E+03 cpm Non-Rad Liquid 2R37 .... 3.60E+05 cpm 3.60E+03 cpm Waste

  • For high radiation conditions on Letdown Line Monitor 1R31A (2R31), refer to EAL SU7.1 Basis:

A*;,A m r -- ... W - --.r I- r7 L , , ~.. t .' ..- ,.' .* . - The Emergency Director rCoodinator should not wait until the appliable time has elapsed, but should declare the event as soon as it is determined th-at the Condition will likel This 4G-EAL addresses a potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. [These c-entr-..s ar- loc-ate in the Off site Dosa CalculatiOn Manual (CD C4), and for plants that have notim3pleetqed Generic-Letter-80-01, in the Radiological Eff'uent Tec6hn~ical Speifc'hat'cnS (RFTS).j The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls..[Some sites m..ay.find it adv.ntage.us to add.es. 

      ,*,*r,.,* ,,   *   -] I;,' , ;,-J          _I -     __* -   .,;4.l-    __     ..         r-.
  • A I - "I e- LII~~~~~~

1 

                                  .1L. III-j L.IllLL      . VY  ILI                 L  L  "i. I. jJ i".LXQL The threshold values that equates to a RE-T-S-multiple of two times the ODCM limits are-is specified in AU-1-EAL RU1.1 and ,*A, P-,                                                       only to distinguish between non-emergency conditions, and from each other. While t-hese-this multiples obviously corresponds to an off-site dose or dose rate, the emphasis in classifying these this events is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate.

Salem Page 2 of 6 Rev. 0 (draft E) EAL#: rlU I.i

SGS ECG - EAL Technical Bases EP-SC-1 11-203 [Relea* 

          .. e .,qt he,,d     be p,*,ated er av.*r-ag.d. Forexam..ple, a      .....e .... c ding 4x ODCM4 forc 30 miputes dooc Rot meet the thr-esholdl.]

This EAL i*ncldes anY release for'"hich a radieaGtivity discharge periit Was not prepared, or a %lecase that exceeds the conditionS (e.g.,' m~inimum-- dilution flowN, maximum discharge flow, alarm setpoin~ts, etc.) on the applicablc permit. 

   -  EAL #1 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in the 1GEAL.

This EAL is intended for sites that have established effluent monitoring on non-routine release pathways for which a discharge permit would not normally be prepared. Salem Page 3 of 6 Rev. 0 (draft E) EAL#: RU1.J31J

SGS ECG - EAL Technical Bases EP-SC-1 11-203 [The ODCM establishes 

                         ,    .      aP......:   eo gy for determ....g
                                                                 .     ..*pj.a.la..
                                                                              ;            .. 'n..ito,'

shThe ODGAI7 s d squr-cn v,,, a.n, for ga;eous r-eleae p the use of proe determi;;ed apt7Hp! avcrage meteer-olgyl ie the meost A4rniti:g di4t31n4d Sector fpr 

,9how'4g G9MP!:anC    ccWith the re gUlatory comtet.This              EAL 8houwld be deteRrnPed uein9 EAL #2 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to oxceed the threshold identified in the 1C established by the radioactivity discharge permit. This value may be associated with a planned batch release, or-a continuou6s rolcase path.

[in eithe- ca-se, the value is 9tabvihed,by the .D.M to warn. of a reie.e that is not9. com.plian.e wi4 the RETS. !nd-exing the EAL to the CDC, setp9ts in th... Man.er.. I..UrE. tha-t the &4L wi!! npever be less than the setpoint establisheeedby a &Pecif4cdisoa cage pcRm*t.] EAL #3 This EAL addresses Unc"ntro l-ed r.l.ases that are detected by sample analyses, particu1larly onR unmonitoroed pathways, e.g., spills of radio~actiVe liquids into storm drains, heat exchanger leakage in river Water systems, etc.: EALs #1 and #-5 The ).101QmR/hr value in EAL #4, and the Site specific value for EAL #^5,is based on a-release rate not exceeding 50C) mrcmpe year. [A.. priq*ded in the 9 44,1/RETS, prorated Gv. .r 8766 h cur., mqu.tipled by two., aped rounded, (500,q 8766 ;,- 0.1 14.] EAL #1 a*d #2 directly corFrelate with the IC since annual average meteorolo.gy is required to be Used in ShG'A'ing compliance with the ODCM and is used in calu*latiRng the alarm. setpoints. EALs #4 and #5 are a function of actual meteorology, which will likely be The underlying basis of this EAL inVol'VeS the degradatio~n in the lovel of safety of the plant implied by the uncontrolled release. Exceeding EAL #4 9Fr, 5 is an indicatie*

  • f an uncontrolIled release.

Explanation/Discussion/Definitions: The column "UE' gaseous release value in Table R-1 (Unit 1 + Unit 2) represents two times the associated effluent monitor alarm setpoint. This setpoint is set to preclude exceeding the ODCM release rate limits associated with the specified monitor. Salem Page 4 of 6 Rev. 0 (draft E) EAL#: RUi A

SGS ECG - EAL Technical Bases EP-SC-1 11-203 The plant vent monitors (R41) sample and detect noble gases and collect samples of particulates and iodine discharge through the plant vent. Channel D (R41 D) provides the gaseous effluent release rate (pCi/sec) by combining (product of) the on-range R41 A through R41 C with plant vent flow (cc/sec). Definitions: VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s): 1, NEI 99-01 Rev. 5, AGI Example EAL #1 2, Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6) 3, FSAR Section 11.4 Radiological Monitoring 4, PSBP 315733(4) Radiation Monitoring System Control Manual Salem Page 5 of 6 Rev. 0 (draft E) EAL#: RU ]. 1I

SGS ECG - EAL Technical Bases EP-SC-1 11-203 This page intentionally blank Salem Page 6 of 6 Rev. 0 (draft E) EAL#: RUMo

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 2 times the ODCM for 60 minutes or longer EAL# & Classification Level: RU1.2 - UNUSUAL EVENT Mode Applicability: All EAL: ANY VALID liquid monitor reading > Table R-1 column "UE" AND a 60 minutes have elapsed (Note 2) Note 2: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown. Salem Page 1 of 6 Rev. 0 (draft E) EAL#: RU1* o2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Table R-1 Effluent Monitor Classification Thresholds* - _ Release Point Monitor GE SAE ALERT UE v Plant Vent 1 R41 D + 2R41 D 0 Effluent EPetoloRNoble Gas OR 8.48E+09 pCi/sec 8.48E+08 pCi/sec 4.84E+07 pCi/sec 4.84E+05 pCi/sec ui GasSPIDS combined Unit 1 + Unit 2 release rate Containment Fan Coil 1(2)R13A/B ---- 1.64E+05.cpm 1.64E+03 cpm Process Liquid 1R18 U 1= 5.50E+05 cpm IRa dwa ste N/A -0 Disposal See EAL RAI.3 

' Process                               2R18                                                                                                             U2= 9.90E+05 cpm

-J Steam 1R19A-D U1= 6.40E+05 cpm U1= 6.40E+03 cpm Generator Blowdown Process 2R19A-D U2= 8.30E+05 cpm U2= 8.30E+03 cpm Non-Rad Liquid 2R37 ---- 3.60E+05 cpm 3.60E+03 cpm Waste

  • For high radiation conditions on Letdown Line Monitor 1 R31A (2R31), refer to EAL SU7.1 Basis:

HHt--Huld L=00it"Utul t7UUIU'___' ____ UUL w. HuILH Hi' Opp UcitwC~u H111 i - 

 ýJIn   L-n     k  + ckr~ 1IA r4                 r~ + ke      c~-f +~~~er
                                                              %                          -.4-PmmnPH thp iniri!                        timnQ This IfEAL addresses a potential decrease in the level of safety of the plant as indicated by a radiol6-gical relea-s6e-- tha-tex6e-eds regulatory comfrIitmehts f&r an ext fided period -6f timne.

Nuclear power plants incorporate features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. [These co.ntrols are l,-oate in the Off site Dose Calculatjion Manual (OD04M), and for plants that have not implpem~et C'e arirI Letcter 39- 9~1, f the Radiologica! Effluent Tec-hnical Specifications (REVTi9/.j The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls.[Some sites may, find it advantageous to addess gaseous and liquid releases v,,44 separ-at E, Ls.] The threshold values that equate to a RET-S multiple of two times the ODCM limits apr isare specified in AUI--EAL RU1.2 aRd AA! R only to distinguish between non-emergency conditions, and from each other. While these-this multiples obviously corresponds to an off-site dose or dose rate, the emphasis in classifying these-this events is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate. V'a~~~~~~~ a' a f'.LTaTa1 A' 1YA7WCrV u?ýr CtW') M C& LA. i I - -t I'aza~ ff' - LA 

£t171L2Ad    fnr~ Qnf         *;ptin.       -'r~pn  pI-,* ý^_       i        f        I-,k~rb4 Salem                                                                           Page 2 of 6                                                         Rev. 0 (draft E)

EAL#: t t .22U

SGS ECG - EAL Technical Bases EP-SC-1 11-203 This ELA iRnc-Ides any release for which a radi*aGtiv;ty diScharge permit was not pr.epaed, or a releas. that exceedS the conditions (e.g., minimum dilution f!ow, maximum ds,-harg.flow, a.arm s.tpoiRS, etc.) on the applicable permit. EAL 21 This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in the fGEAL. This EAL is intended for sites that have established effluent monitoring on non-routine liquid release pathways for which a discharge permit would not normally be prepared (Containment Fan Coil, SG Blowdown & Chemical Waste Basin) as well as planned batch releases for which a radioactivity discharqe permit is prepared (Liquid Radwaste Disposal). Salem Page 3 of 6 Rev. 0 (draft E) EAL#: RUI] .2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 [iThe QDCM4 ectablishes a e thodololgy ýfo determPining effluant r-adig mone-hte-setpoints. Th4e CD CM cpecifies defaultcsurGe teRmee nde, for gaseu releas, pprs-~e useof i-edeermi;l arjc ai avt~g meor-olog in th ryPrvc' Iirrithiry d--,,AIPW44 Se~t EAL #2 This EAL addresses radioactiity releases, that for whatever reason, cause effluent radiation moni'tor readings to exbced the threshold- identifiled in the IC established by the radioacti-Vity diScharge permit. This- value may be associated With a plahned batch release, o'F a continuous release path.,. . [In1 r or ae, the ý!Ue ithF a i, establihed by the ODChM te warn o*f areleas that is not in c cc with the RETS. Indexing the EAL to the QDO- 4 sctpi*t*, Tmphian in this m4aner ic. urem tha4-t the EAL will! never-be less than the Setpointectab4ichcd bya &pecificdisc;halrge pecrrn'.] EAL #f3 This EAL addresses uncon-trolled releases that arc detected by sample analyses, pa~tcUlarly on unmonitored pathways, e.g., spills of radio~acti've liquids intoD storm drains, heat exc'h-anger 

        ""      leakage       river water systems, etc.

EpALs ai ands snn5 The 0.10 mU'iudhr value in EAL #4, and the site specific value for tieis EAL based on a release rate net eXceeding 500 mrem per year. [As provided in the ODOM,' PET-S, perorated over- 8766 hour-s, m~uitiplied bY two, and r-ounded. (500 8766 ;, .114)-. EAL #1 and # directly c2 correlate with the IC since annual average meteorelogy is required to be used in showing compliance with the ODCMI and iSUsed in calculating the-alarm setpoints. EALs obtaind fro#5 are aauctionsof atual meteoroelgy, which will likely bee different from the limiting annual average value. Thus, there will likely be a banuericl inconsistency4. The underlying basis of this EAL involves the degradation in the level of safety of the plant implied by the uncontrolled release. Exceeding EAL #41or #5 is an indication of an unconRtrolled release. Explanation/Discussion/Definitions: The column "UE" liquid release values in Table R-1 represent two (2) times the High Alarm setpoints ( except 2R1 8 which is 1.5 times) associated with the specified monitors. The High Alarm setpoints are obtained from channel calibrations procedures as listed in the reference section of this bases. Salem Page 4 of 6 Rev. 0 (draft E) EAL#:RUi.2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Instrumentation that may be used to assess this EAL is listed below: o Containment Fan Coil Process 1(2)R13A/B (Upper Range is 1.OOE+06 cpm) Service water is used as the cooling medium for the containment fan coil units (CFCUs) and could be contaminated if the cooling coil leaks with containment pressure above Service Water pressure. Since the Service Water System discharges into Circ Water and then back to the river, the fan cooler units will be indirectly monitored for radioactivity. This is done through the use of two monitors for the five fan coolers. The two monitors sample two of the three Circ Water headers that contain Service Water used to cool the CFCUs just before it discharges back to the river. Alarms on these monitors would be indicative of a CFCU leak but could also be associated with other systems including from the pathways monitored by the R1 8s, R1 9s and the R37, which also discharge into Circ Water and are monitored by the 1(2)R13A/B. If simultaneous Rad Alarms are received on an R1 3 monitor along with any R1 8s, R1 9s or R37 monitor, then the source of the Rad effluent may not be a CFCU leak and further investigation would be warranted. However, exceeding the EAL threshold value for > 60 minutes should result in Unusual Event classification even if the exact source remains questionable. Liquid Radwaste Disposal Process 1(2)R18 (Upper Range is 1.OOE+06 cpm) This channel continuously monitors all Waste Disposal System liquid releases from the plant. Automatic valve closure action is initiated by this monitor when a high radiation level is indicated and alarmed in the Control Room. Liquid Radwaste discharges to Circ Water which then discharges to the Delaware River. This Unit 1 EAL threshold is based on 2 times the High Alarm Set Point as defined in the Channel Calibration procedure. This Unit 2 EAL threshold is based on a value that is approximately 1.5 times the High Alarm Set Point as defined in the Channel Calibration procedure which ensures that the threshold value is within the upper range of the monitor. Since the ranges of the 1(2) R18s monitors do not support EAL threshold values of 200 times the high alarm value, no Alert threshold is provided on Table R-1. If the release pathway could not be isolated as expected, the EC should refer to EAL RA1.3 for Alert threshold values based on sample analysis. o Steam Generator Blowdown Process 1(2)R19A-D (Upper Range is 1.00E+06 cpm) Each of these channels (four channels per unit) monitors the liquid phase of the steam generators for radioactivity, which would indicate a primary-to-secondary system leak. The four steam generator blowdown sample lines each have a radiation monitor. A high radiation alarm signal will close the No. 12 (22) steam generator blowdown tank inlet Salem Page 5 of 6 Rev. 0 (draft E) EAL#:RUI.2

SGS ECG - EAL Technical Bases EP-SC-111-203 valves and the steam generator blowdown isolation valves on the affected steam generator. 0 Non-Rad Liquid Waste 2R37 (Upper Range is 1.OOE+06 cpm) The non-radwaste basin provides a potential release path due to the fact that steam generator blowdown is directed to the basin during plant startup. This monitor provides for continuous monitoring of the discharge from the non-radwaste basin. Non-Rad Liquid Waste discharges to Circ Water which then discharges to the Delaware River. Definitions: VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AU1 Example EAL #2
2. Salem ODCM Section 3.3.8 - Radioactive Liquid Effluent Monitoring Instrumentation
3. Salem ODCM Figures 1-1 and 1-2, Liquid Release Flow paths for Unit 1 and Unit 2
4. UFSAR Section 11.4 Radiation Monitoring
5. PSBP 315733(4) Radiation Monitoring System Control Manual
6. 51($2).IC-CC.RM-0097/98, Channel Cal for 1/2R13A/B
7. S1(S2).IC-CC.RM-0028, Channel Cal for 1/2R18
8. S1(S2).IC-CC.RM-0029/30/31/32, Channel Cal for 1/2R19A/B/C/D
9. S2.IC-CC.RM-0060, Channel Cal for 2R37 Salem Page 6 of 6 Rev. 0 (draft E)

EAL#:RUI.UJ 2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 2 times the ODCM for 60 minutes or longer EAL# & Classification Level: RU1.3 - UNUSUAL EVENT Mode Applicability: All EAL: Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > Table R-2 column "UE" AND 

> 60 minutes have elapsed (Note 2)

Note 2: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown. Table R-2 Effluent Sample Classification Thresholds i Release Point Sample ALERT UE NG 6.40E-01 pCi/cc 6.40E-03 pCi/cc Plant Vent 0 1-131 5.60E-05 kCi/cc 5.60E-07 ILCi/cc In Unmonitored Isotopic 200 x ODCM 3/4.11.2 2 x ODCM 3/4.11.2 Containment Fan Coil Isotopic 200 x ODCM 3/4.11.1 2 x ODCM 3/4.11.1 

          -2  Liquid Radwaste Disposal       Isotopic    200 x ODCM 3/4.11.1        2 x ODCM 3/4.11.1
          ."  Steam Generator Blowdown       Isotopic    200 x ODCM 3/4.11.1        2 x ODCM 3/4.11.1 Chemical Waste Basin            Isotopic   200 x 0DCM 3/4.11.1        2 x ODCM 3/4.11.1 Unmonitored                     Isotopic   200 x ODCM 3/4.11.1        2 x ODCM 3/4.11.1 Salem                                              Page 1 of 5                                    Rev. 0 (draft E)

EAL#: R U 1. 3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Basis: [Refr t Apendx Afor-a detailed basis of the Fadiologica!efflu9nt 1C/EAL8.j The Emergency Coord;,atorF shoUld not Wait Until the applicable time has elapsed, but shoul!d declare the evenG;t as soon as it is detePrmined that the condition Will likely exceedth This IGEAL addresses a potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. [Tr-ese . eo tro,- a.e ,oated np the Off site Dose C~alculation Manual (OD0CM), and for plants that have n~et irnple~rpet~ Gen .e.. Lette/r 89 0, in the Radliological Effluent T-eh-*n*al Specifi"atio.n (RETS).j The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls .[Sr.e.tes m.ay. find it to add.-Fs gaseGouc aRGd"'qud releases with coparato EA L&.] The RET-S-multiple of two times the ODCM limits are-is specified in Awl and MA EAL RU1.3 only to distinguish between non-emergency conditions, and frem each othe . While these-this multiples obviously corresponds to an off-site dose or dose rate, the emphasis in classifying these-this events is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate. [Releases should n~ot be pl-roatel br-averaged. For- example, a irale'ase 6exoedi.T 4x-0CM4 for 30 ;inutec dOes pot Pqet the thr*e*4cho This EAL includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit for > 60 minutes. EAL #4 Thi~s EAL addresses radioactiVity' releases, that for whatever reasonR, cause- effluent radiation mo-ntor readin-g to eXeed the threshold iderntified in the IQ. This EAL is intended for sites that have established effluent mon~itoring on nonroutine releas pathWaysG for wAhich a discharge permit woul1d not nrmFRally be9 prepared. [The Q,9044 ectabhcheso a ,m"hbdology for, d*otrmf;,,ng effluent r-ad4;ation m.onit)r eýtpoi,'t; The 0DGMcspc~iocs dlefault sqOurce teRmcs andL, for-gaseousrelea ces p rnsr~bes the -uceo~f proG deterinqied annual aver-age meteqFroiogy in the mGct limtinRg downwind cectqr-frý cqhoqwing compliance'_ with the regulator oq....,-m Ths EL shqoud be deteto;I ";,Rng ÷ghig t EAL #2 Salem Page 2 of 5 Rev. 0 (draft E) EAL#: IFU%]3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 This EAL add.resses radioactivity releases, that farrWhteVed s a ses particr monr readings th eXceed "he threshold identiotd in thc established by the radioactiity diSecharge peFaMt. ThiS value may be associated With a plaened batch release, or a cont;RInus releaSG path. [In either Gase. the v'a"u is e stablihed by the 00CM4 to wtarnf of a r-eieasq that is noat in com~pliancea with4 the, a ET'S. Indexin3g the EA4L t9 the ODOM.setpointLa : thic manneri Rneuroc tha thes EAL wi!! never be laes than the satpoint oetab~iiheud by a spe cnific disnhat-ge p arm it.1 E=A L +#3 This EAL addresses uncontrolled releases that are detected by sample analyses, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc. EALs 24, and #5§ The 0.10 mR/hr value in E;AL #4A,--nd the Site specific Valu" fGr EAL #5,i 5,s as. n a r e6e-rat-3 not eYceeding 500 mRem per year.7 [As prov',ided i3 the 900C , RETS, pot.ated ver. 8766 -hurs, mFUli4p*l* by two, aind ro.....ed. (500: 8766 ,72 - 0. 11 ). EAL #1 and #2 dir-etly correlat* *ith th3e l0 since annrual average m,,eteoro.ogy is requirFed to b used in ShowiRg compli;nce With the 00CM aRd is used in calc;ulating the -a1am setp.ints. EALs #4 and #5 arc 8 function of actUal mre,*.teorology, which Will likely be different .fRm thC- liit;in, a.- avernage valule. Thus, there will likely be a numerical inconsistency. The u.derlyi.g basis of this EAL involveS the degradation in the level 9f safety -f the plant implied by .... ................ .. . EAL #4 r #5 is a indication of an ur;conltro14ý r-e-a-se Explanation/Discussion/Definitions: Releases in excess of two times the site Offsite Dose Calculation Manual (ODCM) Section 3/4.11.1 or 3/4.11.2 limits that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the UNUSUAL EVENT emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes. Table R-2 provides calculated radiological release noble gas and iodine sample concentrations that equate to a release that is 2 times the ODCM limit (Section 3/4.11.2) of 500 mRem/year as well as specifying liquid release effluent sample streams 2 times the ODCM limits (Section 3/4.11.1). Each Salem unit has a single gaseous release point (Plant Vent) for which a sample concentration threshold has been calculated. Salem Page 3 of 5 Rev. 0 (draft E) EAL#: RU ,.3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AU1 Example EAL #3
2. Off-Site Dose Calculation Manual, Section 3/4.11.1 - Liquid Effluents
3. Off-Site Dose Calculation Manual, Section 3/4.11.2 - Gaseous Effluents
4. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)

Salem Page 4 of 5 Rev. 0 (draft E) EAL#:RU] 3

SGS ECG - EAL Technical Bases EP-SC-111-203 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#:RUIo3

SGS ECG - EAL Technical Bases EP-SC-111-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 200 times the ODCM for 15 minutes or longer Mode Applicability: All EAL# & Classification Level: RAI.1 -ALERT EAL: VALID gaseous monitor reading > Table R-1 column "ALERT" AND _ 15 minutes have elapsed (Note 2) Note 2: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown. Salem Page 1 of 6 Rev. 0 (draft E) EAL#: R A]o

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Table R-1 Effluent Monitor Classification Thresholds* Release Point Monitor GE SAE ALERT UE v) PlantVent 1R41D+2R41D o Effluent Noble OR 8.48E+09 pCi/sec 8.48E+08 pCi/sec 4.84E+07 pCi/sec 4.84E+05 pCi/sec Gas SPDS combined 0 Unit 1 + Unit 2 release rate Containment Fan Coil 1(2)R13A/B 1.64E+05 cpm 1.64E+03 cpm Process Liquid 1R18 UI= 5.50E+05 cpm Radwaste N/A -o Disposal See EAL RA1.3 Process 2R18 U2= 9.90E+05 cpm Steam 1R19A-D U1= 6.40E+05 cpm U1= 6.40E+03 cpm Generator Blowdown Process 2R19A-D U2= 8.30E+05 cpm U2= 8.30E+03 cpm Non-Rad Liquid 2R37 3.60E+05 cpm 3.60E+03 cpm Waste For high radiation conditions on Letdown Line Monitor 1R31A (2R31), refer to EAL SU7.1 Basis: [Refer to Appcn~di A for a detailod basis 9f the r~adiologioa! efifluent /C',AL&.] I iL.IrLA)~ iIU . r'LA n L Ikri LA LLA; Itoi nkn Ii IiiLA'LAnL deI nr, lJLvt~L 1I.I-r~t~~~~t~T fh -LA o AT iLA Li I L 

                                                                                                                                                                                              -jSL       I hrýj     rIr AAALIAL             h            JAH iLV.I~iiAiiIAiI               '     xP           +e         A ALLLII111+     ,nF      IAL    k,   i.L   kr'-r, iLIA  LIIAIInl             I [pIppppA+~Ii..1L tiyL~LILL     FaI            I appliGable time-This IGEAL addresses an actual or substantial potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time.

Nuclear power plants incorporate features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. [Trese . onto.,- aro located 

'P' the;i ff" *,it          fl Cni ;,4; e                                       i a*l4;,,,oI    Cff,,, -r .,-',,              fra,              t
  • h"*. .ve;. (rr ETS)

Gonor4G Letter-89 01, in the Radioi.gioa.. Eff4......t T.hn... SPecifi.ationS (RETS.).. The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls. r c, ;4-- ýr-j 4 4- _ Ili,. I;.... ;I4 I--/- - - . _...;.41-L -A LI I -L I I I _'Y IL I' LII ILLI ULALAL.ILi LLi LALALAI LiLiLA ULALALiLiLALALIILA II L$L4ILAILAILAL.iLiLiLA V liLIl The threshold values that equates to a RE-TS-multiple of two hundred times the ODCM limits ape-is specified in AU! RU! and AA! EAL RA1.1 only to distinguish between non-emergency conditions, and from each other. While these-this multiples obviously corresponds to an off-Salem Page 2 of 6 Rev. 0 (draft E) EAL#: IRA1. 1

SGS ECG - EAL Technical Bases EP-SC-1 11-203 site dose or dose rate, the emphasis in classifying these-this events is the degradation. in the level of safety of the plant, not the magnitude of the associated dose-or dose rate. [To nre*,-

  • lfie ,r I;r f* lc-.,at'ir ph, a value should-be se,**etd roug4ly half way,between the A U! value andl the value Ga~c-ulated for, Si value. ThPvle wil! be basedt* p radiaton ne t;e-adings to exV:Heed 200 tim c the Teeh.!iea/ Specnif4G*- c.n I;,t and releases are net temin7ýated within 15 rnqitutes. The CD CM establishes a Methodology fo determining effluent radiation monitot hatpoe e ts. The eDfle spemnitoesde fault nn-outinetremls and, for,gaseoGus re/cases, pr-e~senb c the use of proe determ~ined anniual aver-age mepteoroGlogy an the Mest / M't4'g dqKPKg'u7 8entqr for showing eoqmp~~e~ wih the~ r-egalateral Geo~mmtments.

This EAL Gan be do term/nond using this~ methodo/ogy,if approepriate.] [Re/ea ses should npot be pror-atedoer-averaged. For, example, arFe eaSE cc ~"'ding6 0 QDCMU fo-r 5 miputes doees noet meet the threshold.] EAL includes any release for wlhich a radio~actiVity diScharge permit was nol Thi ... prepared, or a release that exceeds the conditionS (e.g., minimum dilution flew, maXimumF discharge flow, alarm setpo~intS, etc.) on the applicable Permit. -This EAL is intended for sites that have established effluent monitoring on non-routine release pathways for which a discharge permit would not normally be prepared. EA.L #2.- This EAL addresses redioacti '.ity releases, that for whaqtever reaqson, cause effluent radiation monitor readinRgs to exceed the threshold idenptified in the IC establ_ýished by tPhe rad oce~tivity.discharPge permit. This. value m~ay be associated. with a planned batch release, oF a continuoups release path. -.. [in ithe a., the A s a isa by th QDC44 to Gf ar Ialal 

                                                                                                                                   'eleaale     a-s noS ceompian~e             wit~h the RES            436dasK-ia       the   EA     te the-     a-DC4     isetpaaa 4 3ts ina M'apper-a1/4,iaa         Iaaa&.re th t-PE                 nevr,il   be Ic' Ls     n  than    LIa th    seto    ,#nt     stabfs esA  n     anl he   a.

by, c' sp1ii m dis cha 4 aasa-a n-,va rg EAL #3 This,E=AL addresseqs uRGcontro led releases that are detected by sample analyses, pa~tcularly ohunoitor~ed pathways, e.g., spills of radioactive liquids into) stor.m drains, heat exchanger leakage in river water systems, etc-. EALs #1 and #5 The 10_0 mR'Jhr value in EAL #4 a and the site specific value forp EAL #5,;s based onea release rate not -exceeding 500 mrem per year. Salem Page 3 of 6 Rev. 0 (draft E) EAL#: RAI. I

SGS ECG - EAL Technical Bases EP-SC-111-203 [As pr... ded in the M, ,RE=TS, pr-.rated over 8766 h ... , mutip/l;d, 29900, and ,-u,,nded. (500 .- 8*766 200 - 14 4.11 EAL #1 and #E2dircctlyoureloate with the IC SiRc annual average + ni toereoegy is reqhured to be used in cheWing eompliaune Witha the Carmson and is used is calculatirg the alaFFimSetpeintS. E=AL~s #4 and #5 are a function of actual m~eteorologY, which will likely be different fGom the limiting annual average value, Thus, there wil likely be a mnumeital

neenSiSteney-.

The aderlint g baisoftohis EAL involes the degradation in the nlevel of safetm of the plan implied by the uodinetrioedhrelease. EXgeeding.p EAn1t or han5 is aR41idication ovfa uncon~trollod rolcasc.Explanation/Discussion/Definitions: The column 'ALERT" gaseous release value in Table R-1 (Unit 1 + Unit 2) represents two hundred times the associated effluent monitor alarm setpoint. This setpoint is set to preclude exceeding the ODCM release rate limits associated with the specified monitor. The plant vent monitors (R.41) sample and detect noble gases and collect samples of particulates and iodine discharge through the plant vent. Channel D (R41 D) provides the gaseous effluent release rate (pCi/sec) by combining (product of) the on-range R41A through R41 C with plant vent flow (cc/sec). Definitions: VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AA1 Example EAL #1
2. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)
3. UFSAR Section 11.4 Radiological Monitoring
4. PSBP 315733(4) Radiation Monitoring System Control Manual Salem Page 4 of 6 Rev. 0 (draft E)

EAL#: RAIi

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Salem Page 5 of 6 Rev. 0 (draft E) EAL#: RA I,0

SGS ECG - EAL Technical Bases EP-SC-I 11-203 This page intentionally blank Salem Page 6 of 6 Rev. 0 (draft E) EAL#:RAIA

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 200 times the ODCM for 15 minutes or longer EAL# & Classification Level: RA1.2 - ALERT Mode Applicability: All EAL: ANY VALID liquid monitor reading > Table R-1 column "ALERT" AND > 15 minutes have elapsed (Note 2) Note 2: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown. Salem Page 1 of 5 Rev. 0 (draft E) EAL#: RAI] .2

SGS ECG - EAL Technical Bases EP-SC-111-203 Table R"1 Effluent Monitor Classification Thresholds* Release Point Monitor GE SAE ALERT UE o Plant Vent 0Effluent Noble 1R41D OR + 2R41D EPetoloR G 8.48E+09 pCi/sec 8.48E+08 pCi/sec 4.84E+07 pCi/sec 4.84E+05 pCi/sec M'Ga SPDS combined (9 Unit 1 + Unit 2 release rate Containment Fan Coil 1(2)R13A/B 1.64E+05 cpm 1.64E+03 cpm Process Liquid 1RI8 U1= 5.50E+05 cpm Radwaste N/A

  • Disposal See EAL RA1.3
'     Process                            2R18                                                                                                                       U2= 9.90E+05 cpm

-- Steam 1R19A-D U1= 6.40E+05 cpm U 1= 6.40E+03 cpm Generator Blowdown Process 2R19A-D U2= 8.30E+05 cpm U2= 8.30E+03 cpm Non-Rad Liquid 2R37 ---- 3.60E+05 cpm 3.60E+03 cpm Waste

  • For high radiation conditions on Letdown Line Monitor 1R31A (2R31), refer to EAL SU7.1 Basis:

oto Appe.dix A f, r a doetailed basio)f the rd*i*iogia, offbent l . C/EALS.] k , ,L , , ,tr 

                                 .    ......    .A... .....          ..       ..     .. I. . . . Aii..
                                                                                                    ..         L       j.A A....
                                                                                                                         ....           . 1..
                                                                                                                                            . .-in    -...
k. no r 4
  ;hnPId 11       hrH        thp miPnt ;q mncn Aqft                               ,qidtrminciq f             th~t thp mnr-it-n will lik-l.                              rr          fhn This ,-GEALaddresses an actual or substantial potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time.

Nuclear power plants incorporate features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. [These con..trol e are lo,-atedl 

    ýqtbnQf       site     Dose          )iaIti~-q-Oa~-u                     44pa                  I1)and (9904),                 frqr plai'~,         that    ha~"'        "3ti~pee Getneri! Letter-39-01, 4n the? Radiologioal EffLILA. Teo liLa~l Sp                                                              oat,'on s (RETS). The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls.

r c, ;14 , A- 4 4- 14 1 4. '4 - -- - - --- - -.-- I .- I-IL .41.4 bS4I 114 ~%LALAI.4LA LLA LAI..4LAILILALA I.ALALALAI.ALALA I 11.4 111.1 LAILA I LAILALAI.ILALA VIlLI I s.parale,.L-E, 1 The threshold values that equate to a RET-S-multiple of two hundred times the ODCM limits are-isare specified in AU! RU! andAA! EAL RA1.2 only to distinguish between non-emergency conditions, and from earch other. While these-this multiples obviously corresponds Salem Page 2 of 5 Rev. 0 (draft E) EAL#: R A12

SGS ECG - EAL Technical Bases EP-SC-1 11-203 to an off-site dose or dose rate, the emphasis in classifying thesesthis events is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate. [Tos ensurle a rea/letc near !inear eschalatiro path,i a value ehurmi whaSol prtedpreUghdy half way between the viaue codi anedg, tha!e dal..luation fAoS vaxum. The viale whllgbe ba sed onradiation monitor rcapdingc to exceed 200 tmes the Technical Specifiation limit and Teleasis are i ot ternddnatf d within 15 inue e stablishesdeflentamoitocn a nethond-oungy r dleterminPing- cifluent r-adiation monitor setpoints. The CDC44 Spec/f/ede fauRt source terme pathways gaseos readscas permbthe usen for nfordetermay d arnual aCveraginmeteraology Ci the most imiting downwind 

                           &eter           for Shewin)g comwgas *planedt the regulatses orMMitm eat.

This E,4L c-an be d-etermin~ed using th is appropriate.] ietodoegf [R~eleases sehoul not be proer-te er avagedl.For- example, a rcelease exc-eeding 600 ODC44 ýfo 5 minutes doe-e n et mneet the thres~eid.] This EAL includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit. EAL-#1 This EAL is intended for sites that have established effluent monitoring on non-routine release pathways for which a discharge permit would not normally be prepared (Containment Fan Coil, SC Blowdown & Chemical Waste Basin) as well as planned batch releases for which a radioactivity discharge permit is prepared (Liquid Radwaste Disposal). EAL #2 This EAL. addresses radioactiVity releases, that for whatever reaSonR, cause effluent radiation monitorm raPdinng to eXceedthe threshold idet*ified in the IC established. by the radioaGtivity discharge permit. This value may be associated with a planned bath relhease, or a continuou1s release path-. [In either case, the valuc is esetablished .by the ODCMA to war~n of a r~elea cc that is Pet.in compliance wth the RETS. 4ndox4n the &AL to the CDCM setpe4nts in this mannernue tht the EA L will Ree elesta the stpeip ~lesakhed by a spec-if4 ic.slqharerpP44 This EAL addresses Uncntro*lled releases that arc detected by sample analyses, patiularly

  • n uRmnRitred pathways, e.g., spills *fradiaoative liquids into storm draiRS, heat exchanger leakage in river water systems, etc-.

Salem Page 3 of 5 Rev. 0 (draft E) EAL#: FRA1 .2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EALs #4' and #5 The 10.0 mPhr value i* EAL #-, an*d the it* -- e*ifi Value f,,or, EAL ,,5,is based on a release rate not execeding 500 mrem per year. [,A,s pr0':4ded IR the ODC4*M-, ,ETS. pr.r.ated.ever-8766 ho..rs, .. d-by 200, and (500 

              . d. .7 6 (596)               0 - 44.4)].

EAL #1 and #2 directly correlate with the IC Since annual average meteorology is- -required to be used in showing comnpliance with the OIDGM and is Used in ca!culating the larm setp.int* . EALs #4 aRd #5 are a functiG* Gf acGt6al meteorology, which will likely be different 4Mfr the limiting anRnual aveI-age value. Thus, ther 

                                                           . wi. likely be a n.umerc*al The underlying basis of this EAL io*lv.es the degradation in the level of safety of the plat*

implied by the un.nltrolled release. Exceeding E=AL #4 or #5 is an indicatioFn of-an uncontro!Ied release. Explanation/Discussion/Definitions: With the exception of the R18 monitors, the "ALERT" column liquid release values in Table R-1 represent two hundred (200) times the High Alarm setpoints associated with the specified monitors. The High Alarm setpoints are obtained from channel calibrations procedures as listed in the reference section of this bases. Instrumentation that may be used to assess this EAL is listed below: 0 Containment Fan Coil Process 1(2)R13A/B (Upper Range is 1.OOE+06 cpm) Service water is used as the cooling medium for the containment fan coil units (CFCUs) and could be contaminated if the cooling coil leaks with containment pressure above Service Water pressure. Since the Service Water System discharges into Circ Water and then back to the river, the fan cooler units will be indirectly monitored for radioactivity. This is done through the use of two monitors for the five fan coolers. The two monitors sample two of the three Circ Water headers that contain Service Water used to cool the CFCUs just before it discharges back to the river. Alarms on these monitors would be indicative of a CFCU leak but could also be associated with other systems including from the pathways monitored by the R1 8s, R1 9s and the R37, which also discharge into Circ Water and are monitored by the 1(2)R13A/B. If simultaneous Rad Alarms are received on an R1 3 monitor along with any R1 8s, R19s or R37 monitor, then the source of the Rad effluent may not be a CFCU leak and further investigation would be warranted. However, exceeding the EAL threshold value for > 15 minutes should result in an Alert classification even if the exact source remains questionable. 0 Liquid Radwaste Disposal Process 1(2)R1 8 (Upper Range is 1.OOE+06 cpm) Since the ranges of the 1(2) R18s monitors do not support EAL threshold values of 200 times the high alarm value, no Alert threshold is provided on Table R-1. If the release Salem Page 4 of 5 Rev. 0 (draft E) EAL#:RAIo2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 pathway could not be isolated as expected, the EC should refer to EAL RA1.3 for Alert threshold values based on sample analysis. This channel continuously monitors all Waste Disposal System liquid releases from the plant. Automatic valve closure action is initiated by this monitor when a high radiation level is indicated and alarmed in the Control Room. Liquid Radwaste discharges to Circ Water which then discharges to the Delaware River. o Steam Generator Blowdown Process 1(2)R19A-D (Upper Range is 1.OOE+06 cpm) Each of these channels (four channels per unit) monitors the liquid phase of the steam generators for radioactivity, which would indicate a primary-to-secondary system leak. The four steam generator blowdown sample lines each have a radiation monitor. A high radiation alarm signal will close the No. 12 (22) steam generator blowdown tank inlet valves and the steam generator blowdown isolation valves on the affected steam generator. o Non-Rad Liquid Waste 2R37 (Upper Range is 1.OOE+06 cpm) The non-radwaste basin provides a potential release path due to the fact that steam generator blowdown is directed to the basin during plant startup. This monitor provides for continuous monitoring of the discharge from the non-radwaste basin. Non-Rad Liquid Waste discharges to Circ Water which then discharges to the Delaware River. Definitions: VALD: An indication, report, or condition, is considered to be VALID when it is verified by (1)an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AA1 Example EAL #2
2. Salem ODCM Section 3.3.8 - Radioactive Liquid Effluent Monitoring Instrumentation
3. Salem ODCM Figures 1-1 and 1-2, Liquid Release Flow paths for Unit 1 and Unit 2
4. UFSAR Section 11.4 Radiation Monitoring
5. PSBP 315733(4) Radiation Monitoring System Control Manual
6. S1(S2).IC-CC.RM-0097/98, Channel Cal for 1/2R13A/B
7. S1(S2).IC-CC.RM-0028, Channel Cal for 1/2R18
8. S1 (S2).IC-CC.RM-0029/30/31/32, Channel Cal for 1/2R1 9A/B/C/D
9. S2.IC-CC.RM-0060, Channel Cal for 2R37 Salem Page 5 of 5 Rev. 0 (draft E)

EAL#: A].2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 200 times the ODCM for 15 minutes or longer EAL# & Classification Level: RA1.3 - ALERT Mode Applicability: All EAL: Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > Table R-2 column "ALERT" AND > 15 minutes have elapsed (Note 2) Note 2: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.

. Table R-2 Effluent Sample Classification Thresholds Release Point Sample ALERT UE NG 6.40E-01 pCi/cc 6.40E-03 pCi/cc Plant Vent 0

1-131 5.60E-05 pCi/cc 5.60E-07 uCi/cc Unmonitored Isotopic 200 x ODCM 3/4.11.2 2 x ODCM 3/4.11.2 Containment Fan Coil Isotopic 200 x ODCM 3/4.11.1 2 x ODCM 3/4.11.1 

          -    Liquid Radwaste Disposal       Isotopic    200 x ODCM 3/4.11.1      2 x ODCM 3/4.11.1
          .L7  Steam Generator Blowdown        isotopic   200 x ODCM 3/4.11.1      2 x ODCM 3/4.11.1 Chemical Waste Basin           Isotopic    200 x ODCM 3/4.11.1      2 x ODCM 3/4.11.1 Unmonitored                    Isotopic    200 x ODCM 3/4.11.1      2 x ODCM 3/4.11.1 Salem                                               Page 1 of 6                                 Rev. 0 (draft E)

EAL#: IFRI LA1i .3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Salem Page 2 of 6 Rev. 0 (draft E) EAL#: RA* ,3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Basis: [Refer to App..dix A for a detaied basis of the.. dioE,g! .. IC/EAL s.] The Emergency Coo~rdinator should not wait uintil the applicable time has elapsed,bu huddecare the event as Seen as it is determined that the cnditio will likely eXceed th This 4-GEAL addresses an actual or substantial potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. [T-eSe . .ontrIS are lo*ated in the Off-site Dose Cailculation Manual (Q9CM4), and for plants that have not im~plemýente Ge.... Letter 99 01, in th9 RadioogiGa* Eff/ue nt c-n ,-el p-'"...... (RE TS).. The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls. [99ame sites m"ay find it advan tagee us te ad&ress gase~u and liqui'd releases wv4thsepal-t E5L.] The RET-S-multiple of two hundred times the ODCM limits are- isspecified in AU4-aRd4AMEAL RU1.3 only to distinguish between non-emergency conditions, and from each other. While these-this multiples obviously corresponds to an off-site dose or dose rate, the emphasis in classifying thee- this events is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate. [To ensur-e a real,' t,.e ner neai eacala tian pat4. a value should be Sgle'hdo FUghly ha/_f Way be+1q-em-th~eAL4 value and the6 value_ eaiculatqd AforAS! value. Th4e va4ue- w4~ be? based onR radiation4 monpitor reaadings to exeed 200 tim~eas the TeGhnical Spe fato; - t and releases ar.e no.t terminated within * *,iRutes. The QDC4 establis .... 

                                               ' a 'o thoedlogy for- determining effluent radiation mo/nitot setpqints. The ODOM spocf~e& defagult source? terms and-, for gaGeous release a pro scrbes the use Of p        determiedl

[e annuai average meteeor-ology in the meat doewwind sector for shep 

                                                                  .imiting                       w          '"

comýpliance with the regulatory' eammitments. Thi~s EA4L cnan be deteormýned using thita methodolo!gy it [Re! eases should Pot be prorýated or a'.vera ged. F or ex*ample5 a release exc-eeding 690,:x QDQC for 5 m,inutes does nPt meet the thresh&old] This EAL irncludes any release fG rwhich a radi*oati.Vity- diScharg-e permit Was not prepared, or a r-elese that XexeedS the conditionS (eg.Ymnmum dilutionR flow, m~ax-imum dischar-ge flow, alarm 6C-tpoint6, etc.) en the applicable permt EAL #l1 Salem Page 3 of 6 Rev. 0 (draft E) EAL#:RIAI. 3

SGS ECG - EAL Technical Bases I EP-SC-1 11-203 This EAL is intended for Stes that h.Ve established effue4nt monitoring on non routine releas. pathWays for which a dis.harge permit would not norm.ally be prepared.EAL 42 This EAL addresses radioactivity releases, that for w.hatever reaSon, cause effluent radiaion mon~itor readings to exceed the throschld identified in the lC established by the radioactivity discharge-permit. This -Vhal may be associated With a planned batch release, *r con..tinuous release path. 

       ... .her-
            ...              the value's estabflshedby            "he OD     to i.ar. of a r          .that.       pat, comp4i~anee 'ith'th      -      TS. Indexing the E,4L to the CDCM cc tpe~int& in this me nnqr-insur-es that              e F41L 141!1

.- neve be less than3 the se tpOint establhshe d by a &pecificd is harge peFrm i.] 

   -- EAL #3 This EAL addresses uncontrolled releases that are detected by sample analyses, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.

EALs #4 and #5 Th10. 0 mP~h r value in EAL #4 , and the site SpecifieGValue14 for EAL #5, i based on a releae rate not exceeding 500 rF.n. per .year. [As rOvided in the ODCM P..ET, proratedever 6Trs multiplied 

                                                                                       ,          -- by 200,, and (500 *8766 .- 200 -- 11. -)].

EAL I #41 and- direetlycor 

                              ,         .      lat. With the Its'      e annu..al a.erage m+et8eorology is rFeuired to be use di A ShA
        ...              og Gpli;n;Ge   w.lith
                                     , th, OD*O,M and is used in calculating the alar,, setp.its. EALs            ,,

an ;; re a funcRtion of actual mneteorology, which Will likely be different from the imitig aRnU6l average value. Thus, there will likely be a numerical inconsistency. Explanation/Discussion/Definitions: Confirmed sample analyses in excess of two hundred times the site Offsite Dose Calculation Manual Section 3/4.11.1 or 3/4.11.2 limits that continue for 15 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. This event escalates from the UNUSUAL EVENT, by raising the magnitude of the release by a factor of 100 over the UNUSUAL EVENT level (i.e., 200 times ODCM). Table R-2 provides calculated radiological release noble gas and iodine sample concentrations that equate to a release that'is 200 times the ODCM limit (Section 3/4.11.2) of 500 mRem/year as well as specifying liquid release effluent sample streams 200 times the ODCM limits (Section 3.11.1). Each Salem unit has a single gaseous release point (Plant Vent) for which a sample concentration threshold has been calculated. The required release duration was reduced to 15 minutes in recognition of the raised severity. Salem Page 4 of 6 Rev. 0 (draft E) EAL#: 'rO_\_]&.3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AA1 Example EAL #3
2. Off-Site Dose Calculation Manual, Section 3/4.11.1 - Liquid Effluents
3. Off-Site Dose Calculation Manual, Section 3/4.11.2 - Gaseous Effluents
4. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)

Salem Page 5 of 6 Rev. 0 (draft E) EAL#: RA1.3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 This page intentionally blank Salem Page 6 of 6 Rev. 0 (draft E) EAL#: RAI 3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 100 mRem TEDE or 500 mRem Thyroid CDE for the actual or projected duration of the release Mode Applicability: All EAL# & Classification Level: RSI.1 - SITE AREA EMERGENCY EAL: VALID gaseous monitor reading > Table R-1 column "SAE" AND Dose assessment results are NOT available AND 15 minutes have elapsed (Note 1) Note 1: Ifdose assessment results are available, declaration should be based on dose assessment (EAL RS1.2) instead of gaseous monitor values. Do NOT delay declaration awaiting dose assessment results. The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Salem Page 1 of 5 Rev. 0 (draft E) EAL#:RSIi

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Table R-1 EfflUent Monitor Classification Thresholds* Release Point Monitor GE SAE ALERT UE Plant Vent 1R41D +2R41D oo- Effluent Ee Noble b OR 8.48E+09 pCi/sec 8.48E+08 pCi/sec 4.84E+07 pCi/sec 4.84E+05 pCi/sec 

  )SPDS                                      combined
 . Unit 1 + Unit 2                release rate Containment Fan Coil                       1 (2)R1 3A/B                              ........                                                      1.64E+05 cpm                              1.64E+03 cpm Process Liquid                              1R18                                                                                                                                      U1= 5.50E+05 cpm Radwaste                                                                                                                                        N/A

-o Disposal See EAL RA1.3 

 "    Process                             2R18                                                                                                                                      U2= 9.90E+05 cpm

.J Steam 1R19A-D U1= 6.40E+05 cpm U1= 6.40E+03 cpm Generator Blowdown Process 2R19A-D U2= 8.30E+05 cpm U2= 8.30E+03 cpm Non-Rad Liquid 2R37 3.60E+05 cpm 3.60E-03 cpm Waste I I I I For high radiation conditions on Letdown Line Monitor 1 R31A (2R31), refer to EAL SU7.1 Basis: [PRe fe to Appendix A for a d~eta :Ycd *basis of thegradjele-gia1 efflinrept I C/EA LSA This IG-EAL addresses radioactivity releases that result in doses at or beyond the site boundary that exceed 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems heeded for the protection of the public. fWhile these failures are addressed by other I-GsEALs, this l-G-EAL provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertainties associated with the source term and/or meteorology.1 rriTkn

  • A M AI-- rn'rcn~ .,4, e v I.~ ' r - 1.,-  ! 44-iF-~ 14;,- ~,-, ,- e eq u4valent (ODE). For the purpose offth ese C/QE,41e. the decoe q uantgt total effectgve doe equivalent (TEDE)ý as defined in 10 CF=R 20, ics Ucedý inq .cuoGf ". ..swum of EDE= andCE...

7I-k L) A 0 A f~ -- ,,4.,ecc m-, 4 

                                                             ,r     4        t-1
                                                                            *1,-       1 ~
                                                                                              ,41,14                  4,1lrc .rc-  ~ ~ ~         ,m~\         ,4,c#,,.               £..     ,

It k 1/4' '1/4 

                                   -J-   -;,J1/4   1/4'   4-'       1/4 1-,~   t.1    1/4t 1/4' LA PrtLA ,--r-r    -    .
                                                                                                                ='    1. 1r,r 1;. I 1/4', /=.. I.. -, .---    ,    J 4-  1--.   CCZrr.?JC with   those      Af thp ýqf~qfp              iplvoK'odr in tho fnpi!!tv'.l" P                                    (wnno~n!300pip( 70001I~--
-[The TEDE dose which forms the bases for the specified effluent monitor threshold is set at 10% of the EPA PAG, while the 500 mrem thyroid, DE was established in consideration of the 1:'5 ratio o'f the EPA. PAG fer TEDE and thyroid C-DEE.1 Salem                                                                                   Page 2 of 5                                                                         Rev. 0 (draft E)

EAL#: I31. I

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL #-l-The site*Spe.if.Table R-1 monitor list 'n EAL #1 sh*o*d includes effluent monitors on all potential release pathways. [The moinit*or reading EALs hoL,,d be dete1,;Pined Using a dose assessment. m*tao that back c-i6ae fa, the Ge.4esse-~di3tei.See dcse a~ege;lrp it mon1toe d. r.. 't~l÷ime. is Suggested that a 

                                              .oleasae            dura*tiqo of c   hour
                                                                                     .e be assumhed, a**d that the EALs be based      'o3 a Site.p.         ific bouinda...(or beyond) dose of 1900, mm who.e bd or 500 mrem thyýred ..          on.e hour., whicheveris '-more imiting (as was d"one for EALs 2 and
  1. 4). ifindiviua. a'site a..al.ses hdc*ate a longer or sho-,er duretonf,* A theprq.4ed,
                                                                                      ,                   t*h,e.,

[The meteoroloegy usede shoLd be the same as those used oeai and AA i metitcr-r-ead:13g EA41e. The samýe source term,4 (noble ga ses, pactiGu4'ates, and /7aogene) may aso, be used asfoneg as it maintains a reaistic and near- liear esalationbetv Parra- EA ,s for the fouricttat a h If rclassiiation oa is warrante For thpr so emr t4gen term, if th4e ea/cu/ated vausar ~ h oqr if con Ueaton betwee,37the valuesan dioe mentig pret values doues nct exfor the 939f3 id eor Um ence of dose a tent for ASg rssess end(AG! c-alculations.] Since dose assessment is based on actual meteorology, whereas the monitor reading EAL is not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted. For this reason, emergency implementing procedures sheuldcall for the timely performance of dose assessments using actual meteorology and release information. If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor reading EAL. Salem Page 3 of 5 Rev. 0 (draft E) EAL#: R1S i .

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Explanation/Discussion/Definitions: This EAL address gaseous radioactivity releases, that for whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed 100 mRem TEDE. The column "SAE" gaseous effluent release values in Table R-1 (Unit 1 + Unit 2) correspond to calculated doses of 10% of the EPA Protective Action Guidelines (TEDE). The plant vent monitors (R41) sample and detect noble gases and collect samples of particulates and iodine discharge through the plant vent. Channel D (R41 D) provides the gaseous effluent release rate (pCi/sec) by combining (product of) the on-range R41A through R41 C with plant vent flow (cc/sec). If dose assessment results are available, EAL RS1.2 would dictate the need for a Site Area Emergency classification due to abnormal radiation effluents. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). VALID: An indication, report, or condition, is considered to be VALID when it is.verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, ASI Example EAL #1
2. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)
3. UFSAR Section 11.4 Radiological Monitoring
4. PSBP 315733(4) Radiation Monitoring System Control Manual Salem Page 4 of 5 Rev. 0 (draft E)

EAL#: RS i1

SGS ECG - EAL Technical Bases EP-SC-1 11-203 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#: RS .1

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 100 mRem TEDE or 500 mRem Thyroid CDE for the actual or projected duration of the release EAL# & Classification Level: RS1.2 - SITE AREA EMERGENCY Mode Applicability: All EAL: Dose assessment using actual meteorology indicates TEDE 4-day dose > 4.OE+02 mRem or Thyroid CDE dose > 2.OE+03 mRem at or beyond the MINIMUM EXCLUSION AREA (MEA) Basis: rmF,-,, ÷ ,J...,  ;,, A P-* -1 ÷ ;l -r .._,J 4-J I .,  ; l-, ,,, _,-, 

                                                                                                                                           ,I         .      4-,.1hfI  C'/A I  ,1 This IC-EAL addresses radioactivity releases that result in doses at or beyond the MINIMUM EXCLUSION AREA (MEA)site beYRdary that exceed 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

[While these failures are addressed by other [-GsEALs, this I--EAL provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertainties associated with the source term and/or meteorology.] [The EPA PAGs are ex.pr..sed in ter.m. of the sum. .f the effetve dooe e.....;,,n 1/CI)J= nt r4-,-ý/' H-14-4 -W 4, , 4 /fcrI~inj~ ^, tbt + ,-nb r 4ifcrldrc' , , i - Inn-, 4,,n 'l f l-r C7,. , 1--, ,I,- - - 4,-, -i-.,,,!f" I/7A I, I n-,- ÷1,,.- , ,-.. , i, , i' ÷,-,I F-,-.-, ,- , ,- ,r,, 1.I _'_. .. I _ _ _L./. I - "L.45U1151 t - -l " --- ,5 - - -15. " - .1 .5 . 1L£ 

                                                                                                                                      -4"*7         .* '
                                                                                                                                                    'J     L.-I--

The E-PA R-AG gu~idance pro vi4des for the ucse adult thyroid dese Con'VErc;io.n9 factGre. However, 

                                                    *5 1.1.15  -v'  11.4 1      1-   *1-     1511       '.

-[The TEDE dose is set at 10% of the EPA PAG, while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio ofthe EPA PAG for TEDE and thyroid CDE.J Salem Page 1 of 3 Rev. 0 (draft E) EAL#: R31.2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 The Site SpeG!+fic monitor- list inEAL #1 ShoGUld include effluent Mcnit-3rS Gn all Potenta rel ease pa1-thvwiays. [The9 monitor-raeading EALs should be dleterminedl using a dos as 'n 'n'-'t meth that back c-aicula tes from the dseo values SPeC-ifiEd in th9 10. 34iG G(soos a'ee3rGyio moniitored in resal tim3e, it is suggested that a i-elas dur-atien of one heur be assumedl, an~d OF 500 MroM thyroid in one hour, wh4cheve r is mrliiting (aS Was d-ne for EALs #2 an

  1. -4). if individlual site aigal'se 43diiate a~o iq31Er-Gr-cshptr-n dflruto Fthe p9r~494-nh-~i+/--hth-e SUb Ste ntial poio-f the- act4vfty isre-leasqpd, the- lonIger dur-ation should be used.]

[The meteoroelogy used shouldl be the same as those used for- deten.i44ng AUI an~d A monitor rad~gELs. The same sourcGe term4 (noble gases, pa~Wticuae, andf halogensý) i3maý alSo) be use4doS long 8S it Mainta4ns a realistic and neSr-lieer-escale- n b etkween the EA1s for the four cls~ia insIf proper escelations do not resut fr-om the use of the same Source termý,. if the cnalculated Values aer unr;ea 94a14s'clyhigh, or if correlationý between,, the values en dose assessment values daoes not exist, then con3sider- using an a cide nt sour-ce term: for ASi Since dose assessment is based on actual meteorology, whereas the monitor reading EAL is not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted. For this reason, emergency implementing procedures s-heuld-call for the timely performance of dose assessments using actual meteorology and release information. If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor reading EAL. Salem Page 2 of 3 Rev. 0 (draft E) EAL#: RS1 .2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Explanation/Discussion/Definitions: The dose assessment output on the Station Status Checklist (SSCL) is reported at varying distances from the plant as a TEDE 4-Day dose. This TEDE 4-day dose assumes a 4 hr release duration. To obtain the approximate dose for a projected release condition of 1 hour, the TEDE 4-day dose value would need to be divided by 4. A TEDE 4-Day Dose > 4.0E+02 mRem correspond directly to a TEDE dose rate value of 100 mRem/hr and exceeds 10% of the EPA Protective Actions Guides (PAGs). The Thyroid-CDE Dose > 2.OE+03 mRem correspond directly to an CDE dose rate value of 500 mRem/hr and exceeds 10% of the EPA Protective Actions Guides (PAGs) which was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE. For the purposes of this EAL, the Site Boundary for SGS is the MINIMUM EXCLUSION AREA. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). MINIMUM EXCLUSION AREA (MEA): The closest location just beyond the OWNER CONTROLLEDAREA where a member of the general publiccould gain access. For Salem the MEA-is 0.79 miles. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AS1 Example EAL #2
2. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)
3. UFSAR 2.1.2.2, Boundaries for Establishing Effluent Release Limits Salem Page 3 of 3 Rev. 0 (draft E)

EAL#: RSI2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels I Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 100 mRem TEDE or 500 mRem Thyroid CDE for the actual or projected duration of the release EAL# & Classification Level: RS1.3 - SITE AREA EMERGENCY Mode Applicability: All EAL: Field survey results indicate closed window dose rates > 100 mRemlhr expected to continue for > 1 hr at or beyond the PROTECTED AREA BOUNDARY OR Analyses of field survey samples indicate 1-131 concentration > 3.85E-07 j.Ci/cc at or beyond the PROTECTED AREA BOUNDARY Basis: [Refer- toAppendix A for a detailod basis of the radieie*giTl .if..t C/EALs.] This 4G-EAL addresses radioactivity releases that result in doses at or beyond the PROTECTED AREA BOUNDARY soi be,,,4*a,-,that exceed 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. {While these failures are addressed by other 4GsEALs, this W-EAL provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertainties associated with the source term and/or meteorology.] [The EPA RAGs are expressed intermc of the sum of the effeti.,e deo.. ',1 (E=DE) end-the commRpitted effective deco eq uivalent (CEDQE), or as the thyroGid commi*tted dc equiva.ent (CD E). Fe-r the pu.pe.e of these ICEALs, the dose quantity total effective dose equivalept (TEDE), as def n 10, C*FR 20 . is use d in lie.u of"... s-um of EDE= ,n CEDE.,." The EPA PAG ,-,Uid..e pro 'd 'for 

                                       , t!e Use adult throid do... . e e....er.so, h.,-,o Howev..

comre 

    *,*st*t                                                             !

hoVe d1ecded to* Gcalulate c'Id th,,-eid CDE, ilI;y ICOLEDA ,.Lsn to-eed be ,,,,eton; Salem Page 1 of 3 Rev. 0 (draft E) EAL#: RSi o3

SGS ECG - EAL Technical Bases EP-SC- 11-203 -[The TEDE dose is set at 10% of the EPA PAG, while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.] EAL #! The site specificm*oRnit- r list in EAL #1iShould include c.flueRt mRonirs* oR all pot'ntia release pathways. [The monitoGr 1reading EALS should be determ--ined using a dccc asse&S1ment m~ethod that back eaiculatc from4 the dose v ucc c'SPcified in the !C. 343ce dbe arE? geter-nal1l/ it mon(qtitor/ed in rca! ti'me, it is sL'ggestedl that a r~e/ca c dur-ation of onba hotur be assumqed, and that the &ALs be basedl on a site spe elfic boundar-y (or beyond) dose of 100 mr-em whoei bedý 

#4). ifipdi44dua! cite analysec iindic-ato a !ong or or-shoader duration for the per~di wi- h cubs tan~tial portion of the ac#444tyis released, the longer-         dur-atio n shc uld. be use-d.] .i.

[The P*eteGo'om' 'i S' b, came. as ... I, f eterm*n4ngU! a*d monitor' rcading EALc. The same surGe t~rR (noble gaces, pa,~itcGa tes, and halogenc, a.. also be used as lon~g as it mqaintainPs a i-ea/etic-and near,linear-esca/atgon between the EALs for-the four-clacssficat'on. ifproper esealatgons do no9t recult frcm3th e use of the cam~e sourc-e term, if the Ga'~ld 'alue are unrea/isticzal.' hgh, or if corr-elation bebwccn the valueSan dose assessment'vaffues doGes not exist, then~ consider using an accidoentcourýec te-prn for .451 and AGI c-alculations.] Explanation/Discussion/Definitions: This EAL addresses a radioactivity release field survey 1-131 sample concentration or count rate that would result in a Thyroid CDE dose of greater than 500 mRem for one hour of inhalation at or beyond the PROTECTED AREA BOUNDARY. This value exceeds 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. The Iodine-131 field survey sample concentration and count rate threshold is based on 1-131 dose conversion factors (DCFs) from EPA-400. The thresholds are based on a Thyroid-CDE Dose Rate of 500 mRem/hr for 1-131. For the purposes of this EAL, the PROTECTED AREA BOUNDARY is used as it is an easily determined location to obtain a field survey dose rate reading or to obtain a field sample. Definitions: IMMINENT: Mitigation actions have been ineffective, addit ional actions are not expected to be successful, and trended information indicates that the event .or condition will occur within approximately 2 hours (unless a different time is specified)I Salem Page 2 of 3 Rev. 0 (draft E) EAL#:RS] .3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AS1 Example EAL #4
2. Off-Site Dose Calculation Manual, Figure 5.1-3, Area Plot Plan of Site
3. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)

Salem Page 3 of 3 Rev. 0 (draft E) EAL#:RSI.3

SGS ECG - EAL Technical Bases EP-SC-111-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivitygreater than 1000 mRem TEDE or 5000 mRem Thyroid CDE for the actual or projected duration of the release Mode Applicability: All EAL# & Classification Level: RGI.1 - GENERAL EMERGENCY EAL: VALID gaseous monitor reading > Table R-1 column "GE" AND Dose assessment results are NOT available AND > 15 minutes have elapsed (Note 1) Note 1: If dose assessment results are available, declaration should be based on dose assessment (EAL RG1.2) instead of gaseous monitor values. Do NOT delay declaration awaiting dose assessment results. The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Salem Page 1 of 5 Rev. 0 (draft E) EAL#: RG ]o

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Table R-1 Effluent Monitor Classification Thresholds: Release Point Monitor GE SAE ALERT UE Plant Vent 1 R41 D + 2R41 D Effluent Noble OR 8.48E+09 pCi/sec 8.48E+08 pCi/sec 4.84E+07 pCi/sec 4.84E+05 t0Ci/sec 6h Gas SPDS combined Unit I + Unit 2 release rate Containment Fan Coil 1 (2)R1 3A/B ........ 1.64E+05 cpm 1.64E+03 cpm Process Liquid 1R18 U1= 5.50E+05 cpm Radwaste N/A Disposal See EAL RA1.3 Process 2R18 U2= 9.90E+05 cpm -1 Steam 1R19A-D U1= 6.40E+05 cpm U1= 6.40E+03 cpm Generator Blowdown Process 2R19A-D U2= 8.30E+05 cpm U2= 8.30E+03 cpm Non-Rad Liquid WasteIII 2R37 ---- 3.60E+05 cpm { 3.60E+03 cpm For high radiation conditions on Letdown Line Monitor 1R31A (2R31), refer to EAL SU7.1 Basis: ro,-,, ,. At.,- tn.,;v A f£r,9-#* lI nil bv, cqc ' ÷r*,f/ - irf;,.".l ,*i,"' ,n l,.r,+,,",÷ Ik/t AI-/l 1 L' .j, This I--EAL addresses radioactivity releases that result in doses at or beyond the site boundary that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and likely involve fuel damage. MWhile these failures are addressed by other l-C~sEALs, this I-CEAL provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertainties associated with the source term and/or meteorology.1 

                     -ri     r- r-) A    r-) A                                                                                                                                                     1 qP  .      -               P  -4ýh,                             q     P 9244 q   P    TF-4P    P f IM    A     T    P   -- MD 1,      1 P   ý41c).Q P   4;1 a !I
        /j=[_.=I.t           1;f-     ...              4      ýýý;.-            I            .       .       - -/1C            7                    --      1--,

c*,U,,*aI*,t (/' E- . Fo" tho purp,,.*-, f thes* !Q/E"L, ,,u-n;,tythe dose ttal effective d4osa V (.Afl...*I IL I LL~L./. ~4..) L4~JII flI.~LA III ~ ~SI I I L...'.J~ I ,~ITFV.~tA t., 

 '-Hel)        ~;          1-1;                      9 )9(ýG-                7;u;  u&P         S       aGuW     &HýyfGGN)L)Lis GGPV)ýL;SLJ;:                                GF)L)IJT. f~G4ePF sem            state hav                  de',irdhd hG GaGU9.                          GhNild 9-W                (Qh/nr lP!tilifv, !fl/9A!                   .;-ed          ff1 be Gon'sistfni

[The TEDE dose which forms the bases for the specified effluent monitor threshold is set at the EPA PAG, while the 5000 ,-rem thyroid CDE was established in consideration of the 1"5 

 -- 4-,-           4-k-.    =3A          A     _-.-      Tm         -,.-      4 41k,,,--,4 ("n[             1 Salem                                                                                        Page 2 of 5                                                                         Rev. 0 (draft E)

EAL#:RG 1

SGS ECG - EAL Technical Bases EP-SC-111-203 EAL -#1 The site speeifiG-Table R-1 monitor list in EAL #1 should includes effluent monitors on all potential release pathways. [The mon~itor- reading EALs should be determinedl using a dose assessment method that back calculateS froM the dEcoe lalueS Spa cified in the IG. Since doGSe are gnerOai4 Ily n m*nitor-ed-/ r'ealltme,, it "--sugge sted that are,ea d F" one hG o b-oa .*.ourrbehmd, an that the E"Ls be basedodn a site Spec.f.c be)und.ary (Or beyO*d1dlose of 1000 mrp*em *h*ol*e body,orf5-,0 mrcmi thy.roid ... in one 

                                      . hour, hich-ever is more limiting (as was done fer-E,4L ,,2 ande #f4). i f 44-"ý-Uq cite -analysesindligate a longer- or s'hor*r duration for the p nrlod in wichi the substantial por-tion of the activityi          ao the longer: dLr*.aon should ba*used.]

[Th3e dseteoraeogy used should be the camet as the sed g for drere:n3ngAU1 and AA i monpitor-r-eading EA4Ls. The same sourcGe term4ý (noble ga8se, pa~tiGulateS, andI halogens) m4ay alseb e used as loeg as it maintains a reenitis aynd neartineareSasationbes een thewEanL fcr the fouretaesrifiotions. If proepersescaations do net result from the use of thesamensre terib, if the calculated values are unriealsticalg, high, or if oerrelation between the values and dose assessment vraesul does pt exoit. r r ead i'ng EAPfr. a ent source and AG4 -acalulatiGons.] Since dose assessment is based on actual meteorology, whereas the monitor reading EAL is not, the results from these assessments may indicate that the classification is not warranted, Or May indica-;te- th-at aqhigher classification is warranted. For this reason, emergency implementing procedures should4call .for the timely performance of dose assessments 'using actual meteorology and release information. If the results of these dose assessments are-available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor reading EAL. Salem Page 3 of 5 Rev. 0 (draft E) EAL#:; ( ]. 1

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Explanation/Discussion/Definitions: This EAL address gaseous radioactivity releases, that for whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed 1000 mRem TEDE. The column GE gaseous effluent release values in Table R-1 (Unit 1 + Unit 2) correspond to calculated doses of 100% of the EPA Protective Action Guidelines (TEDE). The plant vent monitors (R41) sample and detect noble gases and collect samples of particulates and iodine discharge through the plant vent. Channel D (R41 D) provides the gaseous effluent release rate (pCi/sec) by combining (product of) the on-range R41A through R41 C with plant vent flow (cc/sec). If dose assessment results are available, EAL RG1.2 would dictate the need for a General Emergency classification due to abnormal radiation effluents. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AG1 Example EAL #1
2. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)
3. UFSAR Section 11.4 Radiological Monitoring
4. PSBP 315733(4) Radiation Monitoring System Control Manual Salem Page 4 of 5 Rev. 0 (draft E)

EAL#:RGI.1

SGS ECG - EAL Technical Bases EP-SC-1 I 1-2D3 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#: RG 1.]

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 1000 mRem TEDE or 5000 mRem Thyroid CDE for the actual or projected duration of the release EAL# & Classification Level: RG1.2 - GENERAL EMERGENCY Mode Applicability: All EAL: Dose assessment using actual meteorology indicates TEDE 4-day dose > 4.0E+03 mRem or Thyroid CDE dose > 2.0E+04 mRem at or beyond the MINIMUM EXCLUSION AREA (MEA) Basis: [Refer to Appendi 

                       .       ,4A for a detailed, basis of the radiologica*.l e-ffluent/*'1A Ls._

This 4-t-EAL addresses radioactivity releases that result in doses at or beyond the MINIMUM EXCLUSION AREA (MEA) site bo-d.a,*r*-that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and likely involve fuel damage. f/hile these failures are addressed by other I-GsEALs, this I-G-EAL provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertainties associated with the source term and/or meteorology.- 

    -[The      E-PA RAGs are exp~e ssac 0nterm:;s of the sumn Gf the effec~tive dose equivaleni (EDE) and the c-mi*tte* *va.nt    effFctive dose eqU:          (CE*DE., or as the thyroid
                                                                     .cm":ttc                        dc'so equivalent (CD E) For the purpose cf these 1c/EA4L 5, the doese quantity total effective dose eq.ivalent (T.EDE), as dofined in 1.0 CFR 2.,i. use in... i of........                f ED andCE ThPe E=PA PA G guidanc-e pro'~desc for the use adult thyroeid dose cGvrion factors. Hewevor, SOcme States have decided to calc-ulate ch,'ld thyroid CD)E. Utility IC/EALS need1 to be Gonsisteni 14ith those-3 Of the9 States9 involved in the faeiliteS eMergencplý a~nn,'g Zone.]

[The TEDE dose is set at the EPA PAG, while the 5000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.] Salem Page 1 of 3 Rev. 0 (draft E) EAL#:RGi.2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL #l-Thc Site SPecific monitor liSt in EAL #1 shoGuld include effluont Mcnitors on all potentia release pathway-&. [Thp oio edn EALs shouldl bc detemin*ed us'ng a dose a ssessrnont met!7od that back ca! Ula teS fromP the dobo values specifief d : the 1C,.&S4% doSeS are gEoneiralf4 m--onitored in real time, it is suggested that a release dL .ation of on-e hour be assumped, an that the EAOs be based on, a site "pe .if.- bound-ary. (or..beyond) dose of 1000 mr. whol. bodyý or-5000 mr-em thyroid in one hour, whichever is moPere !:miting (as was don~e for-EA4Le 

                     #,) if         *.                                  'IUL           for the per.
                                                                                                  .          w the substantial pssesmen of the acstv             is released-, the longer dthion should   n be used.],

[The metesulosgy used sho be sldthe samae as t hat for datersificg AsLI! a used rdAAn iml' Feaentingpedu The same sourte term nebly perses, pa.f dose and sesents) *uin acu be used ats long as it maintains a ralistio andt near-liear ese dsalaen between the E, forwthe clasificaf proaper escalationsdo not result faom the use 9f the sao e sou,e teP4 i te c-alc"ýiedýaue a unr6agticag,

re hig' or-~ ,if 6e~eatiG thowI (Arqr QCZP5I I Vus"- , __ '-P' fa dose as essmen ýýue does tnot exist, thet4 Gopisder usnga aidant &G 0tr' orAS G"

and AG4 c- alculains. Since dose assessment is based on actual meteorology, whereas the monitor reading EAL is not, the results from these assessments may indicate that the classification is not warranted-, o~r may indic~aAe that a higher claSSification is warranted. For this reason, emergency implementing procedures sheu44-call for the timely performance of dose assessments using actual. meteorology and release information. If the results' of these dose assessments are available when the classification is made (e.g., i~nitiated at -a lower classification level), the. dose assessment results override the monitor reading EAL. Salem Page 2 of 3 Rev. 0 (draft E) EAL#: N\

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Explanation/Discussion/Definitions: The dose assessment output on the Station Status Checklist (SSCL) is reported at varying distances from the plant as a TEDE 4-Day dose. This TEDE 4-day dose assumes a 4 hr release duration. To obtain the approximate dose for a projected release condition of 1 hour, the TEDE 4-day dose value would need to be divided by 4. A TEDE 4-Day Dose > 4.OE+03 mRem correspond directly to a TEDE dose rate value of 1000 mRem/hr and exceeds the EPA Protective Actions Guides (PAGs). The Thyroid-CDE Dose > 2.0E+04 mRem correspond directly to an CDE dose rate value of 5000 mRem/hr and exceeds the EPA Protective Actions Guides (PAGs) which was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE. For the purposes of this EAL, the Site Boundary for SGS is the MINIMUM EXCLUSION AREA (MEA) distance. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). MINIMUM EXCLUSION AREA (MEA): The closest location just beyond the OWNER CONTROLLED AREA where a member of the general public could gain access. For Salem the MEA is 0.79 miles. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AG1 Example EAL #2
2. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)
3. UFSAR 2.1.2.2, Boundaries for Establishing Effluent Release Limits Salem Page 3 of 3 Rev. 0 (draft E)

EAL#:RI.2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 1000 mRem TEDE or 5000 mRem Thyroid CDE for the actual or projected duration of the release EAL# & Classification Level: RG1.3 - GENERAL AREA EMERGENCY Mode Applicability: All EAL: Field survey results indicate closed window dose rates > 1000 mRem/hr expected to continue for > 1 hr at or beyond the PROTECTED AREA BOUNDARY OR Analyses of field survey samples indicate 1-131 concentration > 3.85E-06 tCi/cc at or beyond the PROTECTED AREA BOUNDARY Basis: r m ;_ A -r-- - -,C 4-1-- 1 _-W1-__4 I ý-=- A I -I This -G-EAL'addresses radioactivity releases that result in doses. at or beyond the PROTECTED AREA BOUNDARY&eteýbeun4az that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and likely involve fuel damage. {While these failures are addressed by other ,sEALs, this 4-G-EAL provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertainties associated with the source term and/or meteorology.] _[Thýe E- A PA4G& are expreseel dp tsarm 9f the surn 9f the effective delce equ4valem ýJ MIt : ,rr I jt A k 1 

                             ,r,,

rt.1aarat~ ifm aarl X, n'*f .L~ItL a,aall r4a-acaa AAAL 9 

                                                                                                         ~ILI' ~ . .L't)PW=rjr ighnI~nLJJ/                                1/4.IL on . aa .'t f/I HjI.             A ;rt4 L    i.,aaaat         ;H aL /4  . a'~L
                      ~~L~ rr
                    ~)fIi~',~r#                      ~        ,         -ca-arf         P     r, a',I"7                        +aa 4

aeaaaa7'*~,+-W~a ra T-,,-'#, 

                    ;,/           ,-    La i    , ,q , -, .F    ,L
                                                                 --.4  a,,/ a 1a;i     a t=.,3
                                                                                           -l
  • n. ' a;4 , ,- _F al t., La . *.O ._ - .r L -L. L . L .1 C . nFL . V

-Tiar LIDA Q4 (2ja ic - ~- 'a I- " a p,4 a- t--r fhp erp;a ý It4 thIr f14 rp ii acar pipa r'rra a-abar lqfcaa-'a'-rýro I- r-a, r If Salem Page 1 of 3 Rev. 0 (draft E) EAL#: RGI] 3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 come9 states hav'.e dec-de d to calculate child thyroqid G;9. Ut~izitylOE=ALs Reed to be Goncist,-nz with these of the states inýývoelv in the fa-c:!:tes em4er-gency plann,9ng zonqe.] [The TEDE dose is set at the EPA PAG, while the 5000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.J EAL--#1 The site moitor ist in EAL #I should inlude e 

                                                                                 ,pecificG              en t-a-ete release pathways.

[The monite- read"ng EAL*c should be det-rdusing a dose ases&.. nt meth. d that back c-alcu4atas from3 the dccc valuec cpcci fledl in the 'C. Since doese are gen~erally not monitored ir* eal time, it ic suggested that a refea.. duration. of one. hour be? assumed., apd that the EA4 be ,baced on a cite .p.cifi, (or beyond) deco of 1000 mrem w4'ho*le boundary body or 5000 mrem thyroid i3 one hour, w'her' is mqrr- "t (as was done for EAL endand........f.... 

       #I), if                 ÷......... .. 's 64""";";'""°/       .c
                                             ........        a         f.....'r .. or.snor        . dur.ation
o. . ..Lgr, . r-, . .. for
                                                                                                                ...... the per:,-in, t.. ..,-4,,/i*
R whi,l, the c.ubstantal p*r-tion f the activit, is rele*aced, the longer durat"on should be used.]

[The tseoroo" y u...d should be the came as ho..e u.sed for dAte1rq"'"4g, AU! and1AA monitor reading EALs. The cam..e sourGce teFrm (noble ga.e.... p.. :"i" and hai.gel.. 4my also be usedl as lon4g as 4t P~ait~a4sarcealistiG end , ear linear cala -ben vlel t~ EL& for the four classifications. If pro'per esc.alations deo,-t result from the use of the same source tc,, if h*e culated Values a..e Un r. aloSt:÷a/,y high, or if co.qn-lation, betw,,- .. the c.ue, and do~se assessment values does not exiist, then conSider us-R, anceide nt sour-ce- term: for-AS and,AG" calr',U,'latiG .] 

          ,SinRe do.Se aSse sFsen* t is             ba.ed-*,Gr-.tL-,eteGG,'gy-i,-,                          F   +   the monitorrcc, EAL isnet, the results from those assessments May indicate that the classification                                              on is warranted, or may indicato that a higher classification is warranted. Fe) this rca sonR, em~ergency implementing procGedures should call for- the timely perfermanoe of dose-asseSsments using actual meteorolo~gy and release i~f9PR~atiGR.if he Fesu-Its of these dese assessments are available when the classification is made (e.g., initiated at a lower classificati-o    level), the dose assessme.t results override the monitor reading EAL.

Explanation/Discussion/Definitions: This EAL addresses a radioactivity release field survey 1-131 sample concentration or count rate that would result in a Thyroid CDE dose of greater than 5000 mRem for one hour of inhalation at or beyond the PROTECTED AREA BOUNDARY. This value exceeds the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. The lodine-131 field survey sample concentration and count rate threshold is based on 1-131 dose conversion factors (DCFs) from EPA-400. The thresholds are based on a Thyroid-CDE Dose Rate of 5000 mRem/hr for 1-131. Salem Page 2 of 3 Rev. 0 (draft E) EAL#: RGI.3

SGS ECG - EAL Technical Bases EP-SC-111-203 For the purposes of this EAL, the PROTECTED AREA BOUNDARY is used as it is an easily determined location to obtain a field survey dose rate reading or to obtain a field sample. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). PROTECTED AREA (PA): A security controlled area within the OWNER= CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AGI Example EAL #4
2. Off-Site. Dose. Calculation Manual, Figure 5.1-3, Area Plot Plan of Site.
3. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)

Salem Page 3 of 3 Rev. 0 (draft E) EAL#:RG 1.3

SGS ECG - EAL Technical Bases EP-SC-1 11-204 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 2 - Onsite Rad Conditions/Fuel Pool Events Initiating Condition: UNPLANNED rise in plant radiation levels Mode Applicability: All EAL# & Classification Level: RU2.1 - UNUSUAL EVENT EAL: UNPLANNED water level drop in the refueling cavity, refueling canal or spent fuel pool (SFP) as indicated by ANY of the following: o Confirmed SFP low level alarm (OHA-C35 SFP LVL LO) o RVLIS - Refueling Mode o Visual observation (local or remote) AND VALID area radiation monitor reading rise on ANY of the following: o 1(2)R5 Fuel Handling Bldg o 1(2)R9 Fuel Storage Area o 1(2)R32A Fuel Handling Crane Fuel Handling Bldg (local monitor) o 1(2)R2 Containment General Area 130ft elevation o Temporary ARM Basis: This 4-0-EAL addresses increased radiation levels as a result of water level decreases above irradiated fuel or events that have resulted, or may result, in unplanned increases in radiation dose rates within plant buildings. These radiation increases represent a loss of control over radioactive material and represent a potential degradation in the level of safety of the plant. EAL #!1 r Q ;4- *,  ! ,-,  ;.-; -,-P-,*÷ 

                                                                                                           *   ,,, -* -, -P-4-;           -,, I                   ,*        I*,.*l         *.,.J   I*1 LI.it'&         .
                         -I-.LI~l 4
                                  - - '. -. I    I             !- jiiAj      II XdL)  '.4..t   !,     -

fl)L , , ,- , - - 

                                                                                                                             .LI.I4LL         .4     .%)       VI 4ALfl WI14~L       I       V 1/4..TX-1 r4rI, .4t;SLsICJ finn,      rnnn;fnroC I           nriri         nr LT4)fr4,n.4rI')L    nn~         In~ tv          fo  ,rin.i/-n 4        ,'t-r4Ajj
                                                                                                                '1     I11        ~r'.'

crn nrf S) IfI nuiln~irn-, 

                                                                                                                                                            .5       ALS.)         -birAS'ALLI   r     -

LSL . 4 

,m.-ay a1low -eopot O s * ýaioto,.                                   D"peonunpg on a."*-a.,1                                , Iev. l ivo,'.,,,a'i÷i,,                                the d ,cliaraio" Salem                                                                                          Page 1 of 4                                                                                  Rev.0 (draft E)

EAL#: RU2.1I

SGS ECG - EAL Technical Bases EP-SC-1 11-204 threshold ma. need to be based on id'atien* e.of water-makeup rate o. der..as. :, w..ate &tor-agetank/leva!.] I eactor h Ca" t ' -e at t!wo du-ff' as Of Wate in the Spent Fuel R44~u/ Iuz.IT. r- Canal at a B144R, ex-pfiqt coever-age of these tYpes of eve~nt via .... o--l #!is ap.r.opr.iategiven3 their,-po ;Gracd d9oe or-,a fpr .ta.ff, t.*: te The refueling pathway is the a-s;.e-sp.. *f"combination of cavities, tubes, Ga and pools in which spent fuel may be located. While a radiation monitor could detect an increase in dose rate due to a drop in the water level, it might hot be a reliable indication of whether or not the fuel is covered. tFor example, an , bridge ARM reading may increase uue to planned evolutions such 

                          -i,fuel' as head lift, or even a fuel assembly being raised in the manipulator mast. Also, a monitor could in fact be properly responding to a known event involving transfer or relocation of a source, stored in or near the fuel pool or responding to a planned evolution such as removal of the reactor head. Generally, increased radiation monitor indications will need to combined with another indicator (or personnel report) of water loss..

[App/catiGn Gf this EAL r...u..s understandingof the ac'tua r**adio ;t'i"'de. og ,o'7 present in the v.'c-4niy affth e monitor-. Information3 Not4ee Ne. 90 08, "KR 85 Hazards from Decayed F-uell" shGu~ldbe cosdeen esabihý3g r-adiat;,on mo' 5/ L For refueling events where the water level drops below the RPV-Reactor Vessel flange, classification would be via EAL G442CU3.1. This event escalates to an ALERT per AA2-EAL RA2.1 if irradiated fuel outside the reactor vessel is uncovered. For events involving irradiated fuel in the reactor vessel, escalation would be via the Fission Product Barrier Table-for events in operating modes 1-4. EA I2 This EAL addresses incessi plant radiation levels that represent a loss Of control oTI Pad aciovb4t1/2Tht&4~4ý69ltin§ in ý3 pbtbhtial de8OFidatioh in the level of ýfety of th64 Oat-. This EAL excludes radiatien level increases that result from plaRned activities such a-s use of rafdiographic soures and movement of radiOactive waste mateFrials.A SPcific liSt ot AIRP415 is nOt'Fqie S'otCUld FcStri .t.:the applicdýbility ef the Threshol .d. The intent is to identify loss o-f 6ontrol- of radioactive materi~al in any monitored area-. Explanation/Discussion/Definitions: The Spent Fuel Pool (SFP) low level alarm actuates at 128' 2" from 1(2)LC650. During refueling operations the reactor vessel and refueling cavity are flooded. During fuel handling operations, the. fuel transfer tube (canal) will confnect the refueling cavity and the Spent Fuel Pool (SFP). An unexplained lowering of refueling cavity level or SFP level can be Salem Page 2 of 4 Rev.0 (draft E) EAL#: RUM

SGS ECG - EAL Technical Bases EP-SC-1 11-204 an indication that these volumes are draining. A drop in refueling cavity and SFP level may result in a SFP low-level alarm. This alarm would be validated by visual observation of lowering level (local or remote) in the refueling cavity or SFP. When the spent fuel pool and refueling cavity are connected, there could exist the possibility of uncovering irradiated fuel. Therefore, this EAL is applicable for conditions in which irradiated fuel is being transferred to and from the Reactor Vessel and SFP as well as for SFP drain down events. For a loss of shielding, the source of the radiation is within the refueling cavity or SFP. Without the shielding provided by normal water inventory in the SFP, equipment pool, and/or refueling cavity, radiation levels from irradiated fuel and activation products will rise substantially. Area radiation monitors that may respond to a loss of spent fuel shielding are those located on the 130' elevation (Containment or Fuel Handling Building): o 1(2)R5 Fuel Handling Bldg o 1(2)R9 Fuel Storage Area 

    ,   1(2)R32A Fuel Handling Crane Fuel Handling Bldg (local monitor) o    1(2)R2 Containment General Area 130ft elevation o Temporary Area Radiation Monitors Definitions:

UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AU2 Example EAL #1
2. Sl(S2).OP-AR.ZZ-0003(Q) OHA-C35 SFP LVL LO
3. Si (S2).OP-AB.FUEL-0002(Q) Loss of Refueling Cavity or Spent Fuel Pool Level
4. S1(S2).OP-AB.RAD-0001(Q) Abnormal Radiation
5. S1(S2).OP-AB.FUEL-0001(Q) Fuel Handling Incident Salem Page 3 of 4 Rev.0 (draft E)

EAL#:RU2.i

SGS ECG - EAL Technical Bases EP-SC-1 11-204 This page intentionally blank Salem Page 4 of 4 Rev.0 (draft E) EAL#: U 2,,i

SGS ECG - EAL Technical Bases EP-SC-111-204 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 2 - Onsite Rad Conditions/Fuel Pool Events Initiating Condition: UNPLANNED rise in plant radiation levels Mode Applicability: All EAL# & Classification Level: RU2.2 - UNUSUAL EVENT EAL: UNPLANNED VALID area radiation monitor readings or survey results rise by a factor of 1,000 over normal levels (Note 7) Note 7: Normal levels can be considered as the highest reading in the past 24 hours excluding the current peak value Basis: This 4-~--EAL 2ddresses incrnasnd radiation lovek r c"i 1+ nf NAiý+ýr !L\Imi -4 ,-~ c iC in irradiated fuel o-r events that have resulted, cr may resflt,4nUNPLANNED increases in radiation dose rates within plant buildings. These radiation increases represent a loss of control over radioactive material and represent a potential degradation in the level of safety of the plant. EAL H1 r Qif-n n ~- I nrn- n = i i~nn,-4, in-4 ýqi -qnpfn~fipq,- c', iu,,l+,-.,- nf l ,un/ =r nlnj ql qrpq~J I radiation moit-ePorsq, an3d por-eOn n! (-eg, refueling Grakl i-pets. If available, video c-amera mayP allowf-v e3o tiee epen~ding on3 availa ble leveI i.Ltru, entation, the Gleclarat:o 

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storage tank !ee!.] 

                                                                      ;4-. C' - -I  ý'_ ;1, 4n the Spent Fuel Pit4gFue T-r,-asfer Cana!o at a 914WR, ex.p.i.it coverage of thesee types of ..a...
     ..                         f                                       .            .                  B_           '-      ,   ;÷-1      4_       _

ý,ý o .* 1111 il I - --- I- L11-11 11LI-I 1-1 111 - - - - - - I I The refueling pathway is a site specific combination of cavities, tubes, canals and pools. While a radiation monRitor could detectA an inRGease- in dose rate due to a drop in the 

      * .x*,..,,,,      ~!I~11v,,    ,t;
                                       ýz, ,,

1iA LiLA Lk; A F111 _[For= exam.ple, a refuelin,g bridge ARM reading mayincr.ease due to plannd evolutions k-nA kn I; ar 

                                            ý+      ri, in            ýl     a    -nn nýkl,        k-;-~        -      -A        i +kn -mti.,          1-n+n         -  _ i     -     A I-'-

mon-ito-r Pc-ouId in fct be9 properly respondingh to a known ev.'enRt inv'olvi gtansrfe-r Or relocation Salem Page 1 of 3 Rev. 0 (draft E) EAL#: 'RW 2.2

SGS ECG - EAL Technical Bases EP-SC-111-204 of a so-urce, stored in or near the fuel pool or- so*Pdinrg to a planRnd eVolutioR Such a removal of the reactor head. Generally, increased radiationR moton r iRdi.ation wil neeld to, omrbiRed with anotherindicator (Or personnelf report) of water loss] [App.i.ation of this EA.L requireador.t..d.g of te a.tUa. .... ito 

                                                         .adio.l.g.

P r8EnPt iq th9 WG3i' Gf thE? monitor. h3A9Frm'Fir4G, MrU'9 ir,NO. 91909 XR(-95 Hazrds fr-O For refueling events where the water level drops below the RPV flange classification A9woul be via CU20. This event escalates to an Alert per AA2 if irradiatted fuel outside the reactor vessel is uncovered. For events involving irradiated fuel in the reactor vessel, escalation would be via the Fission Proeduct Barrier: Table for events in operating modes 1--4. radioactive niatriaIl resultiRg in a potential degradation in the level of safety of the PlAt This EAL excludes radiation level increases that result from planned activities such as use of radiographic sources and movement of radioactive waste materials. A specific list of ARMs is not required as it would restrict the applicability of the threshold. The intent is to identify loss of control of radioactive material in any monitored area. Explanation/Discussion/Definitions: Definitions: UNPLANNED - A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. VALID - An indication, report, or condition, is considered to be VALID when it is verified 

      -by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed.

Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AU2 Example EAL #2 Salem Page 2 of 3 Rev. 0 (draft E)

EAL#: FW2.2

SGS ECG - EAL Technical Bases EP-SC-111-204 This page intentionally blank Salem Page 3 of 3 Rev. 0 (draft E) EAL#:RU2o2

SGS ECG - EAL Technical Bases EP-SC-1 11-204 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 2 - Onsite Rad Conditions/Fuel Pool Events Initiating Condition: Damage to irradiated fuel or loss of water level that has resulted or will result in the uncovering of irradiated fuel outside the Reactor Vessel Mode Applicability: All EAL# & Classification Level: RA2.1 - ALERT EAL: Damage to irradiated fuel or loss of water level (uncovering irradiated fuel outside the Reactor Vessel) that causes a VALID high alarm on ANY of the following radiation monitors: Fuel Handling Bldg o 1(2)R5 Fuel Handling Bldg o 1(2)R9 Fuel Storage Area o 1(2)R32A Fuel Handling Crane Fuel Handling Bldg (local monitor) o 1(2)R41A Plant Vent Containment o 1(2)R2 Containment General Area 130ft elevation o 1(2)R11A Containment Air- Particulate o 1(2)R12A Containment Vent - Noble Gas o 1(2)R12B Containment Vent- Iodine Basis: This 1-0-EAL addresses increases in radiation dose rates within plant buildings, and may be a precursor to a radioactivity release to the environment. These events represent a loss of control over radioactive material and represent an actual or substantial potential degradation in the level of safety of the plant. Salem Page 1 of 5 Rev. 0 (draft E) EAL#: IRA2d

SGS ECG - EAL Technical Bases EP-SC-1 11-204 [These events escalate from AJ-2-EAL RU2.1 in that fuel activity has been released, or is anticipated due to fuel heatup. This 4.-EAL_applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage,] EAL if 1 [Sit &P csrf c-4 ' r7snli~gq s r 7 GýhGle 43r7 

                                         ,4aý             r 4P4-r, r7      atio:) SurI- a's w ate"r /evl algd Ieee'-ir9-r-adiationqmonitores, an7d per-soinne (e.g.,           '-efulig 6;rn ý;) roepets if available, vid-eo Gamras may aloiw ... m. o            a     Dpen.ding on availablo l-ve- inst..;m.ntation. the de;larao*-

threshold m~aý, i'ed-to e b' e~ 9 ýndi~a~es of wa~r ij73keLt p rt dec-1ý-reSe in wa te storage tank leve!.] [In light of ReaGto*r* Cavi, Sea/ fai,,.e in cdents at two d.ffer*ent PVAs and !.s of wAt.r in the Spent Fuei*Pi'Fuc! Troansfer"Ca.3al at a 944R, explicit cover.age of these tef events via 14r-esheid1#1 is appropriategilvený their peotential Afo increaseed-ds- to-plat saff E:A I-,2 This EAL addresses radiation monitor indications of fuel uncovery and/or fuel damage. Increased ventilation monitor readings may be indication of a radioactivity release from the fuel, confirming that damage has occurred. Increased background at the ventilation monitor due to water level decrease may mask increased ventilation exhaust airborne activity and needs to be considered. While a radiation monitor could detect an increase in dose rate due to a drop in the water level, it might not be a reliable indication of whether or not the fuel is covered. [For example, a refueling bridge ARM reading may increase due to planned evolutions such as head lift, or even a fuel assembly being raised in the manipulator mast. Also, a monitor could in fact be properly responding to a known event involving transfer or relocation of a source, stored in or near the fuel pool or responding to a planned evolution such as removal of the reactor head. Generally, increased radiation monitor indications will need to combined with another indicator (or personnel report) of water loss.] [Application of this EAL r-equiresunostn 9n f the actual r-adiologicalcoGnditions pre-sent in the vicini-ty of the monpitor. Informa tion3 Notic-e NG. 90-08, F"KR-85 Hazards from De~a"& Fuel"she uidbe co~siedered ii3 est abls',g Faitet 3r,;e--A Escalation of this emergency classification level, if appropriate, would be based on A9-1 EAL RS1.1 orAG4EAL RG1.1. Explanation/Discussion/Definitions: Indications of spent fuel damage may include: 0 Actual visual observation of a fuel handling incident Salem Page 2 of 5 Rev. 0 (draft E) EAL#: `A2. 1

SGS ECG - EAL Technical Bases EP-SC-1 11-204 o Gas bubbles in the vicinity of a fuel bundle o Discoloration of the water in the vicinity of a fuel bundle o Increasing radiation and alarm on area and ventilation radiation monitors When the Spent Fuel Pool (SFP) and refueling cavity are connected, there could exist the possibility of uncovering irradiated fuel. Therefore, this EAL is applicable for conditions in which irradiated fuel is being transferred to and from the Reactor Vessel and SFP. For a loss of shielding, the source of the radiation is within the refueling cavity, refueling canal or SFP. Without the shielding provided by normal water inventory in the SFP, refueling canal and/or refueling cavity, radiation levels from irradiated fuel and activation products will rise substantially in either the Containment or Fuel Handling Building. Radiation levels > 2 R/hr in the Containment or FHB are indicative of imminent uncovering of spent fuel or reactor internals. Fuel Handling Building (FHB) Area Radiation Monitors (ARMs) 1(2)R5 Spent Fuel, 1(2)R9 New Fuel Storage and 1(2)R32A Fuel Handling Crane are located on the 130' elevation of the FHB. o 1(2)R5 Fuel Handling Bldg - This channel continuously monitors the fuel storage areas. A high radiation alarm will initiate charcoal filtration of the FHB atmosphere. o 1(2)R9 Fuel Storage Area - This channel also continuously monitors the fuel storage areas. A high radiation alarm will also initiate charcoal filtration of the FHB atmosphere. o 1(2)R32A Fuel HandlingCrane Fuel Handling Bldg (local monitor) - This channel is not connected to the central Radiation Monitoring System and is provided with a flashing beacon and stops upward hoist movement. 1(2)R41A Plant Vent is the low range noble gas Plant Vent monitor. Releases of fission product gases to the FHB atmosphere would be transported via the FHB Ventilation and detected in the plant vent radiation monitor. Containment Area Radiation Monitor (ARM) 1(2)R2 Containment is located on the 130' elevation of the Containment. Releases of fission product particulates, iodines or gases to the Containment atmosphere would be transported via Containment ventilation and detected in the Containment Vent Radiation Monitors 1(2)R11A (part.), 1(2)R12A (gas) or 1(2)R12B (iodine). Definitions: Salem Page 3 of 5 Rev. 0 (draft E) EAL#: [A2o

SGS ECG - EAL Technical Bases EP-SC-1 11-204 VALID - An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AA2 Example EAL #2
2. S1(S2).OP-AB.FUEL-0002(Q) Loss of Refueling Cavity or Spent Fuel Pool Level
3. SI (S2).OP-AB.RAD-0001 (Q) Abnormal Radiation
4. SI(S2).OP-AB.FUEL-0001(Q) Fuel Handling Incident
5. UFSAR Section 11.4 Radiation Monitoring Systems Salem Page 4 of 5 Rev. 0 (draft E)

EAL#: RA2o

SGS ECG - EAL Technical Bases EP-SC-1 11-204 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#:RA2.,

SGS ECG - EAL Technical Bases EP-SC-1 11-204 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 2 - Onsite Rad Conditions/Fuel Pool Events Initiating Condition: Damage to irradiated fuel or loss of water level that has resulted or will result in the uncovering of irradiated fuel outside the Reactor Vessel Mode Applicability: All EAL# & Classification Level: RA2.2 - ALERT EAL: A water level drop in the refueling cavity, spent fuel pool or refueling canal that will result in irradiated fuel becoming uncovered Basis: Th IC addresses 

             -         ireases in ,radiatinR dose rates Within plRnt buildiRgs, and may be a precu.sor to a radioactiVity release to the RnY.,ir..e..t. These This events represents a loss of control over radioactive material and represents an actual or substantial potential degradation in the level of safety of the plant.

JThes-This events escalates from AU2-EAL RU2.1 in that fuel activity has-been-released, e is anticipated due to fuel heatup. This IG-EAL applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage.1 EAL ii# [Site Spe...i lindications may include instrumentation such as water level and local area radiation monitors, and personnel (e.g., refueling crew) reports. If available, video cameras may allow remote observation. Depending on available level instrumentation, the declaration threshold may need to be based on indications of water makeup rate or decrease in water storage tank level.] [In,Lght of Reactor Cavity Sea' failurn inciden t at two dffFrn RS and Ie2e of a ii3 the Spent Fuel P, 4, eW Transfcr Cenai ata BLUVR, epli~t roveýrage of these types ofe-,'Wt viheshold HIisaporate g: vqnth ow9i pGetntial Afo increasedl doses to plant staff]. This EAL ad-dres6se radiationR monitor indications of fuel LJRG9V8ý' and/orP fUe dam~age. Salem Page 1 of 3 Rev. 0 (draft E) EAL#: RA2.2

SGS ECG - EAL Technical Bases EP-SC-1 11-204 InrGeased Vontilation monitor readingS may be indication of a radioactiVity release #roM the fuel, nRfi-rming that damage has ocurred. Increased background at the ventilation monitorF duo to wvater level decrease May Mask inRa-easc~d ventilation exhaust airbo)rne acti'ýit and needs to be coRSidercd. 

       \ANhilcz aqradi-Ation monitor coeuld detect an increase in dose rate du~e to) a drop in tho water lo*ve.,   it might Rot be a reliable indication of whetheF 9o net the fuel is covered.

[For example, a refueling bridge ARM reading may ic....rease due to planned evolutio such as head lif, or even a fuel assembly being raised in the manipulator mast. Also-,a monitrcoud in faCt be properly resPonding to a known event involving transfer or reloation. of a source, stored in*G near the fuel pool or resp9oding to a planne.dAvolutio such a. rem.va of t.he rea.to head. .Generally, increased radiation mn..itor indications Will Reed to combined with another iRdicator (o-r perSoGnel report) of water loss.] 

       ý4policatiep of this EA4L requires und~eer-standing of the actuc4! radliologic-al condition pro~e nttheio W~cnl y Of the mo9nitor-. In~fomation Notice No. 90 089, "KR 85 HazaqrdsromFr Escalation of this emergency classification level, if appropriate, would be based on A-S4--EAL RS1.1 orAG4EAL RG1.1.

Explanation/Discussion/Definitions: None EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AA2 Example EAL #1 Salem Page 2 of 3 Rev. 0 (draft E)

EAL#: rA2.2

SGS ECG - EAL Technical Bases EP-SC-1 11-204 This page intentionally blank Salem Page 3 of 3 Rev. 0 (draft E) EAL#: RA2.2

SGS ECG - EAL Technical Bases EP-SC-1 11-205 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 3 - CPJCAS Rad Initiating Condition: Rise in radiation levels within the facility that impedes operation of systems required to maintain plant safety functions Mode Applicability: All EAL# & Classification Level: RA3.1 - ALERT EAL: Basis: This I4P-EAL addresses increased radiation levels that- impact continued operation in areas requiring continuous occupancy to maintain safe operation or to perform a safe shutdown. The cause and/or magnitude of the increase in radiation levels is not a concern of this 4-GEAL. The Emergency Coordinator must consider the source or cause of the increased radiation levels and determine if any other t-rEAL may be involved. [This KC is no9t P-eaUo op aply to kneroeass 43 the cnomntdomeq roadiation montitor as thesere Pts ho...h are adessed in- the ission product ba...er tablo.] JThe value of 15mR/hr is derived from the GDC 19 value of 5 rem in 30 days with adjustment for expected occupancy times. Although Section III.D.3 of NUREG-0737, "Clarification of TMI Action Plan Requirements", provides that the 15 mR/hr value can be averaged over the 30 days, the value is used here without averaging, as a 30 day duration implies an event potentially more significant than an Alert.] Areas requiring continuous occupancy include the Control Room and, as appr.priatc to the site, any other control station;s that are staffed conRtiRn6uusly, such as a r..dWa.st. cont. ,Rom or a security alaFrm station. [rTypicl these areas ore the Control Room a... the Central Alarm Station (CAS).- Salem Page 1 of 2 Rev. 0 (draft E) EAL#: RAM

SGS ECG - EAL Technical Bases EP-SC-1 11-205 Explanation/Discussion/Definitions: Control Room ARM 1(2)R1A measures area radiation in a range of 0.1 - 103 mR/hr. Should increase Control Room radiation be detected, operators are directed to align Control Room Ventilation in the Accident Pressurized mode. There is no permanently installed CAS area radiation monitor that may be used to assess this EAL threshold. Therefore, this threshold must be assessed via local radiation survey for the CAS. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AA3 Example EAL #1
2. UFSAR Section 11.4 Radiation Monitoring Systems
3. SI(S2).OP-AB.RAD-0001(Q) Abnormal Radiation Salem Page 2 of 2 Rev. 0 (draft E)

EAL#t:RA

SGS ECG - EAL Technical Bases EP-SC-1 11-206 EAL Category: E - ISFSI EAL Sub-category: Spent Fuel Transit Initiating Condition: Damage to a loaded cask CONFINEMENT BOUNDARY Mode Applicability: Mode NOT applicable EAL# & Classification Level: EUI.1 - UNUSUAL EVENT EAL: Damage to a Multi Purpose Canister (MPC) CONFINEMENT BOUNDARY as indicated by on-contact radiation readings > 600 mRJhr (gamma + neutron) on the surface of the spent fuel cask, excluding the air vents, OR > 60 mR/hr (gamma + neutron) on the top of the spent fuel cask while in transit to the. ISFSI. Basis: An NOU-E-UNUSUAL EVENT in this I-0-EAL is categorized on the basis of the occurrence of an event of sufficient magnitude that a loaded in-transit eask-MPC CONFINEMENT BOUNDARY is damaged or violated. This includes classification based on a loaded fuel storage cask CONFINEMENT BOUNDARY loss leadiRg to the degrada'iGRn f the fuel duriqn storage or posing an operational safety problem with respect to its removal from storage. rm-i-l ,-.,Hc. ii4 I OC01 C' F_-,f+- A D--,-* -* 

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                                                                                                                                            -f-    1 7 Explanation/Discussion/Definitions:

This EAL applies to emergency conditions affecting a spent fuel cask caused by an accident or natural phenomena. This EAL would be applicable at all times in all modes for a loaded spent fuel storage cask from the time the lid is installed, as the cask leaves the Salem Fuel Handling Building and during transport to the INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI). This EAL provides for an Unusual Event classification, which may be entered if conditions occur that have the potential for damaging or degrading the CONFINEMENT BOUNDARY of a spent fuel cask. Damage to the storage cask could result in an increase in direct radiation readings from the cask. This Salem Page 1 of 3 Rev. 0 (draft E) EAU# oM

SGS ECG - EAL Technical Bases EP-SC-1 11-206 Salem EAL is only applicable for a Salem spent fuel cask that is in transit to the ISFSI. After the spent fuel cask is in place at the ISFSI, any further conditions that could adversely impact the ISFSI or an individual cask from either Salem or Hope Creek would be assessed and classified as needed by the Hope Creek Shift Manager (SM) per Hope Creek EAL EUI.1. As provided in the Holtec HI-STORM 100 System Certificate of Compliance (CoC), Appendix A (Technical Specifications), Section 5.7.4 contains radiation values for the cask that should not be exceeded. Under Amendment #5, the highest allowable radiation level on contact with the HI-STORM 100 cask body is 300 mRihr on the side.of the cask and 30 mR/hr on the top of the cask. Keeping ini line with NEI guidance that a UE is w-arranted for radiation conditions at a level of twice the Technical Specification value, 600 mRlhr and 60 mR/hr are being used as the EAL threshold radiation levels. ContinuiedUs(et::of this lowe-r value is conservative for casks loaded under later CoC amend-ments where the radiation limit values may increase. The threshold values aret-sufficientiI a6bove nominal radiation levels 'of the CONFINEMENT BOUNDARY:that" radiation levels above this EAL threshold would indicate significant damage to the CONFINEMENT BOUNDARY. No releases of radioactive material requiring offsite response or monitoring are e>pected because. theo.seal-welded spent fuel canister (part of the CONFINEMENT BOUNDARY) is

  • desighnd.}tO~ir&.@.:mairiintact under all normal, off-normal, and credible accident'conditiors of onsitetanrs~pr.tand storage at the. ISFSI, according to Holtec licensing documrehtsý',>Prior-to the installa'tfid-nh 6f the spent fuel -cask lid on the HI-STORM 100 cask, emergenc,y classificationhss would be based on other Category R EALs. . -

Definitions:. INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that: is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. CONFINEMENT BOUNDARY: Is the barrier.(s) between areas containing radi6dctiv* substances and the environnment and includes the mnulti-purpose canister (MPC) and, for the purposes of this EAL, the associated cask shielding. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, E-HU1 Example EAL #1
2. HOLTEC HI-STORM 100 UFSAR, Chapter 5 and Chapter 11
3. Certificate of Compliance, Docket # 72-1014
4. Holtec International Final Safety Analysis Report for~the HI-STORM 100 Cask System Holtec Report No.: HI-2002444
5. Certificate of Compliance No. 72-1014 Appendix A Technical Specifications for the HI-STORM 100 Cask System Section 1.1 Definitions Salem Page 2 of 3 Rev. 0 (draft E)

EAL#: EU 1. ,1

SGS ECG - EAL Technical Bases EP-SC-1 11-206 Salem Page 3 of 3 Rev. 0 (draft E) EAL#: EUI.1

EALs for: HAZARDS

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: ,-H__- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HU1.1 - UNUSUAL EVENT (Common Site) EAL: Seismic event identified by ANY two of the following: o Earthquake felt in plant by Control Room Operators o SMA-3 Event Indicator (flag) white o National Earthquake Information Center (NEIC) (Note 4) Note 4: The NEIC can be contacted by calling (303) 273-8500. Select option #1 and inform the analyst you wish to confirm recent seismic activity in the vicinity of Salem/Hope Creek Generating Station. Provide the analyst with the following coordinates: 390 27' 46" (39.4650) north latitude, 750 32' 08" (75.5370) west longitude. Basis: These-This EALs -re-is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators. E-AL "'1 Damage may be caused to some portions of the site, but should not affect ability of safety functions to operate. As defined in the EPRI-sponsored Guidelines for Nuclear Plant Response to an Earthquake, dated October 1989, a "felt earthquake" is: An earthquake of sufficient intensity such that: (a) the vibratory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated. Salem Page 1 of 5 Rev. 0 (draft E) EAL#:HUI.1

SGS ECG - EAL Technical Bases EP-SC-1 11:-207 [For- moa~t plants with seis~mic inatrum entatien, the seipmic-switch cc are Se-t at an aG elerat49t of about 9040g, This EAL should be developed on site &pec-if4c basis. The method of detection c-an be based on instrumentation, validatad ~by a reliable? source, or-oper-ator assessment.]q The National Earthquake Information Center can confirm if an earthquake has occurred in the area of the plant. Explanation/Discussion/Definitions: SGS seismic instrumentation consists of a Kinemetrics SMA-3 Strong Motion Accelerograph and associated sensors that are equipped with seismic triggers set to alarm (Unit 1 OHA A-37 SEIS RCDR SYS ACT) and initiate recording at an acceleration equal to or exceeding 0.01 g. When the seismic trigger activates the SMA-3 Event Indicator (flag) will change from black to white and the amber event alarm will illuminate. The amber event alarm will extinguish when ground acceleration reduces below the 0.01 g setpoint but the Event Indicator (flag) will remain white until manually reset. Three time-history triaxial acceleration sensors are provided (2 in Reactor Building, 1 in Auxiliary Building). These sensors transmit electrical signals to be recorded on magnetic tape. The NEIC can confirm seismic activity in the vicinity of the SGS/HCGS site. Refer to Note 4 to contact the NEIC. Alternatively go to the USGS NEIC website: http://earthquake.usgs.gov/eqcenter/ On the US map, click on 'New Jersey' and then click on earthquake indicator for information. The maps are updated within 5 min. of a measured earthquake. Additional Earthquake information can be found on the internet at: o http://www.earthquake.usgs.gov o http://www.mgs.md.gov (click on "Live Earthquake Data online") o http://earthquake.usgs.gov/regional/neic This event escalates to an ALERT under EAL HA1.1 if the earthquake exceeds Operating Basis Earthquake (OBE). levels (0.1g). An approximate relationship between acceleration units in gravity and magnitude reported per the Richter scale is as follows: An Acceleration of: is approx. equal to a Richter Scale Magnitude of: 0.01g 4.0 0.02g 4.5 Salem Page 2 of 5 Rev. 0 (draft E) EAL#: H U ]. 1

0.Ig 0.2g 5.5 EP-SC-1 11-207 6.5 Salem Page 3 of 5 Rev. 0 (draft E) EAL#: HUio

SGS ECG - EAL Technical Bases EP-SC-1 11-207 Definitions: PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU1 Example EAL #1
2. UFSAR Table 7.7-3 Seismic Monitoring Instrumentation
3. SC.OP-AB.ZZ-0004(Q) Earthquake
4. S1.OP-AR.ZZ-0001 (Q) OHA A-37 SEIS RCDR SYS ACT
5. UFSAR 2.1.1 Site Location
6. UFSAR 1.2.4 Seismology Salem Page 4 of 5 Rev. 0 (draft E)

EAL#: IH=I U IJ, i

SGS ECG - EAL Technical Bases EP-SC-1 11-207 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#: H U A1

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C-H_- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HU1.2 - UNUSUAL EVENT (Common Site) EAL: Tornado TOUCHING DOWN within the PROTECTED AREA OR Average Wind Speeds > 95 MPH from ANY elevation of the Met Tower Basis: -These-This EALs are-is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators. El O This EAL is based on a tornado str44P49(touching down) within the PROTECTED AREA or high winds onsite W,,ithin the Protected Area. LAthI thc ran of thel nItIumentti ai l r -- nd 1 111 1peed.] Escalation of this emergency classification level, if appropriate, would be based on VISIBLE DAMAG-EDEGRADED PERFORMANCE, or by other in-in-plant conditions, via EAL HA1.2. Explanation/Discussion/Definitions: Average, as used in the EAL threshold, is intended to be the 15 minute rolling average as provided by SPDS and not the instantaneous wind speed. The design wind velocities are 108 mph (including a gust factor of approximately 1.3) at 30 feet above ground. However, the Control Room wind speed only provides indication up to 100 mph so the classification threshold has been capped at 95 mph to allow for onscale indication of wind speed. The manner in which the HCGS SPDS processes data from the meteorological Salem Page 1 of 2 Rev. 0 (draft E) EAL#: ]U1. 2

SGS ECG - EAL Technical Bases EP-SC-1 11 -207 instrumentation differs from the SGS SPDS; consequently, minor differences between HCGS and SGS readings may occur. A tornado touching down within the PROTECTED AREA warrants declaration of an UNUSUAL EVENT regardless of the measured wind speed at the meteorological tower. A tornado is defined as a violently rotating column of air in contact with the ground and extending from the base of a thunderstorm. The National Weather Service can be contacted for further information about existing or projected Adverse Weather Conditions: o Phila/Mount Holly (609) 261-6600 o NWS Web site http://www.erh.noaa.gov/er/phi o Phila/Mount Holly (609) 261-6604 o Phila/Mount Holly (609) 261-6602 Definitions: PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, and paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU1 Example EAL #2
2. UFSAR 3.3.1.1 Design wind Velocity and Loading
3. OP-AA-108-111-1001 Severe Weather and Natural Disaster Guidelines
4. NC.CH-SC.MET-1206(Q) Meteorological Monitoring System Calibration and Maintenance
5. SC.OP-AB.ZZ-0001(Q) Adverse Environmental Conditions Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:H i.l 2

SGS ECG - EAL'Technical Bases EP-SC-1 11-207 EAL Category: C-H_- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HU1.3 - UNUSUAL EVENT EAL: Main Turbine rotating component failures resulting in EITHER of the following: o Main Turbine casing penetration o Main Turbine or Generator Seal Damage Basis: These-This EALs are-is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators. EAL #4 This EAL addresses main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Generator seal damage observed after generator purge does not meet the intent of this EAL because it did not impact normal operation of the plant. Of major concern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs. Actual fires.and flammable gas build up are appropriately classified via EAL HU2.1 and EAL HU3.1. This EAL is consistent with the definition of an UNUSUAL EVENT NQUE while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment. Escalation of this emergency classification level, if appropriate, would be to EAL HA1.3 based on damage done by projectiles generated by the failure or by anythe radiological releases in Category R. for a BWR. Or in.conjunction With St.aM o geqcntG, tube. rU ptre, for a PWR. These latter events would he nlas.ifiod by the radio!ooina! IC> or Fission PrAPund, Rprrier IC._ Explanation/Discussion/Definitions: Salem Page 1 of 2 Rev. 0 (draft E) EAL#: =HU .3

SGS ECG - EAL Technical Bases EP-SC-1 11-207 Main Turbine rotating component failures of sufficient magnitude to cause damage to the turbine casing or turbine/generator seals increases the potential for leakage of combustible/explosive gases and of combustible liquids to the Turbine Building or damage to plant systems due to PROJECTILES. The presence of H 2 gas in sufficient quantities may present a combustion hazard. Actual fires and flammable gas build up is classified under fire and flammable gas EALs. Generator seal damage observed after generator purge does not meet the intent of this EAL since it did not impact normal plant operations. Turbine rotating component failures may also result in other direct damage to plant systems and components. Damage may rupture the turbine lubricating oil system, which would release flammable liquids to the Turbine Building. Potential rupture of the condenser and condenser tubes may cause flooding in the lower levels of the Turbine Building. This damage should be readily observable. Escape of H 2 gas from the generator due to a loss of seal oil pumps or turbine lube oil without a turbine rotating component failure should not be classified under this event but should be reviewed lAW EALs in Subcategory H.3, Hazardous Gas. Definitions: PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability or personnel safety. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU1 Example EAL #4
2. UFSAR 3.5.4 Turbine Missile Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: HUi o3

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HU1.4 - UNUSUAL EVENT EAL: Internal Flooding that has the potential to affect safe shutdown systems or components required by Technical Specifications for the current operating mode in ANY Table H-1 plant structure Table H-I Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control PointArea o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building. o RWST, PWST, and AFWST Area Basis: T-hese-This EALs are is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators. E-AL-#3 This EAL addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: HUI 4

SGS ECG - EAL Technical Bases EP-SC-1 11-207 [Th3e site speric areas ic~ude these aeas that CGn ta s-,,,t Rfl rfFequ4:d fper safe 84hutdew3 oG the plant. which are noet designodl to be partia!!y or fufly submo4r-ged. The plan ta iPE=E-Em~ay pro vide incight into atrcas to be oc-delr-ed whe ndeveiepipg thi EAL] Escalation of this emergency classification level, if appropriate, would be based VISIBLE DAMAGEon DEGRADED PERFORMANCE via EAL HA.4, or by other plant conditions. Explanation/Discussion/Definitions: Flooding as used in this EAL describes a condition where water is entering the room faster than installed equipment is capable of removal, resulting in a rise of water level within the room. Classification of this EAL should not be delayed while corrective actions are being taken to isolate the water source. The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I. Flooding can occur from several sources including the Circulating Water System, Service Water System, Demineralized Water, Component Cooling Water, Fire Protection and Refueling Water Storage Tank. Flooding is determined in these areas by visual report from staff or by confirmation of sump alarms. S1 (S2).OP-AB.ZZ-0002 (Q) directs the operators to determine the exact location and severity of flooding. Attachments in this procedure delineate the affected plant areas, potential source(s) of water, affected vital equipment, flood rate and time to submerge vital equipment. If mitigating actions to control flooding have been unsuccessful and the flooding level has reached 50% of the equipment disabled level(s) as specified in S1(S2).OP-AB.ZZ-0002, FLOODING, then the flooding is severe, is in excess of sump handling capability and has the potential to affect safety equipment and therefore, classification under this EAL is warranted. The source of the flooding and the status of the sump pumps are not factors in evaluating this EAL. For areas that do not have a flooding level specified in Si (S2).OP-AB.ZZ-0002, SM judgment should be used. Definitions: PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, .area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: I=1UiA~

SGS ECG - EAL Technical Bases EP-SC-1 11-207 DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit o Insufficient system pressure from keep-fill pumps o Elevated area temperatures or radiation levels o Increased sump pump operation in areas in which the system is located EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU1 Example EAL #3
2. UFSAR 3.2 Classification of Structures, Components and Systems
3. S1(S2).OP-AB.ZZ-0002 (Q) Flooding Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: *I *A o4

SGS ECG - EAL Technical Bases EP-SC-1 11-207 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: H U I.o4

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HU1.5 - UNUSUAL EVENT (Common Site) EAL: River level > 99.5' OR River level < 80.0' Basis: This =Al= addresses other site specific phenGemea (suc~h aS hurricane, flood, Gr sciche) that can also) be precursors of ,more serious events.See Explanation Section below: Explanation/Discussion/Definitions: The first condition of this EAL indicates river level conditions that can threaten the level of safety of the plant due to flooding. River level greater than 99.5' (+10.5' Mean Sea Level, MSL) is indication of impending site flood conditions. Flood protection measures are required by Salem Technical Specifications and procedure at 99.5'(+1 0.5'MSL). At this river level precautionary actions are taken, including filling outside tanks and ensuring that perimeter flood doors are closed. These actions ensure that the facility flood protection features are in place prior to a river level that would necessitate their use. Hope Creek performs these actions at 95.0' (+6.0'MSL). The High river level threshold is below the river level that would require a plant shutdown. Technical Specification actions required by a River Level of >1 00.5' includes placing the plant in at least Hot Standby within the next 6 hours and in Cold Shutdown within the next 30 hours. This is based on the river level at which facility flood protection features provide protection to safety related equipment. Hope Creek performs similar actions are at 99.5' (+10.5'MSL). The grade level at the Salem station is lower than that for Hope Creek (Salem = 99.5', Hope Creek = 101.5'). Salem Page 1 of 2 Rev. 0 (draft E) EAL#: H U 1. 5

SGS ECG - EAL Technical Bases EP-SC-1 11-207 The second condition of this EAL indicates river level conditions, River level < 80.0' (-9.0'MSL), approaching the loss of the Service Water Intake (Ultimate Heat Sink). The low level threshold indicates a river level condition that is one foot lower than the historical low water level of 81.0' (-8.0'MSL) (December 31, 1962) and is higher than the Service Water pumps design level. These events will be escalated based on damage to plant safety systems, loss of fission product barriers or abnormal radiological releases as discussed in other EAL categories. River level indication is displayed in Unit 1 on LA-8639 which has a range of 70' to 110'. The National Weather Service can be contacted for further information about existing or projected Adverse Weather Conditions: 

   "   Phila/Mount Holly        (609) 261-6600 o   NWS Web site             httip://w\&,,.erh.noaa.gov/er/phi
   "   Phila/Mount Holly        (609) 261-6604 o   Phila/Mount Holly        (609) 261-6602 Definitions:

PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU1 Example EAL #5
2. Technical Specifications 3/4.7.5 Flood Protection
3. UFSAR 2.4 Hydraulic Engineering
4. UFSAR Figure 2.4-3 Service Water Intake
5. UFSAR Figure 3.4-1 Datum and Water Level Relationships
6. S1 (S2).OP-AB.CW-0001 (Q) Circulating Water System Malfunction
7. S!(S2).OP-AB.ZZ-0002(Q) Flooding
8. OP-AA-1 08-111-1001 Severe Weather and National Disaster Guidelines Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:HU ]5

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting V11TAL AREAS Mode Applicability: All EAL# & Classification Level: HAl. 1 - ALERT EAL: Actuation of the Hope Creek OBE Seismic Switch (> 0.1g) has occurred as verified by the Hope Creek Shift Manager AND Earthquake confirmed by ANY of the following: o Earthquake felt in plant by Control Room Operators o National Earthquake Information Center (NEIC) (Note 4) o Control Room indication of DEGRADED PERFORMANCE of safe shutdown systems Note 4: The NEIC can be contacted by calling (303) 273-8500. Select option #1 and inform the analyst you wish to confirm recent seismic activity in the vicinity of Salem/Hope Creek Generating Station. Provide the analyst with the following coordinates: 390 27' 46" (39.4650) north latitude, 750 32' 08" (75.5370) west longitude. Basis: These-This EALs escalates from HUI.1 in that the occurrence of the event has-may have resulted in damage to plant structures or areas containing equipment necessary for a safe shutdown, or has-may have caused damage to the safety systems in those structures evidenced by _Ceontrol R~oom indications of degraded system response or performance. The occurrence of visible-damage and/or degraded system response is intended to discriminate against lesser events. The initial repo.rt should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to.assess the actual magnitude of the damage. The significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation. Salem Page 1 of 5 Rev. 0 (draft E) EAL#: H]A ]o I

SGS ECG - EAL Technical Bases EP-SC-1 11-207 Escalation of this emergency classification level, if appropriate, would be based on System Malfunction ICsEALs. EA~Ls#2 -#5 [These E=ALs should-speci-fsite speific S*-ru-tures ares that contain or9 safety 

                                                                           *Sytem-or Gcomponn andedý                            safe ow of tme pianT. Site specific- fce ShUlteiG'Vv

,Ana4ysis should bece~sultee df- equipment and plant a~reas requirieddto establish or-mintain3 EAL 2! Seismic events of this magnitude can result in a VITAL AREA being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. [This th-eshold should be based o.n site specific FSA R GteS>g9 baSi-s. See ERPR*! ..po.sore "Guidelines for N'uclear-Rlant Rasper,,se to an3 E~ar-th quak"-, dated Oc-tober- 1989, f9r The National Earthquake Information Center can confirm if an earthquake has occurred in the area of the plant. Explanation/Discussion/Definitions: Ground motion acceleration of 0.1g is the Operating Basis Earthquake (OBE) for SGS. As defined in the EPRI-sponsored Guidelines for Nuclear Plant Response to an Earthquake, dated October 1989, a "felt earthquake" is: An earthquake of sufficient intensity such that: (a) the vibratory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of Control Room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated. The NEIC can confirm seismic activity in the vicinity of the SGS/HCGS site. Refer to Note 4 to contact the NEIC. Alternatively go to the USGS NEIC website: http.//earthquake.usgs.govleqcenter/ On the US map, click on 'New Jersey' and then click on earthquake indicator for information. The maps are updated within 5 min. of a measured earthquake. Additional Earthquake information can be found on the internet at: 0 http://www.earthquake.usgs.gov Salem Page 2 of 5 Rev. 0 (draft E) EAL#:HAI.1

SGS ECG - EAL Technical Bases EP-SC-1 11-207 o http://www.mgs.md.gov (click on "Live Earthquake Data online") o http://earthquake.usgs.gov/regional/neic An approximate relationship between acceleration units in gravity and magnitude reported per the Richter scale is as follows: An Acceleration of: is approx. equal to a Richter Scale Magnitude of: 0.01g 4.0 0.02g 4.5 0.1 g 5.5 0.2g 6.5 Definitions: VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability.(e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit o Insufficient system pressure from keep-fill pumps o Elevated area temperatures or radiation levels o Increased sump pump operation in areas in which the system is located PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detectionsystems. Access to the PA requires proper security clearance and is controlled at the Security Center. Salem Page 3 of 5 Rev. 0 (draft E) EAL#: HA*]Ao i

SGS ECG - EAL Technical Bases EP-SC-1 11-207 OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. Salem Page 4 of 5 Rev. 0 (draft E) EAL#: HMAi 1

SGS ECG EALTechnical Bases EP-SC-1 11 -207 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA1 Example EAL #1
2. UFSAR Table 7.7-3 Seismic Monitoring Instrumentation
3. SC.OP-AB.ZZ-0004(Q) Earthquake
4. Sl.OP-AR.ZZ-0001 (Q) OHA A-37 SEIS RCDR SYS ACT
5. UFSAR 2.1.1 Site Location
6. UFSAR 1.2.4 Seismology Salem Page 5 of 5 Rev. 0 (draft E)

EAL#: HAI1A i]

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting VITAL AREAS Mode Applicability: All EAL# & Classification Level: HA1.2 - ALERT EAL: Table H-1 Plant Structures Containing Safe Shutdown Systems or Components 0 Auxiliary Building 0 Service Water Intake Structure 0 Control Point Area 0 Inner/Outer Penetration Areas 0 Containment 0 Fuel Handling Building 0 Service Building 0 RWST, PWST, and AFWST Area Salem Page 1 of 5 Rev. 0 (draft E) EAL#:HAI.2

SGS ECG - EAL Technical Bases EP-SC-1 11-207 Basis: This EAL escalates from EAL HU1.2 in that the occurrence of the event has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by Ceontrol Rroom indications of degraded system response or performance. The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage. The significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation. Escalation of this emergency classification level, if appropriate, would be based on System Malfunction 4G-sEALs. A! W-#2 #5 [These EALs shuld o peci4' Ste .SPe.ific 

                                   ... tr-U tU..      a.a that       , safetySy'SteM, OF Aoafis should                           ipment and plantpa safe shutdown.]

This EAL is based on a tornado -.PýkPý-touching down) or high winds that have caused VISIBLE DAMAGE to structures containing functions or systems required for safe shutdown of the plant. Explanation/Discussion/Definitions:.. Average, as used in the EAL threshold, is intended to be the 15 minute rolling average as provided by SPDS and not the instantaneous wind speed. The design wind velocities are 108 mph (including a gust factor of approximately 1.3) at 30 feet above ground. However, the Control Room wind speed only provides a display up to 100 mph so the classification threshold has been capped at 95 mph to allow for onscale indication of wind speed. The manner in which the HCGS SPDS processes data from the meteorological instrumentation differs from the SGS SPDS; consequently, minor differences between HCGS and SGS readings may occur. The ALERT classification is appropriate if relevant plant parameters indicate that the performance of safety systems has been degraded: No attempt should be made to fully inventory the actual magnitude of the damnage or quaintify' the' degradation of safety system performance prior to declaration of an ALERT under this threshold. The declaration of an ALERT and the activation of the TSC provide the Emergency Coordinator with the resources needed to perform detailed damage assessments. Salem Page 2 of 5 Rev. 0 (draft E) EAL#:HAI=IA2J

SGS ECG - EAL Technical Bases EP-SC-1 11-207 The National Weather Service can be contacted for further information about existing or projected Adverse Weather Conditions: o Phila/Mount Holly (609) 261-6600 o NWS Web site http://www.erh.noaa.gov/er/phi o Phila/Mount Holly (609) 261-6604 o Phila/Mount Holly (609) 261-6602 Definitions: VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit o Insufficient system pressure from keep-fill pumps Elevated area temperatures or radiation levels o Increased sump pump operation in areas in which the system is located PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. Salem Page 3 of 5 Rev. 0 (draft E) EAL#: HAi2

SGS ECG - EAL Technical Bases EP-SC-1 11-207 VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, and paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included. Salem Page 4 of 5 Rev. 0 (draft E) EAL#:HAio2

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA1 Example EAL #2
2. UFSAR 3.3.1.1 Design wind Velocity and Loading
3. UFSAR 3.2 Severe Weather and Natural Disaster Guidelines
4. OP-AA-1 08-111-1001 Severe Weather and Natural Disaster Guidelines
5. NC.CH-SC.MET-1206(Q) Meteorological Monitoring System Calibration and Maintenance
6. SC.OP-AB.ZZ-0001 (Q) Adverse Environmental Conditions Salem Page 5 of 5 Rev. 0 (draft E)

EAL#: HA .2

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting VWTAL AREAS Mode Applicability: All EAL# & Classification Level: HA1.3 - ALERT EAL: Turbine failure-generated PROJECTILES resulting in EITHER of the following: o VISIBLE DAMAGE to ANY Table H-I plant structures o Control Room indication of DEGRADED PERFORMANCE of safe shutdown systems Table H-I Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Basis: These-This EALs escalates from EAL HU1.3 in that the occurrence of the event has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by Ceontrol R-room indications of degraded system response or performance. The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discrirrminate against lesser events. The initial report should not be interpreted as mandating a lenrgthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual Salem Page 1 of 5 Rev. 0 (draft E) EAL#:HA .

SGS ECG - EAL Technical Bases EP-SC-1 11-207 magnitude of the damage. The significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation. Escalation of this emergency classification level, if appropriate, would be based on System Malfunction 1CsEALs. EALs #2 - ,5 rs'-t'f o,,o',' [These EALs sheuldf speaf sitc spe~icw itr-ucturcs Gr areas that conut in safet' system o-Gr cOMPOnont and ffor4R_ Fql._-1A Safe httWGf4EPlt.S6PPrfiSaShdR r ,ta,sic 72 should be c-pu~ fe r _-up 19 aae Platne areas Fau f9 asabs or, ma~t This EAL addresses the threat to safety related equipment imposed by PROJECTILES generated by main turbine rotating component failures. Therefore, this EAL is consistent with the definition of an ALERT in that the potential exists for actual or substantial potential degradation of the level of safety of the plant. Explanation/Discussion/Definitions: Definitions: VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit o Insufficient system pressure from keep-fill pumps Salem Page 2 of 5 Rev. 0 (draft E) EAL#:HAI=JA 3

SGS ECG - EAL Technical Bases EP-SC-1 11-207 o Elevated area temperatures or radiation levels o Increased sump pump operation in areas in which the system is located Salem Page 3 of 5 Rev. 0 (draft E) EAL#: [=]A1 o3

SGS ECG - EAL Technical Bases EP-SC-1 11-207 PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, and paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included. PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability or personnel safety. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA1 Example EAL #4
2. UFSAR 3.5.4 Turbine Missiles Salem Page 4 of 5 Rev. 0 (draft E)

EAL#:HAI.3

SGS ECG - EAL Technical Bases EP-SC-1 11-207 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#: HAI.3

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting VITAL AREAS Mode Applicability: All EAL# & Classification Level: HA1.4 - ALERT EAL: Internal Flooding in ANY Table H-I plant structure AND The Flooding is of a magnitude that results in EITHER of the following: o Indication of DEGRADED PERFORMANCE of a Safety System within a Table H-I Structure. o An Industrial Safety Hazard (Electrical Shock, High Temp, etc.) resulting in access restrictions to operate or monitor Safety System equipment. Table H-I Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Basis: These-ThisEALs escalates from EAL HU1.4 in that the occurrence of the event has resulted in VISIBLE DAMAG*E to -lant+ truc÷tures 

                                     ,. ,     r area- containing equipm et  eceSSar-y for a Safe Salem                                         Page 1 of 5                          Rev. 0 (draft E)

EAL#: HAI o4

SGS ECG - EAL Technical Bases EP-SC-1 11-207 shutdow, or has .aus.d an electrical shock hazard precluding access to plant structures containing safe shutdown systems or components or damage to the safety systems or components in those structures as evidenced by Ceontrol Rroom indications of degraded system response or performance. The lack of access or occurrence of VISIBLE DAMAGE ar4;eý-degraded system response is intended to discriminate against lesser events. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of t-he-any damage. The significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this lack of access or performance degradation. Escalation of this emergency classification level, if appropriate; would be based on System Malfunction 42sEALs. ffs 2 - #5 [These EA's should s'pe~i'f"* spec~ai ctr IrtFUheis or-arcas that contain safe4,&Ety M'-Gno copnetan~d fUnctionerorequired fonr 8-:fbtýh Utdbwp of the plapt. Site &pe~ifiGSafe ShutdoWn This EAL addresses the effect of interhal'flooding caused by events such as component failuresj,-equipment-misalignment, or outage activity-mishaps. It isbased on the DEGRADED PERFORMANCE of systems, or has created industrial safety hazards (e.g., electrical shock) that preclude necessary access to operate or monitor safety equipment. The inability to access, operate or monitor safety equipment relries'entsan* asctual or'Substantial potential degradation of the level of safety of the plant. Flooding as used in this EALdescribes a condition where water is entering the room faster than installed equipment is capable of removal, resulting in a rise of water level within the room. Classification of this EAL should not be delayed while corrective actions are being taken to isolate the water source. Explanation/Discussion/Definitions: Flooding is an event or condition in excess of the available sump pump handling capability (installed or temporary) that results in a condition where water is entering a room faster than it is being removed resulting in a rise in water level within the room. Classification should not be delayed while taking corrective actions to isolate the source of the flooding. This EAL addresses the effects of flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps where flooding is occurring in areas that affect safety related equipment. This EAL is based on the degraded performance of systems, or has created industrial safety hazards (electrical shock) that p reclude necessary access to operate or monitor safety equipment. The inability to access, operate or monitor safety equipment Salem Page 2 of 5 Rev. 0 (draft E) EAL#: Hi~I~AMD

SGS ECG - EAL Technical Bases EP-SC-1 11-207 represents an actual or substantial potential degradation of the level of safety of the plant meeting the definition of an ALERT. In those cases where it is believed that DEGRADED PERFORMANCE due to flooding may have caused damage to a Safety System, an ALERT declaration is warranted since the full extent of the damage need not be known. A Safety System is defined as any system required to maintain safe operation or to establish or maintain Cold Shutdown. If the flooding has reached the level(s) specified in OP-AB.ZZ-0002, FLOODING, then the flooding is severe, is in excess of sump handling capability and has degraded the performance of safety related equipment. Consequently, if the flooding has reached the levels specified in OP-AB.ZZ-0002, Flooding, then classification under this EAL is warranted. The source of the flooding and the status of the sump pumps are not factors in evaluating this EAL. For areas that do not have a Flooding level specified in OP-AB.ZZ-0002, SM judgment should be used. Flooding is determined in these areas by visual report from staff or by confirmation of sump alarms. SI(S2).OP-AB.ZZ-0002 (Q) directs the operators to determine the exact location and severity of Flooding. Attachments in this procedure delineate the affected plant areas, potential source(s) of water, affected vital equipment, flood rate and time to submerge vital equipment. Definitions: VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit o Insufficient system pressure from keep-fill pumps Salem Page 3 of 5 Rev. 0 (draft E) EAL#: VHAI. 4

SGS ECG - EAL Technical Bases EP-SC-1 11-207 o Elevated area temperatures or radiation levels o Increased sump pump operation in areas in which the system is located Salem Page 4 of 5 Rev. 0 (draft E) EAL#: HA=t* .14

SGS ECG - EAL Technical Bases EP-SC-1 11-207 PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA1 Example EAL #3
2. UFSAR 3.2 Classification of Structures, Components and Systems
3. Sl(S2).OP-AB.ZZ-0002 (Q) Flooding Salem Page 5 of 5 Rev. 0 (draft E)

EAL#: HAI= A 4

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting VITAL AREAS Mode Applicability: All EAL# & Classification Level: HA1.6 - ALERT EAL: Vehicle Crash or PROJECTILE Impact with or within ANY Table H-I Structure AND The Vehicle Crash or PROJECTILE Impact results in EITHER of the following: o Control Room indication of DEGRADED PERFORMANCE of a Safety System within Table H-I Structure o VISIBLE DAMAGE to ANY of the plant structures in Table H-I Table H-I Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Basis: These EALs e..calate from HU! in that thc occu*r.ene of the eVent has resulted in VISIBLE IDA MAC E fn nhrd+c~i r'+ir.Qcz rr agn *innrlfl~wnmPt fGI: ;3 S~f eShr tdn~ 9 

                                                                                                                         -.4..-,-. I
                                               .. I - - - - I      -11 .11- 1-1 1- - ý 11 ... I ....        I bul     it! U!    jtj-111
                                  -.7  y. ý--                                                                  , .     . . . .       .   .  .

Salem Page 1 of 5 Rev. 0 (draft E) EAL#: HA 1 o6

SGS ECG - EAL Technical Bases EP-SC-1 11-207 indications of degraded system ýeSPOnse .rmac..or pe.. . The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage. The significance here is not that a particular system or structure incurred damage, but rather that the event was of sufficient magnitude to cause either VISIBLE DAMAGE to the safety systems in Table H-1 structures or Control Room indications of degraded system performance.heMco1j significan.e here is not that a pa.ticular system or structure Was d~am;ag~ed, butn_1 rather, that the eVent wAGs of sufficient magnitude to cause this degradation. Escalation of this emergency classification level, if appropriate, would be based on EALs in Category S. System Malfunctions-Gs. This EAL addresses vehicle crashes or PROJECTILE impacts within the PROTECTED AREA that results in VISIBLE DAMAGE to VITAL AREAS or indication of damage to safety structures, systems, or components containing functions and systems required for safe shutdown of the plant. Explanation/Discussion/Definitions: The primary concern in this EAL is the magnitude of the vehicle crashes/ PROJECTILE impacts. A detailed assessment of system damage is not required prior to classification. Vehicle Crash includes AIRCRAFT, Helicopters, Ships, Barges, Trucks, Autos, or any other vehicle types of sufficient momentum to potentially damage the structure. Minor contacts (not crashes) by onsite vehicles such as trucks, autos, forklifts, etc., are excluded from classification under this EAL. PROJECTILE impact includes flying objects from either offsite or onsite, rotating equipment or turbine failure causing turbine-casing penetration. A Safety System is any system required to maintain safe operation or to establish or maintain cold shutdown. In those cases where it is believed that the vehicle crash/ PROJECTILE impact may have caused VISIBLE DAMAGE to a Safety System, an ALERT declaration is warranted since the full extent of the damage may not be known. The turbine building is not a safety structure and would not be considered for this EAL. No lengthy or time-consuming assessment of damage is required prior to classification. In this EAL, no attempt is made to quantify the magnitude of the damage to any safety system but Salem Page 2 of 5 Rev. 0 (draft E) EAL#: HlAII 6

SGS ECG " EAL Technical Bases EP-SC-1 11-207 instead an attempt is made to identify any damage in order to quantify the magnitude and extent of the vehicle crashes/PROJECTILE impact. In short, if the vehicle crash/ PROJECTILE impact is big enough that it has damaged. a Safety System/Safety Structure or cause Safety System DEGRADED PERFORMANCE, then the vehicle crash! PROJECTILE impact is big enough to justify an ALERT declaration. Any security aspects or suspected HOSTILE ACTIONS that involve vehicles or PROJECTILE impact should be considered under EALs in Subcategory H.4. This event will be escalated based on further damage to plant safety systems, fission product barriers, 0r-bnormal radiation releases. The Emergency Coordinator may use discretion and escalate the classification to a SITE AREA EMERGENCY based on the nature of the damage. Salem Page 3 of 5 Rev. 0 (draft E) EAL#: HA1.

SGS ECG - EAL Technical Bases EP-SC-1 11 -207 Definitions: VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability, or personnel safety. DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit o Insufficient system pressure from keep-fill pumps o Elevated area temperatures or radiation levels o Increased sump pump operation in areas in which the system is located PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. Salem Page 4 of 5 Rev. 0 (draft E) EAL#:HAI.6

SGS ECG - EAL Technical Bases EP-SC-1 11 -207 VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, and paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included. AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate PSEG to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or feloni6us acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OCA). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA1 Example EAL #5
2. UFSAR 3.2 Classification of Structures, Components and'Systems Salem Page 5 of 5 Rev. 0 (draft E)

EAL#: H141 ,(

SGS ECG - EAL Technical Bases EP-SC-1 11-208 EAL Category: C-H_- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 2 - Fire or Explosion Initiating Condition: FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HU2.1 - UNUSUAL EVENT EAL: FIRE NOT extinguished within 15 minutes of EITHER of the following: o Control Room notification/report of a FIRE o Verified FIRE detection system alarm/actuation AND FIRE is located in the Turbine Building or ANY Table H-1 plant structure (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Table H-1 Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Salem Page 1 of 5 Rev. 0 (draft E) EAL#: HU2oIJ

SGS ECG - EAL Technical Bases EP-SC-1 11-208 Basis: This EAL addresses the magnitude and extent of FIRES or EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the FIRE4 EXPLOSION, and not the degradation in performance of affected systems that may result. As used here, detection is visual obserp'etien and report by plant personnel orF sensor 8lr indicatioR. EAL E_,AJi1 2! The 15 minute time pcriod bcgins With a crcdiblc notification that a FIRE is occuFrrin, c indicatioGn* f a FIRE detection system alarm/acuation. VerificatioR o*f a FIRE detectiRn System alarm/atun Yro be te itn the* o-ntrol her nrby site specific Iocatioi to ensure thaot it is no-t spurio-us. An alarm is assumed to be a indi.,tiEo)no*f FIRE u*nSes it is disproved within the 15 minute period by..personel disp..ithd to the scene. in other wors a esne eotfo h cn a e Used te disprove a sensor alarmi received within 1 5 minutes of the alarm, but shall Rnt be reuircd..to verif' the alarm.- The 15 minute time period begins with a credible notification/report that a FIRE is occurring, or upon verification that a FIRE detection system alarm/actuation is due to a FIRE.

a. A credible notificatidn/report to the Control room would be a communications from a member of the plant staff (in-house or contractor) that identifies the observation of a FIRE in a specific location.

NOTE: In this case, the 15 minute clocklto assess the EAL and to extinguish the FIRE runs-concurrently and starts upon Control Room receipt-of the FIRE notification/report.

b. Verification that a FIRE detection system alarm/actuation is due to a FIRE (not a spurious/false alarm) includes either one of the following:
1. Control Room (or other nearby site-specific location) receipt of related independent alarm(s) (FIRE, temperature, deluge, FIRE pump start, etc.)

NOTE: In this case, the 15 minute clock to assess the EAL and to extinguish the FIRE runs concurrently and starts upon receipt of the independent alarm(s) related to the FIRE.

2. On/Near-scene visual confirmation if only a single FIRE/smoke detector has alarmed.

NOTE: In this case, the 15 minute cloc-k to assess the EAL and to extinquish the FIRE runs concurrently and starts upon an on/near-scene confirmation of a FIRE related to the sinqle FIRE/smoke detector that had alarmed. Salem Page 2 of 5 Rev. 0 (draft E) EAL#: H U2.1

SGS ECG - EAL Technical Bases EP-SC-1 11-208 The intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). fThe site.spe.i.GTurbine Building and Table H-1 list sh, ,l -beislimited and applies to buildings and areas in actual contact with or immediately adjacent to VITAL AREAS or other significant buildings or areas. The intent of this I,-EAL is not to include buildings (i.e., warehouses) or areas that are not in actual contact with or immediately adjacent to VITAL AREAS. This excludes FIRES within administration buildings, waste-basket FIRES, and other small FIRES of no safety consequence. Immediately adjacent implies that the area immediately adjacent contains or may contain equipment or cabling that could impact equipment located in VITAL AREAS or the FIRE could damage equipment inside VITAL AREAS or that precludes access to VITAL AREAS.] EAL-ff22 This EAL addresses on. ,those Eo=XpiLOSIOS of SUffici.nt force to damage Per-=ne;;t Structures Gor _-qi';pR'me*nt wvithin the PROTECT-ED AREA.- No attempt is made to assess the ac-tual magnitude of the damage. The occU1Frreneof the EXPLOSION is sufficient for declarationi. The 'me.gen.Y dir*e*Gc9 aso Reoods

  • to cosider anoy security aspects of the EXPLOSION, if applicable.

Escalation of this emergency classification level, if appropriate, would be based on EAL HA2.1. Explanation/Discussion/Definitions: The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category 1. Definitions: PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. Salem Page 3 of 5 Rev. 0 (draft E) EAL#: HIU 2o1

SGS ECG - EAL Technical Bases EP-SC-1 11-208 VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectlyendanger the public health and safety by exposure to radiation. FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU2 Example EAL #1
2. UFSAR 3.2 Classification of Structures, Components and Systems Salem Page 4 of 5 Rev. 0 (draft E)

EAL#:HU .

SGS ECG - EAL Technical Bases EP-SC-1 11-208 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#: H U2o1

SGS ECG - EAL Technical Bases EP-SC-1 11-208 EAL Category: G-H_- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 2 - Fire or Explosion Initiating Condition: FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HU2.2 - UNUSUAL EVENT EAL: EXPLOSION within the PROTECTED AREA Basis: This EAL addresses the magnitude and extent of FIRES or EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the FIRE EXPLOSION, and not the degradation in performance of affected systems that may result. used hcre, detectionis visual obsep.'ation and repGot by plant personnel or seno*r alarm 

    **AIs inRdication.

EAL 2! The! 5 minute time perio.d beginS W.th a credible no.tification that a FIRE is ocrG,. orG irn.-Ati- of 

            -A   fiFe deteGti* n system alarrm/actuatioR. Verification of a fire detectio-,n                           ,ystem alarm/actuation inc-ludes actions that caR            be taken within the coRnrl reom or other nearby site specifi*c loation to ensure that it is *ot spurious. An alarm is assum.ed t. be a indicatien                               of    a FIRE un*ess it is disproved within the 1 5 minute period by personnel dispatched to the scene.

in other words, a person.nel ep. from. the scene may be used to disprove a sensor alarm if received within 1 5 *inutes of the alarm,totbut shall be required to verify the alarm. The intent of this 15 m duration is to size the FIRE and to discriminate against smal 

                                 ,inute FIRES that are readily extinguished (e.g., smol'dering Waste paper basket).

[TeSt pe~4 8 sEudbe4*e and ap~ste bul,43 st aRC' area 43atiatwt sh-d 't, -n s, hef4 thiS !C is net to9 includ1e b Uid44gs- 0.e., eeuss or-ameas that are /39t in ac-tual contactwG or immediately a6*a cent to VITAL AREAS. This excTludes F/RES within administration bui.digs,. waste baske t FIRES. and ether small F!oREES of no safetY G.nsequence. MAediate4, a j=7*t Gqti7 r aGGt4 Salem Page 1 of 2 Rev. 0 (draft E) EAL#: H U 2.2

SGS ECG - EAL Technical Bases EP-SC-1 11-208 equiprnt -9r-Gabling that Geu.d impact eq .. .. p..t÷atetdin VITAL AREAS or the fire Gc-ld da...age eq .... rnn;,d VITAL AREAS "r that Pr.ecl d', a..... to VITAL AREAS] This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA. No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration. The Emergency directer Coordinator also needs to consider any security aspects of the EXPLOSION, if applicable. Escalation of this emergency classification level, if appropriate, would be based on EAL HA2.2. Explanation/Discussion/Definitions: If the EXPLOSION is determined to be hostile in nature, the event is classified under EAL HS4.1. Definitions: PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU2 Example EAL #2 Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: H=I1U2.2

SGS ECG - EAL Technical Bases EP-SC-11 11-208 EAL Category: G-H_- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 2 - Fire or Explosion Initiating Condition: FIRE or EXPLOSION in a VITAL AREA affecting the operability of plant safety systems required to establish or maintain safe shutdown Mode Applicability: All EAL# & Classification Level: HA2.1 - ALERT EAL: FIRE in ANY Table H-1 plant structure affecting the operability of plant safety systems required to establish or maintain safe shutdown AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Table H-1 Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area 0 Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Salem Page 1 of 5 Rev. 0 (draft E) EAL#: HA2.1

SGS ECG - EAL Technical Bases EP-SC-111-208 Basis: VISIBLE DAMAGE is used to identify the magnitudo of the fire er oxplesien and to disc-,rimrrinate agaiRst mlino*mr fireS and explosions. T-he refGerene to struotwues conitainin~g safet" system s or com;ponents is included to diScriminate against FIRES or explosions in areas having a low probabiity of oaffe-ting Safe e.pea.emn The significance here is not that a safety system was dcgradcd but the fact that the FIRE or EXPLOSION was large enough to cause damage to these systems. The use o-f VISIBLE DAMAGE sho-uld net be interpr-eted as mandating a lengthy damage asse.s.em t prier to classification. The declaration of an ALERT and the activation of the Technical Support Center will provide the Emergency DireetC)F Coordinator with the resources needed to perform detailed damage assessments. 

-The Em:;ergencY                                                                  the Director also nee-s to cnider any.7 Security a-SPeGISef4E-PlyO-SG0-           N,

[Tbia 94L ahouldl speie sifate SpeG.-flG SýtrUctur Gr area a that contain Sa:fctyaS'Stet7, 01 componet a-nd fun c-tiena required for safc hedo of the9 Plant. Site specefifc-safe Shu tdewn

Ana4yaia shou Id be conault4ed for-equiýýpmetadpat are~as requid tG establish or maintain Escalation of this emergency classification level, if appropriate, will be based on EALs in Category S, System Malfunctions, Category F, Fission Product Barrier Degradation, or Category R, Abnormal Rad Levels / Rad i,.-gioal Effluent4Gs.

Explanation/Discussion/Definitions: The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I. Definitions: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, Salem Page 2 of 5 Rev. 0 (draft E) EAL#: HA2oi

SGS ECG - EAL Technical Bases EP-SC-1 11 -208 destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. Salem Page 3 of 5 Rev. 0 (draft E) EAL#: HA2oif

SGS ECG - EAL Technical Bases EP-SC-1 11-208 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA2 Example EAL #1
2. UFSAR 3.2 Classification of Structures, Components and Systems Salem Page 4 of 5 Rev. 0 (draft E)

EAL#: IHA2.I1

SGS ECG - EAL Technical Bases EP-SC-1 11-208 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#: Z2I

SGS ECG - EAL Technical Bases EP-SC-1 11-208 EAL Category: Q-H- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 2 - Fire or Explosion Initiating Condition: FIRE or EXPLOSION in a VITAL AREA affecting the operability of plant safety systems required to establish or maintain safe shutdown Mode Applicability: All EAL# & Classification Level: HA2.2 - ALERT EAL: EXPLOSION in ANY Table H-I plant structure affecting the operability of plant safety systems required to establish or maintain safe shutdown Table H-1 Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Basis: VISIBLE DAMAGE is used to identify the magnitUde Of the firc or e.plo!s;io and to diSoriminate against mineor fires aRd eXPlGosioG-s. The rofo~Ronoc to) structures contain'ingm Safety1SYStems or com;ponents is includedt di So nminate against FIRES or explsosi areas having a low probability of affecting saf-e eperatiGR. The significance here is not that a safety system was.,degraded but the fa*t that the FIRE -r EXPLOSION was large enough to cause damage to these systems. Salem Page 1 of 3 Rev. 0 (draft E) EAL#: HA2.2

SGS ECG - EAL Technical Bases EP-SC-111-208 Thc use o~f VISIBLE DAMAGE sho-uld not be interpreted as mandating a lcngthy damage assessment prior toolssoiaon The declaration of an ALERT and the activation of the Technical Support Center will provide the Emergency Director Coordinator with the resources needed to perform detailed damage assessments. The Emergency Coordinator Direte4r-also needs to consider any security aspects of the EXPLOSION. [This E,4LShG)UldSP9Cify 640eaP9GifiG 8trucGtUrea or-arc cc that Cont#ain3 safaetySyatcrn, O componGent and functionS re-quiroFd for-safq shutdownq of the p/ant. Site specnific Safe Shut~down Ana4ysis shouldl be con sulto d for-equi.prncntand plant areasarcqui.r-ed to c talbish or-maintc-n Escalation of this emergency classification level, if appropriate, will be based on EALs in Category S, System Malfunctions, Category F, Fission Product Barrier Degradation, or Category R, Abnormal Rad Levels / Rad ,,.,.,-,,-Effluent4Qs. Explanation/Discussion/Definitions: If the EXPLOSION is determined to be hostile in nature, the event is classified under EAL HS4.1. The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I. Definitions: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large'quantities of smoke and heat are observed. EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structure's, @systems, or components. VIITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction,or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA). that is enclosed by the security perimeter fence and monitored by intusioh detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. Salem Page 2 of 3 Rev. 0 (draft E) EAL#:HA2o2

SGS ECG - EAL Technical Bases EP-SC-1 11-208 OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA2 Example EAL #1
2. UFSAR 3.2 Classification of Structures, Components and Systems Salem Page 3 of 3 Rev. 0 (draft E)

EAL#: HIA2.2

SGS ECG - EAL Technical Bases EP-SC-1 11-209 EAL Category: C-H_- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 3 - Hazardous Gas Initiating Condition: Release of toxic, corrosive, asphyxiant or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS Mode Applicability: All EAL# & Classification Level: HU3.1 - UNUSUAL EVENT EAL: Release of toxic, corrosive, asphyxiant or flammable gas in amounts (excluding small or incidental releases) that have or could adversely affect NORMAL PLANT OPERATIONS Basis: This EAL is based on the release of toxic, corrosive, asphyxiant or flammable gases of sufficient quantity to affect normal plant operations. The fact that SCBA or other respiratory protection may be worn does not eliminate the need to declare the event. This I-G-EAL is not intended to require significant assessment or quantification. It assumes an uncontrolled process that has the potential to affect NORMAL PLANT OPERATIONS. This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation. An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death. Escalation of this emergency classification level, if appropriate, would be based on EAL HA3.1. Explanation/Discussion/Definitions: The release may have originated within the Site Boundary, or it may have originated offsite and subsequently drifted onto the Site Boundary. Offsite events (e.g., tanker truck accident releasing toxic gases, etc.) resulting in the plant being within the evacuation area should also be considered in this EAL because of the adverse affect on NORMAL PLANT OPERATIONS. Salem Page 1 of 4 Rev. 0 (draft E) EAL#:HU3,

SGS ECG - EAL Technical Bases EP-SC-1 11-209 Should the release affect plant VITAL AREAS, escalation to an ALERT would be based on EAL HA3.1. Should an EXPLOSION or FIRE occur due to flammable gas within an affected plant area, an ALERT may be appropriate based on EAL HA2.1 or EAL HA2.2. A Toxic Gas is considered to be any substance that is dangerous to life or limb by reason of inhalation or skin contact. A Flammable Gas is considered to be any substance that can result in an ignition, sustained burn or detonation. Carbon dioxide (C0 2 ) is an asphyxiant gas. A 20 lb C0 2 extinguisher discharge will not create a hazardous atmosphere unless the room volume is less than 2500 cubic feet. A Corrosive Gas is a highly reactive substance that causes obvious damage to living tissue. Corrosives act either directly, by chemically destroying the part or indirectly by causing inflammatioh. Acids and bases are common Corrosive materials. Corrosives such as these are also.sometimes referred to as caustics . .. This EAL should not be construed to include confined spaces that must be ventilated prior to entry or situations involving the fire department personnel who are using respiratory equipment during the performance of their duties unless it also affects personnel not involved with the fire department activates. In addition, those situations that.require personnel to wear respiratory protection equipment as the result of airborne contamination as required by Radiation Protection personnel do'not meet the.. intent of this EAL. Definitions: NORMAL PLANT OPERATIONS: Activities at the plant site associated with routine testing, maintenance, or equipment operations, in accordance with normal operating or administrative procedures. Entry into abnormal or emergency operating procedures, or deviation from normal security or radiological controls posture, is a departure from NORMAL PLANT OPERATIONS. VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components,. or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by P SEG Nuclear as part of the Salem & Hope Creek Generating Station co mplex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: HUM

SGS ECG - EAL Technical Bases EP-SC-1 11-209 FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. EAL Bases Reference(s): 1, NEI 99-01, Rev. 05, HU3 Example EAL #1 2, OE25324 Alert Declared Due to C02 Fire Extinguisher Discharge Salem Page 3 of 4 Rev. 0 (draft E) EAL#: HJU3o]

SGS ECG - EAL Technical Bases EP-SC-1 11-209 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: [HUMJ. f]

SGS ECG - EAL Technical Bases EP-SC-1 11-209 EAL Category: C-H_- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 3 - Hazardous Gas Initiating Condition: Release of toxic, corrosive, asphyxiant or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS Mode Applicability: All EAL# & Classification Level: HU3.2 - UNUSUAL EVENT (Common Site) EAL: Notification by Local, County, or State Officials for evacuation or sheltering of site personnel based on an off-site gas release event that includes toxic, corrosive, asphyxiant, or flammable gas Basis: "7- 1 : r- A I  : " -j 4. L- - -- I- - - - -r - L- ,: -F1 - L- I X

1 q P ql:ýP. i), 1 11 1 ! ft!ft ý, jA i A 4-Pý4 P PAP. %"P 14 PAT Ar . Pmpl . P r=qpq r-4 I '~ ,-~+rh, +r, c~.r'+ rr-~rL~r, ~ I ric~ rl+/- r~ r~ r~+if, rc~

1--.1 r-*-'*- The fact that SCBA or other respiratory protection may be worn does not eliminate the need to declare the event. This IC is not inRteRded to reqUire SigRificant aSSessmeRnt or qulaRtifi-ation. it assumes an Uncontrolled proe)Gss that has the Potenrtiai tG affeet-pant oper-ations. This vould preclude om,~r ~I ~ I rslannýc nrr rprpqqp I * + , Arr v ir'1- r-'+qc'+r, rrpcnr lprlr~A, ,r ,-pI-i .. . I.. operation. An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death. Escalation of this emergency classification level, if appropriate, would be based on EAL HA3.1. Explanation/Discussion/Definitions: This EAL is based on the existence of an uncontrolled release originating offsite and local, county or state officials have reported the need for evacuation or sheltering of site personnel. Salem Page 1 of 5 Rev. 0 (draft E) EAL#:nU .

SGS ECG - EAL Technical Bases EP-SC-111-209 State and local officials may determine the evacuation area for an offsite spill or release by using "The Emergency Response Guidebook (ERG2008)" developed by the US Department of Transportation. Should the release affect plant VITAL AREAS, escalation to an ALERT would be based on EAL HA3.1. Should an EXPLOSION or FIRE occur due to flammable gas within an affected plant area, an ALERT may be appropriate based on EAL HA2.1. A Toxic Gas is considered to be any substance that is dangerous to life or limb by reason of inhalation or skin contact. A Flammable Gas is considered to be any substance that can result in an ignition, sustained burn or detonation. Carbon dioxide (CO 2 ) is an asphyxiant gas. A 20 lb. CO 2 fire extinguisher discharge will not create a hazardous atmosphere unless the room volume is less than 2500 cu.ft. A Corrosive Gas is a highly reactive substance that causes obvious damage to living tissue. Corrosives act either directly, by chemically destroying the part or indirectly by causing inflammation. Acids and bases are common corrosive materials. Corrosives such as these are also sometimes referred to as caustics. Definitions: NORMAL PLANT OPERATIONS: Activities at the plant site associated with routine testing, maintenance, or equipment operations, in accordance with normal operating or administrative procedures. Entry into abnormal or emergency operating procedures, or deviation from normal security or radiological controls posture, is a departure from NORMAL PLANT OPERATIONS. VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could .directly or indirectly endanger the public health and safety by exposure to radiation. PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and iriward towards the stations is considered the OCA. FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of Salem Page 2 of 5 Rev. 0 (draft E) EAL#: HU3o2

SGS ECG - EAL Technical Bases EP-SC-1 11-209 flame is preferred but is NOT required if large quantities of smoke and heat are observed. EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. Salem Page 3 of 5 Rev. 0 (draft E) EAL#:HU3.2

SGS ECG - EAL Technical Bases EP-SC-111-209 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU3 Example EAL #2
2. The Emergency Response Guide (ERG2008)
3. OE25354 Alert Due to CO 2 Fire Extinguisher Discharge Salem Page 4 of 5 Rev. 0 (draft E)

EAL#: HU3o2

SGS ECG - EAL Technical Bases EP-SC-1 11-209 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#: H UJ3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-209 EAL Category: Q-H- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 3 - Hazardous Gas Initiating Condition: Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shut down the reactor Mode Applicability: All EAL# & Classification Level: HA3.1 -ALERT EAL: Access to ANY Table H-1 plant structure is prohibited due to toxic, corrosive, asphyxiant, or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shut down the reactor (Note 5) Note 5: If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should NOT be declared as it will have NO adverse impact on the ability of the plant to safely operate or safely shut down beyond that already allowed by Technical Specifications at the time of the event. Table H-1 Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Basis: Gases in a VITAL AREA can affect the ability to safely operate or safely shut down the reactor. Salem Page 1 of 4 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-209 The fact that SCBA or other respiratory protection may be worn does not eliminate the need to declare the event. Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases. This could be based upon documented analysis, indication of personal ill effects from exposure, or operating experience with the hazards. Ifthe equipment i* the stated area was already inoperable, cr o.ut o.f se.., before the event ocGcue-Pd, then this EAL sho-uldInt be declared as it will haVe no @ad*e*se impact on the ability 

                                               , bey"e- that already allowed by Technical of the plaRt to safely operate or safely shutdo"w Specificatio.S at the time of the event.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death. An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnel injury. Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene - used in welding). This EAL assumes concentrations of flammable gasses which can ignite/support combustion. Escalation of this emergency classification level, if appropriate, will be based on EALs in Category S, System Malfunctions, Category F, Fission Product Barrier Degradation , or Category R, Abnormal Rad Levels / Radieaetive Effluent IGs. Explanation/Discussion/Definitions: This EAL is based on gases that have entered a plant structure in concentrations that could be unsafe for plant personnel and, therefore, preclude access to equipment necessary for the safe operation or safe shutdown of the plant. The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I. A Toxic Gas is considered to be any substance that is dangerous to life or limb by reason of inhalation or skin contact. A Flammable Gas is considered to be any substance that can result in an ignition, sustained burn or detonation. Carbon dioxide (C02) is an asphyxiant gas. A 20 lb C02 extinguisher discharge will not create a hazardous atmosphere unless the room volume is less than 2500 cubic feet. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: HASI.1I

SGS ECG - EAL Technical Bases EP-SC-1 11-209 A Corrosive Gas is a highly reactive substance that causes obvious.damage to living tissue. Corrosives act either directly, by chemically destroying the part or indirectly by causing inflammation. Acids and bases are common corrosive materials. Corrosives such as these are also sometimes referred to as caustics. This EAL should not be. construed to include confined spaces that must be ventilated prior to entry or situations involving the fire department personnel who are using respiratory equipment during the performance of their duties unless it also affects personnel not involved with the fire department activates. In addition, those situations that require personnel to wear respiratory protection equipment as the result of airborne contamination as required by Radiation Protection personnel do not -meet the intent of this EAL. Definitions: VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled'at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose-of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA3 Example EAL #1
2. UFSAR 3.2 Classification of Structures, Components and Systems
3. OE25324 Alert Declared Due to C02 Fire Extinguisher Discharge Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: HAMfl

SGS ECG - EAL Technical Bases EP-SC-1 11-209 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: HA3.1

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant Mode Applicability: All EAL# & Classification Level: HU4.1 - UNUSUAL EVENT (Common Site) EAL: A SECURITY CONDITION that does NOT involve a HOSTILE ACTION as reported by the Security Operations Supervisor or designee (Note 8) OR Receipt of a CREDIBLE/ACTUAL THREAT to Salem or Hope Creek station - (determined by security in accordance with SY-AA-101-132, "Threat Assessment") (Note 8) OR A VALIDATED notification from NRC providing information of a Salem/Hope Creek AIRCRAFT threat (Note 8) NOTE 8: Shift Manager (SM) should implement the Prompt Actions of NC.EP-EP.ZZ-0102, EC Response, Attachment 10, prior to classification of a security emergency. Key Information to obtain from Security Supervision upon SM notification of a security event: 

              "    Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION o    If a HOSTILE ACTION, is location the OCA or PA?

Basis: Security events which do not represent a potential degradation in the level of safety of the plant are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under EAL HA4.1, EAL HS4.1 and EAL HG4.1. Salem Page 1 of 6 Rev. 0 (draft E) EAL#:HU4o]

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 A higher initial classification could be made based upon the nature and timing of the security threat and potential consequences. The Iieesee-Emergency Coordinator-shall consider upgrading the emergency response status and emergency classification level in accordance with the Salem - Hope Creek Security Contingency Plansite's Safeguards C'-tingency Pl!n 

-nd E~mergencY Plan.

E-AL-#-1st Condition (SECURITY CONDITION) Reference is made to site-the specific security shift supervision (Security Operations Supervisor or designee) because these individuals are the designated personnel on-site qualified and trained to confirm that a security event is occurring or has occurred. Training on security event classification confirmation is closely controlled due to the strict secrecy controls placed on the Salem - Hope Creek Security Contingency Plan plant Safeguards C.ntingenc..J Plan. This threshold is based on site spe.ific security pansthe Salem - Hope Creek Security Contingency Plan. Site Speeifi aegua4ds-GG-tin.en..-P 

                                       ...                   Pa2SareThe Salem - Hope Creek Security Contingency Plan is based on guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Security Contingency Plan and ISFSI Program.

EAL4ff22nd Condition (CREDIBLE / ACTUAL THREAT) This threshold is included to ensure that appropriate notifications for the security threat are made in a timely manner. This includes information of a credible threat. Only the site to which the specific threat is made needs declare the Notification of an UNUSUAL EVENT. The determination of CREDIBLE is made through use of information found in Threat Assessment, SY-AA-101-132 site..... Se f . . , , .. Q. EAL-#-33rd Condition (AIRCRAFT Threat) The intent of this part of the EAL is to ensure that notifications for the AIRCRAFT threat are made in a timely manner and that offsite response organization (OROs) and plant personnel are at a state of heightened awareness regarding the credible threat. It is not the intent of this EAL to replace existing non-hostile related EALs involving AIRCRAFT. This EAL is met when a plant (site) receives information regarding an AIRCRAFT threat from NRC. Validation is performed by calling the NRC or by other approved methods of authentication. Only the site to which the specific threat is made need declare the UNUSUAL EVENT. Salem Page 2 of 6 Rev. 0 (draft E) EAL#: [THU4M]

SGS ECG - EAL Technical Bases EP-SC-1 11-210 The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an AIRLINER (AIRLINER is meant to be a large AIRCRAFT with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC. Escalation to ALERT emergency classification level would be via EAL HA4.1 and would be appropriate if the threat involves an AIRLINER within 30 minutes of the plant or a HOSTILE ACTION in the OCA or PA. Explanation/Discussion/Definitions: If the security events do not meet the threshold for an UNUSUAL EVENT classification, they may result in the need to make a non-emergency report per RAL Section 11.7.1 .a, One Hour Non-Emergency Safeguards Event (10 CFR 73.71) as determined by Security per SY-AA-1002, "Safeguards Event Report." Security will be focused on actions to mitigate the security event and will provide the SM with key information as the event progresses. Communications between the SMs and the Security Team Leader should be accurate, concise, and focused on EAL criteria and protection of key target sets. As Security and Operations terminology sometimes differ, clarifying questions should be asked to ensure accurate information exchange. 1 st Condition (SECURITY CONDITION) Page 6 of this EAL Basis is a "Security Contingency Event Summary Table" that indicates which Security Contingency Events could result in Security Supervision determining that a SECURITY CONDOTION exists and therefore an UNUSUAL EVENT classification should be made OR, could result in Security Supervision determining that a HOSTILE ACTION is or has occurred and therefore classification at the ALERT or higher level should be made based on the location (OCA or PA) of the HOSTILE ACTION. 2 nd Condition (CREDIBLE / ACTUAL THREAT) This threshold is included to ensure that threat information from any source which is assessed by security supervision as being a "CREDIBLE/ACTUAL THREAT" is classified as an UNUSUAL EVENT. Only the site to which the specific threat is made needs to declare the UNUSUAL EVENT. For Security Events, Salem and Hope Creek is considered a single site, therefore a "CREDIBLE/ACTUAL THREAT" to either Salem or Hope Creek would affect the entire site and a "Common Site" UE declaration would be made. Timely classification will ensure that Offsite Response Organizations and plant personnel are notified in a timely manner resulting in a state of heightened awareness. Threats are evaluated by security per Threat Assessment, SY-AA-1 01-132. Security threats that do not meet the definition of a "CREDIBLE/ACTUAL THREAT" should be dispositioned lAW Threat Assessment, SY-AA-101-132. Salem Page 3 of 6 Rev. 0 (draft E) EAL#: H U 4ill

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 3 rd Condition (AIRCRAFT Threat) AIRCRAFT threat calls from the NRC should be VALIDATED by use of NRC authentication code or a return call to the NRC Headquarter Operations Center. For security events, Salem and Hope Creek is considered a single site, therefore, a "VALIDATED AIRCRAFT THREAT" to either Salem or Hope Creek would affect the entire site and a "Common Site" UE declaration would be made. Definitions: SECURITY CONDITION: Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION. VALIDATED: AIRCRAFT threat call from the NRC that is confirmed to be authentic. Calls from the NRC are VALIDATED by use of the NRC provided authentication code or by making a return call to the NRC Headquarter Operations Center and confirming threat information with the NRC Operation Officer. AIRCRAFT threat calls from other agencies, NORAD, FAA, or FBI should be VALIDATED by calling the NRC Operations Officer. AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. A large AIRCRAFT is referred to as an AIRLINER. AIRLINER/LARGE AIRCRAFT: Any size or type of AIRCRAFT with the potential for causing significant damage to the plant (refer to the Security Contingency Plan for a more detailed definition). CREDIBLE / ACTUAL THREAT: Is a threat which poses a likely and serious danger to the safe operation of the facility or to site personnel and public safety. HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OCA). Salem Page 4 of 6 Rev. 0 (draft E) EAL#: HU4oif

SGS ECG - EAL Technical Bases EP-SC-1 11-210 OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, the area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security center. PROJECTILE: An object that impacts Salem/Hope Creek that could cause concern for continued operability, reliability, or personnel safety. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU4 Example EAL #1, #2, #3
2. Salem - Hope Creek Security Contingency Plan
3. SY-AA-101-132 Threat Assessment
4. SC.OP-AB.CR-0004(Q) - Security Event
5. SC.OP-AB.CR-0005(Q) - Airborne Threat Salem Page 5 of 6 Rev. 0 (draft E)

EAL#:IU4.]

SGS ECG - EAL Technical Bases E P-SC-1 11-210 Security Contingency Event Summary Table Event Could Event Could Result in Result in Contingency Determination Determination Event of a of a Number SECURITY HOSTILE CONDITION ACTION (UE ONLY) (ALERT or Higher) Yes / No Yes / No 

                   # 1               Yes              Yes
                   # 2               Yes              Yes
                   # 3               Yes               No
                   #4                 No              Yes
                   # 5               Yes              Yes
                   # 6                No              No
                   # 7                No              No
                   # 8               Yes              Yes
                   # 9               Yes              Yes
                   # 10              Yes              Yes
                   # 11              Yes              No
                   # 12              Yes              No
                   # 13              Yes              No
                   # 14              Yes              No
                   # 15              Yes              No
                   # 16              Yes              Yes
                   # 17              Yes              Yes
                   # 18               No              Yes
                   # 19              Yes              Yes
                   # 20              Yes              No Salem                               Page 6 of 6                     Rev. 0 (draft E)

EAL#: [HU4° J

SGS ECG - EAL Technical Bases EP-SC-1 11-210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat Mode Applicability: All EAL# & Classification Level: HA4.1 - ALERT EAL: A HOSTILE ACTION is occurring or has occurred within the OCA as reported by the Security Operations Supervisor or designee (Note 8) OR A VALIDATED notification from NRC of a AIRLINER attack threat < 30 minutes away from Salem/Hope Creek (Note 8) NOTE 8: Shift Manager (SM) should implement the Prompt Actions of NC.EP-EP.ZZ-0102, EC Response, Attachment 10, prior to classification of a security emergency. Key Information to obtain from Security Supervision upon SM notification of a security event: 

               "    Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION o    If a HOSTILE ACTION, is location the OCA or PA?

Basis: These-This EALs addresses the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. They are not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements. The fact that the site is under serious attack or is an identified attack target with minimal time available for further preparation or additional assistance to arrive requires a heightened state of readiness and implementation of protective measures that can be effective (such as on-site evacuation, dispersal or sheltering). Salem Page 1 of 6 Rev. 0 (draft E) EAL#:HA .

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 EA4 #- 4 t 1 st Condition (OCA HOSTILE ACTION) This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION within or directed towards the OWNER CONTROLLED AREA (OCA). It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small AIRCRAFT impact, hunters, or physical disputes between employees within the OWNER CONTROLLED AREAOCAOGA. Those events are adequately addressed by other EALs or RALs Note that this EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes the ISFSI, .oated within Salem/Hope reek Q-ROTECTED AREA. If not previously notified by the NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, although not certain, that notification by an appropriate Federal agency would follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. However, the declaration should not be unduly delayed awaiting Federal notification. EAL422nd Condition (AIRLINER Threat) This EAL addresses the immediacy of an expected threat (AIRLINER) arrival or impact on the site within a relatively short time (< 30 minutes). The intent of this EAL is to ensure that notifications for the AIRLINER attack threat are made in a timely manner and that OROs and plant personnel are at a state of heightened awareness regarding the credible threat. AIRLINER is meant to be a large AIRCRAFT with the potential for causing significant damage to the p4atsite. This EAL is met when a plant receives information regarding an AIRLINER attack threat from NRC and the AIRLINER is within 30 minutes of the plant. Only the site to which the specific threat is made need declare the ALERT. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an AIRLINER (AIRLINER is meant to be a large AIRCRAFT with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC. Salem Page 2 of 6 Rev. 0 (draft E) EAL#: =*4o1

SGS ECG - EAL Technical Bases EP-SC-1 11-210 Explanation/Discussion/Definitions: This event will be escalated to a SITE AREA EMERGENCY based upon HOSTILE ACTION affecting the PROTECTED AREA (PA). Also, if Hope Creek declares an SAE due to their PA being affected by the security event, Salem will escalate to SAE to match them. 1 st Condition (OCA HOSTILE ACTION) Reference is made to the specific security shift supervision (Security Operations Supervisor or designee) because these individuals are the designated personnel on-site qualified and trained to confirm that a HOSTILE ACTION is occurring or has occurred. This EAL condition is not premised solely on adverse health effects caused by a radiological release. Rather the issue is the immediate need for assistance due to the nature of the event and the potential for significant and indeterminate damage. Although nuclear plant security officers are well trained and prepared to protect against HOSTILE ACTION, it is appropriate for Offsite Response Organizations (OROs) to be notified and encouraged to begin activation to be better prepared should it be necessary to consider further actions. Page 6 of this EAL Basis is a "Security Contingency Event Summary Table" that indicates which Security Contingency Events could result in Security Supervision determining that a HOSTILE ACTION is or has occurred and therefore classification at the ALERT or higher level should be made based on the location (OCA or PA) of the HOSTILE ACTION. Security events that do not involve a HOSTILE ACTION may result in Security Supervision determining that a SECURITY CONDITION exists and therefore an UNUSUAL EVENT classification should be made per EAL HU4.1. 2 nd Condition (AIRLINER Threat) The fact that the site is an identified attack candidate with minimal time available for further preparation requires a heightened state of readiness and implementation of protective measures that can be effective (onsite evacuation, dispersal, or sheltering) before arrival or impact. This EAL is met when a plant receives VALIDATED information regarding an AIRLINER attack threat from NRC and the AIRLINER is less than 30 minutes away from the site. Only the site (Salem and Hope Creek is considered a single site for Security event classifications) to which the specific threat is made needs declare the ALERT. AIRLINER threat calls from the NRC should be VALIDATED by use of NRC authentication code or a return call to the NRC Headquarter Operations Center. Salem Page 3 of 6 Rev. 0 (draft E) EAL#: [H]A4.1

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 Definitions: HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA). OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. A large AIRCRAFT is referred to as an AIRLINER. AIRLINER/LARGE AIRCRAFT: Any size or type of AIRCRAFT with the potential for causing significant damage to the plant (refer to the Security Contingency Plan for a more detailed definition). SECURITY CONDITION: Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION. PROJECTILE: An object directed toward Salem/Hope Creek that could cause concern for its continued operability, reliability, or personnel safety. Salem Page 4 of 6 Rev. 0 (draft E) EAL#: HA4o.

SGS ECG - EAL Technical Bases EP-SC-1 11-210 VALIDATED: AIRCRAFT threat call from the NRC that is confirmed to be authentic. Calls from the NRC are VALIDATED by use of the NRC provided authentication code or by making a return call to the NRC Headquarter Operations Center and confirming threat information with the NRC Operation Officer. AIRCRAFT threat calls from other agencies, NORAD, FAA, or FBI should be VALIDATED by calling the NRC Operations Officer. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA4 Example EAL #1, #2
2. Salem - Hope Creek Security Contingency Plan
3. SC.OP-AB.CR-0004(Q) - Security Event
4. SC.OP-AB.CR-0005(Q) - Airborne Threat Salem Page 5 of 6 Rev. 0 (draft E)

EAL#: HA4o1]

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 Security Contingency Event Summary Table Event Could Event Could Result in Result in Contingency Determination Determination Event of a of a Number SECURITY HOSTILE CONDITION ACTION (UE ONLY) (ALERT or Higher) Yes / No Yes / No 

                   # 1               Yes              Yes
                   # 2               Yes              Yes
                   #3                Yes               No
                   #4                No               Yes
                   #5                Yes              Yes
                   #6                No                No
                   #7                No                No
                   #8                Yes              Yes
                   #9                Yes              Yes
                   #10               Yes              Yes
                   # 11              Yes               No
                   # 12              Yes               No
                   #13               Yes               No
                   # 14              Yes               No
                   # 15              Yes               No
                   # 16              Yes              Yes
                   # 17              Yes              Yes
                   # 18              No               Yes
                   # 19              Yes              Yes
                   # 20              Yes               No Salem                               Page 6 of 6                     Rev. 0 (draft E)

EAL#: H*.4o

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: HOSTILE ACTION within the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HS4.1 - SITE AREA EMERGENCY EAL: A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the Security Operations Supervisor or designee (Note 8) NOTE 8: Shift Manager (SM) should implement the Prompt Actions of NC.EP-EP.ZZ-0102, EC Response, Attachment 10, prior to classification of a security emergency. Key Information to obtain from Security Supervision upon SM notification of a security event: 

              "    Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION o    If a HOSTILE ACTION, is location the OCA or PA?

Basis: This condition represents an escalated threat to plant safety above that contained in the ALERT in that a HOSTILE FORCE has progressed from the OWNER CONTROLLED AREA to the PROTECTED AREA. This EAL addresses the contingency for a very rapid progression of events due to a HOSTILE ACTION within or directed towards the PROTECTED AREA (PA). Plant VITAL AREAS are within the PROTECTED AREA and are generally controlled by card key readers. A HOSTILE ACTION in the PROTECTED AREA (which includes VITAL AREAS) could represent a situation that threatens the safety of plant personnel and the aeneral nublic. Salem Page 1 of 6 Rev. 0 (draft E) EAL#: HS4.1*

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 These EALs address the contingency for a very rapid proqression of events, -.such as that experienced on September 11, 2001. It is not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements. The fact that the site is under serious attack with minimal time available for further preparation or additional assistance to arrive requires Offsite Response Organization (ORO) readiness and preparation for the implementation of protective measures. This EAL addresses the potential foF a very rapid progesson.. of events due to a HOSTILE ACTION.-I-t-is not intended to address incidents that are accidental events or acts of civil disobedience, such as small AIRCRAFT impact, hunters, or physical disputes between employees within the PROTECTED AREA. Those events are adequately addressed by other EALs or RALs. [Although nuclear plant security officers are well trained and prepared to protect against HOSTILE ACTION, it is appropriate for OROs to be notified and encouraged to begin preparations for public protective actions (if they do*nt normaly* to be better prepared should it be necessary to consider further actions.] [If not previously notified by NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, although not certain, that notification by an appropriate Federal agency would follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. However, the declaration should not be unduly delayed awaiting Federal notification.] Escalation of this emergency classification level to a GENERAL EMERGENCY, if appropriate, would be based upon the actual loss of physical control of the facility. If necessary, Salem will declare this event.on aGtual plant status after impact or progression of a,,o,. Explanation/Discussion/Definitions: The Security Shift Supervision is defined as the Security Operations Supervisor or designee. These individuals are the designated on-site personnel qualified and trained to confirm that a security event is occurring or has occurred. Training on security event classification confirmation is closely controlled due to the strict secrecy controls placed on the Salem - Hope Creek Security Contingency Plan (Safeguards) information. PROJECTILES that are directed into or that have impacted the PA from the OCA or beyond are considered under this EAL as HOSTILE ACTIONS within the PA. Salem Page 2 of 6 Rev. 0 (draft E) EAL#: IH3]4.1*]

SGS ECG - EAL Technical Bases EP-SC-1 11-210 Page 5 of this EAL Basis is a "Security Contingency Event Summary Table" that indicates which Security Contingency Events could result in Security Supervision determining that a HOSTILE ACTION is or has occurred and therefore classification at the ALERT or higher level should be made based on the location (OCA or PA) of the HOSTILE ACTION. Security events that do not involve a HOSTILE ACTION may result in Security Supervision determining that a SECURITY CONDITION exists and therefore an UNUSUAL EVENT classification should be made per EAL HU4.1. Definitions: HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OCA). OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. SECURITY CONDITION: Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION. AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. A large AIRCRAFT is referred to as an AIRLINER. Salem Page 3 of 6 Rev. 0 (draft E) EAL#: HS4.iJ

SGS ECG - EAL Technical Bases EP-SC-1 11-210 AIRLINER/LARGE AIRCRAFT: Any size or type of AIRCRAFT with the potential for causing significant damage to the plant (refer to the Security Contingency Plan for a more detailed definition). PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability, or personnel safety. VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA4 Example EAL #1, #2
2. Salem - Hope Creek Security Contingency Plan
3. SC.OP-AB.CR-0004(Q) - Security Event
4. SC.OP-AB.CR-0005(Q) - Airborne Threat Salem Page 4 of 6 Rev. 0 (draft E)

EAL#: H314.1

SGS ECG - EAL Technical Bases EP-SC-1 11-210 Security Contingency Event Summary Table Event Could Event Could Result in Result in Contingency Determination Determination Event of a of a Number SECURITY HOSTILE CONDITION ACTION (UE ONLY) (ALERT or Higher) Yes / No Yes / No 

                       # 1             Yes               Yes
                       #2              Yes               Yes
                       # 3             Yes                No
                       #4               No               Yes
                       # 5             Yes               Yes
                       #6               No                No
                       # 7              No                No
                       # 8              Yes              Yes
                       # 9              Yes              Yes
                       #10              Yes              Yes
                       # 11             Yes               No
                       # 12             Yes               No
                       # 13             Yes               No
                       # 14             Yes               No
                       # 15             Yes               No
                       # 16             Yes               Yes
                       # 17             Yes               Yes
                       # 18             No                Yes
                       # 19             Yes               Yes
                       # 20             Yes               No Salem                                Page 5 of 6                    Rev. 0 (draft E)

EAL#: I""4. 1

SGS ECG - EAL Technical Bases EP-SC-I 11 -210 This page intentionally blank Salem Page 6 of 6 Rev. 0 (draft E) EAL#: [H34.1*

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: HOSTILE ACTION resulting in loss of physical control of the facility Mode Applicability: All EAL# & Classification Level: HG4.1 - GENERAL EMERGENCY EAL: A HOSTILE ACTION has occurred such that plant personnel are unable to operate equipment required to maintain safety functions (i.e., reactivity control, RCS inventory, or secondary heat removal) at Salem or Hope Creek (Note 8) OR A HOSTILE ACTION has caused failure of Spent Fuel Cooling Systems and IMMINENT fuel damage is likely at Salem or Hope Creek (Note 8) NOTE 8: Shift Manager (SM) should implement the Prompt Actions of NC.EP-EP.ZZ-0102, EC Response, Attachment 10, prior to classification of a security emergency. Key Information to obtain from Security Supervision upon SM notification of a security event: 

              "    Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION o    If a HOSTILE ACTION, is location the OCA or PA?

Basis: EAL-#! 1st Condition This EAL encompasses conditions under which a HOSTILE ACTION has resulted in a loss of physical control of VTAL AREAS (containing vital equipment or controls of vital equipment) required to maintain safety functions and control of that equipment cannot be transferred to and operated from another location. Salem Page 1 of 5 Rev. 0 (draft E) EAL#: H(4.14i]

SGS ECG - EAL Technical Bases EP-SC-1 11-210 ITypically, these safety functions are reactivity control (ability to shut down the reactor and keep it shutdown), reactor water lcveRCS inventoryl (ability to cool the core), and deca heatsecondary heat removal (ability to maintain a heat sinkremove decay heat). f- a B-WR. The equivalent functions for, a PWR are reactiVity' control, RCS inVento.., and seon-dary heat [Loss of phy,*,al controlcof the contro l room.. remote shutdown cap-ability alone May net prevent the ability to maintain safety func-tionS Per Se.DeSign of the remote*hUtdow* nVca ilit And the locationR of the t.a.Sfe switches 

                                                                                     .       should be taken into) account. Primnary emphasis should be placed en those compoenets and instruments that supply protection fo~r and information about safety functi ens.]

If control of the plant equipment necessary to maintain safety functions can be transferred to another location, then the threshold is not met. EAL-#22nd Condition This EAL addresses failure of spent fuel cooling systems as a result of HOSTILE ACTION if IMMINENT fuel damage is likely, such as when a freshly off loaded reactorF cor.e is in the spent fuelPool. [A freshly Off loaded reactor core is defined by site specific criteria.] Explanation/Discussion/Definitions: Definitions: HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OCA). PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability, or personnel safety. VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, Salem Page 2 of 5 Rev. 0 (draft E) EAL#: [*](.i4if

SGS ECG - EAL Technical Bases EP-SC-1 11-210 destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours. Salem Page 3 of 5 Rev. 0 (draft E) EAL#: [HIG4o

SGS ECG - EAL Technical Bases EP-SC-1 11-210 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HG1 Example EAL #1, #2
2. SC.OP-AB.CR-0004(Q) - Security Event
3. SC.OP-AB.CR-0005(Q) - Airborne Threat Salem Page 4 of 5 Rev. 0 (draft E)

EAL#: [H] A4o I

SGS ECG - EAL Technical Bases EP-SC-1 11-210 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#: HG4oI

SGS ECG - EAL Technical Bases EP-SC-1 11-211 EAL Category: G-H- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 5 - Control Room Evacuation Initiating Condition: Control Room evacuation has been initiated Mode Applicability: All EAL# & Classification Level: HA5.1 - ALERT EAL: Control Room evacuation has been initiated Basis: With the Ceontrol RFoom evacuated, additional support, monitoring and direction through the Technical Support Center and/or other emergency response facilities may be necessary. Inability to establish plant control from outside the Ceontrol Rroom will escalate this event to a SITE AREA EMERGENCY per EAL HS5.1. Explanation/Discussion/Definitions: Control Room evacuation represents a serious plant situation since the degree of plant control at the Remote Shutdown Panel (RSP) is not as complete as from the Control Room. The intent of this EAL is to declare an ALERT when the determination to evacuate the Control Room has been made based on environmental/personnel safety concerns, and the physical process of evacuating the Control Room per Sl(S2).OP-AB.CR-0001(Q), Control Room Evacuation, or Sl(S2).OP-AB.CR-0002(Q) Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room or 4kV Switchgear Room, has commenced. The Shift Manager (SM) determines if the Control Room requires evacuation. Control Room inhabitability may be caused by fire, dense smoke, noxious fumes, bomb threat in or adjacent to the Control Room, or other life threatening conditions. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA5 Example EAL #1
2. Sl(S2).OP-AB.CR-0001(Q) Control Room Evacuation
3. Sl(S2).OP-AB.CR-0002(Q) Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room or 4kV Switchgear Room
4. SC.OP-AB.CR-0003(Q) Control Room Habitability Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: H]A5.1

SGS ECG - EAL Technical Bases EP-SC-I 11-211 This Page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: A .I

SGS ECG - EAL Technical Bases EP-SC-1 11-211 EAL Category: G-H_- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 5 - Control Room Evacuation Initiating Condition: Control Room evacuation has been initiated and plant control CANNOT be established Mode Applicability: All EAL# & Classification Level: HS5.1 - SITE AREA EMERGENCY EAL: Control Room evacuation has been initiated AND Control of the plant CANNOT be established within 15 minutes (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: The intent of this I-t-EAL is to capture those events where control of the plant cannot be reestablished in a timely manner. In this case, expeditious transfer of control of safety systems has not occurred (although fission product barrier damage may not yet be indicated). The intent of the EAL is to establish control of important plant equipment and knowledge of important plant parameters in a timely manner. Primary emphasis should be placed on those components and instruments that supply protection for and information about safety functions. 1ypi4aýl These safety functions are reactivity control (ability to shutdown the reactor and maintain it shutdown), reactor water !e'evRCS inventory control (ability to cool the core), and de-ay-secondary heat removal (ability to maintain a heat sink)., for a ,WPV. The oguivale,

  • funct-iens for a PWR are reactiVity control, RCS inVcntory, and Second~aRy heat re-moval.

The determination of whether or not control is established at the remote shutdown panel is based on Emergency Dreet9F Coordinator (E-)-judgment. The Emergency Directorr Coordinator is expected to make a reasonable, informed judgment within the site Spe-*i," time f-t4-anfe'allocated 15 minutes that the licensee has control of the plant from the remote shutdown panel. [The Site SP..:,fi t4,-, for transfer is based on anal.s.sio assess,-en.ts as t9 h'.qU.ck!-y f -r, ,e.+ k f ;~, Itc'In 4 r f~k , ~,-, 

                                                                   /

4 

                                                                          /,

41-e,~ -rr,, ^- TI,,e 71 +,%- - , ,c-.I , ,b-W not eXe?(1 P4uteS Wi~tI7'thG tiWa ~"tf~to. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: RM S5o1

SGS ECG - EAL Technical Bases EP-SC-1 11-211 Escalation of this emergency classification level, if appropriate, would be by EALs in Category F, Fission Product Barrier Degradation, or Category R, Abnormal Rad Levels/Radi...giGa. Effluent-EALs. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: H1 5o 1

SGS ECG - EAL Technical Bases EP-SC-1 11-211 Explanation/Discussion/Definitions: The Shift Manager determines if the Control Room is inoperable and requires evacuation. Control Room inhabitability may be caused by fire, dense smoke, noxious fumes, bomb threat in or adjacent to the Control Room, or other life threatening conditions. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HS5 Example EAL #1
2. SI(S2).OP-AB.CR-0001(Q) Control Room Evacuation
3. S1(S2).OP-AB.CR-0002(Q) Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room or 4kV Switchgear Room
4. SC.OP-AB.CR-0003(Q) Control Room Habitability Salem Page 3 of 4 Rev. 0 (draft E)

EAL#:HS5o1

SGS ECG - EAL Technical Bases EP-SC-111-211 This Page inte RtionRally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#:[S] o

SGS ECG - EAL Technical Bases EP-SC-1 11-212 EAL Category: G-H_- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 6 - EC Judgment Initiating Condition: Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of an UNUSUAL EVENT Mode Applicability: All EAL# & Classification Level: HU6.1 - UNUSUAL EVENT EAL: Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. NO releases of radioactive material requiring off-site response or monitoring are expected unless further degradation of safety systems occurs Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director Coordinator to fall under the UNUSUAL EVENT NOUE emergency classification level. Explanation/Discussion/Definitions: None EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU5 Example EAL #1 Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: H]UM(,*

SGS ECG - EAL Technical Bases EP-SC-1 11-212 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: =*1U1 if]

SGS ECG - EAL Technical Bases EP-SC-1 11-212 EAL Category: G-H- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 6 - EC Judgment Initiating Condition: Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of an ALERT Mode Applicability: All EAL# & Classification Level: HA6.1 - ALERT EAL: Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. ANY releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Directer Coordinator to fall under the ALERT emergency classification level. Explanation/Discussion/Definitions: Definitions: HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek plants. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for its continued operability, reliability, or personnel safety. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:HA6.]

EP-SC-1 11-212 Bases SGS ECG - EAL Technical EAL Bases Reference(s): Example EAL #1

1. NEI 99-01, Rev. 05, HA6 Rev. 0 (draft E)

Page 2 of 2 Salem EAL#: HASAI

SGS ECG - EAL Technical Bases EP-SC-1 11-212 EAL Category: G-H_- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 6 - EC Judgment Initiating Condition: Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of a SITE AREA EMERGENCY Mode Applicability: All EAL# & Classification Level: HS6.1 - SITE AREA EMERGENCY EAL: Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. ANY releases are NOT expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency DreeF Coordinator to fall under the emergency classification level description for SITE AREA EMERGENCY. Explanation/Discussion/Definitions: Definitions: HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek plants. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. Salem Page 1 of 2 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11 -212 PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for its continued operability, reliability, or personnel safety. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HS3 Example EAL #1 Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: HSS~o

SGS ECG - EAL Technical Bases EP-SC-1 11-212 EAL Category: 2-H_- Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 6 - EC Judgment Initiating Condition: Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of a GENERAL EMERGENCY Mode Applicability: All EAL# & Classification Level: HG6.1 - GENERAL EMERGENCY EAL: Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Directer Coordinator to fall under the emergency classification level description for GENERAL EMERGENCY. Explanation/Discussion/Definitions: Definitions: HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek plants. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for its continued operability, reliability, or personnel safety. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:HG6,

SGS ECG - EAL Technical Bases EP-SC-1 11-212 IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HG2 Example EAL #1 Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:HGB l

BALs for: Sysktms Ma lfunctions

SGS ECG - EAL Technical Bases EP-SC-1 11-213 EAL Category: S - System Malfunction EAL Subcategory: 1 - Loss of AC Power Initiating Condition: Loss of all offsite AC power to vital buses for 15 minutes or longer Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SUI.1 - UNUSUAL EVENT EAL: Loss of all Offsite AC power to all 4KV Vital Buses AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: Prolonged loss of off-site AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete loss of AC power to emeFge Rny-vital busses. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of off-site power. Explanation/Discussion/Definitions: The AC power distribution is summarized in Attachment 2, page 2. Emergency Classification escalates to an ALERT under EAL SA1.1 based on AC power to 4KV vital buses being reduced to a single source. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05 - SU1 Example EAL #1
2. UFSAR Figure 8.2-2 500 kV Switchyard Diagram
3. UFSAR Figure 8.3-1 Auxiliary Power System Diagram Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: SUIA

SGS ECG - EAL Technical Bases - EP-SC-1 11 -213

4. UFSAR 8.1.1 Utility Grid System and Interconnections
5. UFSAR 8.3.1 Power
6. SGS Technical Specifications 3.8.1 A.C. Sources
7. SGS Technical Specifications 3.8.2 Onsite Power Distribution Systems
8. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
9. 1(2)-EOP-LOPA-1 Loss of All AC Power
10. S1 (S2).OP-AB.LOOP-000! (Q) Loss of Off-Site Power
11. S1 (S2).OP-AB.4KV-0001 (Q) Loss of 1A(2A) 4KV Vital Bus
12. S1 (S2).OP-AB.4KV-0002(Q) Loss of 1B(2B) 4KV Vital Bus
13. S1(S2).OP-AB.4KV-0003(Q) Loss of 1C(2C) 4KV Vital Bus Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: S UMJ]o

SGS ECG - EAL Technical Bases EP-SC-1 11-213 EAL Category: S - System Malfunction EAL Subcategory: 1 - Loss of AC Power Initiating Condition: AC power capability to vital buses reduced to a single power source for 15 minutes or longer such that any additional single failure would result in complete loss of AC power to vital buses 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Mode Applicability: Shutdown EAL# & Classification Level: SAI.1 - ALERT EAL: Loss of 4KV Vital Bus Power Sources (Offsite and Onsite) which results in the availability of only one 4KV Vital Bus Power Source (Offsite or Onsite) AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: I Hu a;;u 6HE? a99Id9 E--,= ~ztR cft  ;;Le:uteu ,uuvu X*~fE I P eS~afcR~t ;r' fu az,64 -LOSS G A /I nl-i ;ta A f-O ,,a 7,, n', ,,no Drary 'F' -in )z A A;-4 7a1""-,#rTi- ,f '9 The condition indicated by this 4,-EAL is the degradation of the off-site and on-site AC power systems such that any additional single failure would result in a complete loss of AC power to vital busesstation blackout. This condition could occur due to a loss of off-site power with a concurrent failure of all but one emergency diesel generator to supply power to its emegeRG vital busses. ARntherr elated conditioen coud be the loss of all es ' ' ad of cn+t emcrgcncy' diesel generators with only one train of emergency busses being fed from offsite 

- Ia      k-   W aA -Fr     +kan   i+ i-n'in                   - +k-'~1a 1-a -i-;k
                                                                                 -        -~an0i+an- a,,,               n 4;-,^,A l geRat_'ort's with only one trainof eme.-gency busses being fed ba"kfed fro                                         Site power..
                                                                                                                  -ff The subsequent loss of this single power source would escalate the event to a SITE AREA EMERGENCY in accordance with EAL SS1.1.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: SAI1 I1

SGS ECG - EAL Technical Bases EP-SC-1 11-213 [At m 'ultiu. it stations, the E.*-L should. allw cr.ed.it for-operation3 of insta*ll d,.'--g, foe tFi-,rc, SUcn aScGF9S 5_cS o-r Si,nc'nG/j%'S pr v d h t ah~norrr~a or-e mer-get3cy oPeFting p a *r 

                               ,     .   . ,r
  • p'n ~ p I ..

pr-~edi~s adlr-ess t bh,ýP HPrý --, ths Ltaten must also Contsider the m1-papt of thi cond~i~tio on other SharedG Safety fUnctionsR- inP dcV610ng thea site sp eeific E4L.1J [PlIants that.haVe a9 pro ed~raizý1ed capability to cr65s tic AC power from an4 o1ff-sitiq powGer of a companionunit may take c-cadit r,9the reduidaptpow4er: sourrce .Qthn ~,t EAe f-, thi÷s-4C" Ex planation/Discussion/Definitions: "Availability" means the power source can be aligned to provide power to a vital bus within 15 minutes or is currently supplying power to at least one vital bus. The availability of EDGs that have not been challenged to start during degradation of AC power sources to the 4KV vital buses should be based on meeting Technical Specification action requirements for loss of offsite AC power sources. The AC power distribution is summarized in Attachment 2, page 2. This hot condition Alert EAL is equivalent to the cold condition Unusual Event EAL CU1.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05 - SA5 Example EAL #1
2. UFSAR Figure 8.2-2 500 kV Switchyard Diagram
3. UFSAR Figure 8.3-1 Auxiliary Power System Diagram
4. UFSAR 8.1.1 Utility Grid System and Interconnections
5. UFSAR 8.3.1 Power.
6. SGS Technical Specifications 3.8.1 A.C. Sources
7. SGS Technical Specifications 3.8.2 Onsite Power Distribution Systems
8. 1(2)-EOP-T.RIP-1 Reactor Trip or Safety Injection
9. 1(2)-EOP-LOPA-1 Loss of All AC Power
10. S1 (S2).OP-AB.LOOP-0001 (Q) Loss of Off-Site Power
11. S1(S2).OP-AB.4KV-0001(Q) Loss of 1A(2A) 4KV Vital Bus
12. S1 (S2).OP-AB.4KV700.Q2(Q) Loss of 1 B(2B) 4KV Vital Bus 13.S1(S2).OP-AB.4KV-0003(Q) Loss of 1C(2C) 4KV Vital Bus Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:SAI .1

SGS ECG - EAL Technical Bases EP-SC-1 11-213 EAL Category: S - System Malfunction EAL Subcategory: 1 - Loss of AC Power Initiating Condition: Loss of all offsite power and all onsite AC power to vital buses for 15 minutes or longer Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SSI.1 - SITE AREA EMERGENCY EAL: Loss of all Power (Onsite and Offsite) to all 4KV Vital Buses AND _ 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: Loss of all AC power to emergeey-vital busses compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink (Service Water). Prolonged loss of all AC power to emergeRy-vital busses will lead to loss of Fuel Clad, RCS, and Containment, thus this event can escalate to a GENERAL EMERGENCY. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of off-site power. r A ÷ýtl,df;rH *s- i n,÷n;f,1r-'nn ÷t.,,,ý r7* A I n.. ,,..*H. on.-.,,, n-* 

                                                                   /In', iJ,.'i ,-i*,q÷#,,,-* -
  • i m, .- *÷-llq.., -. m -

such PS "oce' r C÷v.... dip. ..,.po ide that abnorl-ma!-Fr -e -eyg-'-g conditionq On oth3'r sharrd safcty fun tonR iq:deVeioping-tho ie: -59eoo'cG ,4.] [Plants that have al p uapab!ig'y to oroce 49e A GPower f a off cite power SUPP4,9fa Ui~it R~a'tak IOn nrnj tGFo the r~d;~a#P~r su~- ~ se-EA 1L for this 'C. Salem Page I of 3 Rev. 0 (draft E) EAL#: S si*.l*

SGS ECG - EAL Technical Bases EP-SC-1 11-213 Escalation to GENERAL EMERGENCY is via EALs in Category F, Fission Product Barrier Degradation, or 4--EAL SG1 ..1, "Prolonged Loss of All Off-site Power and Prolonged Loss of All On-site AC Power." Explanation/Discussion/Definitions: The intent of this EAL is to classify degraded AC power events that result in a loss of all offsite 13.8 KV power sources to the 4KV vital buses along with a loss of all onsite power sources (EDGs). The AC power distribution is summarized in Attachment 2, page 2. This hot condition Site Area Emergency EAL is equivalent to the cold condition Alert EAL CA1.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05 - SS1 Example EAL #1
2. UFSAR Figure 8.2-2 500 kV Switchyard Diagram
3. UFSAR Figure 8.3-1 Auxiliary Power System Diagram
4. UFSAR 8.1.1 Utility Grid System and Interconnections
5. UFSAR 8.3.1 Power
6. SGS Technical Specifications 3.8.1 A.C. Sources
7. SGS Technica[ Specifications 3.8.2 Onsite Power Distribution Systems
8. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
9. 1(2)-EOP-LOPA-1 Loss of All AC Power
10. S1 (S2).OP-AB.LOOP-0001 (Q) Loss of Off-Site Power
11. S1 (S2)bOP-AB.4KV-0001 (Q) Loss of 1A(2A) 4KV Vital Bus
12. S1(S2).OP-AB.4KV-0002(Q) Loss of B(2B) 4KV Vital Bus 13.S1(S2).OP-AB.4KV-0003(Q) Loss of 1C(2C) 4KV Vital Bus Salem Page 2 of 3 Rev. 0 (draft E)

EAL#: SS i

SGS ECG - EAL Technical Bases EP-SC-1 11-213 Salem Page 3 of 3 Rev. 0 (draft E) EAL#: SS IlA

SGS ECG - EAL Technical Bases EP-SC-1 11 -213 EAL Category: S - System Malfunction EAL Subcategory: 1 - Loss of AC Power Initiating Condition: Prolonged loss of all offsite and all onsite AC power to vital buses Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SGI.1 - GENERAL EMERGENCY EAL: Loss of all Power (Onsite and Offsite) to all 4KV Vital Buses AND EITHER of the following: o Restoration of at least one Vital Bus in < 4 hrs is NOT likely o CFST Core Cooling RED or PURPLE path exists Basis: Loss of all AC power to emerge n-y-vital busses compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink (Service Water). Prolonged loss of all AC power to eergen*-y-vital busses will lead to loss of Fuel Clad, RCS, and Containment, thus this event can escalate to a GENERAL EMERGENCY. [The (site &pefc-4 heourc) to retreC poweLr a3bbseGtaSielakuGpigan4i Pe-dorrno d 4n 6on forrncince with 10 CFR9 50.6,3 and Regulatory', Guide 1.155. "Station4 Black-out," nc-_~ýial~h A rn rr;nh, -LIli nfijifcnr nffLos , ,f mrnrryn ur), rr, or nn'ruLA t-111,-r4h-,rn-y r-u ( I -* n~u fi ri ru 4 4 Oi l 

    ,-rrunLi  e;-    -          -~c-l-,,) 1r k             ,-'s r          4  -',       Al/   -    s-,     ;

k,-,f /C ' rI-" n i F ii i ru no r'nr.Inri.I*f fns f/th F~iqcz.rn atr-4ssr4 R. ri.-ur IC.,,' 

                                                                                ? itQ if *      *.ý.in    .' ni ~    .....--    J tr   bh frf,tr         ..£ rp f.r.-np ,

rn r-rufl r, ;#,ru flu, ri t, rSn rI rrS rI SI I S S-rI rurIrSfl 1 This 1-GEAL is specified to assure that in the unlikely event of a prolonged station blackout, timely recognition of the seriousness of the event occurs and that declaration of a GENERAL EMERGENCY occurs as early as is appropriate, based on a reasonable assessment of the event trajectory. Salem Page 1 of 5 Rev. 0 (draft E) EAL#: 9 01.1

SGS ECG - EAL Technical Bases EP-SC-1 11-213 The likelihood of restoring at least one emergecy -vital bus should be based on a realistic appraisal of the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions. In addition, under these conditions, fission product barrier monitoring capability may be degraded. Salem Page 2 of 5 Rev. 0 (draft E) EAL#: S G io II

SGS ECG - EAL Technical Bases EP-SC-1 11-213 [Although4 it mePay be d4ifficUlt to pr-9diet when power Gan be r-estor-ed, it is n to g4ve the 

                                                                                           .;~spy E=rnerget~ cy)Direc-tor a r-easonable idea of how quicnkly (s~he m~ay need to deeliare a Genera' E-merýgency based on hA'o majer conSiderationS:
1. Are there any preSent indications that core cooling is already, degraded to the point thai less or potential loexc of Fission Pro;d'c-tBam-er-s is 14MMINE=NT?
2. if there are no0 precent ind~icationsOf SUch core c-ool:ng legr-ad-ation, how !ike4, is it ta power can be restoredl int4rne to assure that a less of twoG bar-r~erwith a poteta los o the thirdl barr4ercan be preVente-d?

Thus, dicatiG of con.tinuin.g *doegra-dati*on,* cor...e.cin. ust be based4 on F.issioýn Rod Banifrer men3itor~ng with pal-14Gular-emphasis on E'~-megpy nDf-ffto~r-Judgment as it relatest IMMI4NENT-loss or-poten~tialloss of fission prod'cntba rr4ers and degradeda b'lit to monto fi'ssion prodluct bar icrs.] Explanation/Discussion/Definitions: The AC power distribution is summarized in Attachment 2, page 2. Four hours is the station blackout coping time. The status and availability of DC power may limit or prevent restoration activities. When prolonged powering of inverters and DC loads has occurred without AC power available for the battery chargers, DC voltage will degrade. This degradation of DC power may limit monitoring and assessment capabilities as instrumentation and control power may not be available. Since monitoring of overall plant conditions will be difficult with no AC power, CFST indications for determining barrier loss are used. The likelihood of restoring at least one Vital Bus should be based on a realistic appraisal of the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions. In addition, under these conditions, fission product barrier monitoring capability may be degraded. Although it may be difficult to predict when power can be restored, it is necessary to give the Emergency Coordinator reasonable idea of how quickly he may need to declare a General Emergency based on two major considerations:

1. Are there any present indications that core cooling is already degraded to the point that loss or potential loss of fission product barriers is imminent?
2. If there are no present indications of such core cooling degradation, how likely is it that power can be restored in time to assure that a loss of two barriers with a potential loss of the third barrier can be prevented?

It is estimated that several hours are required to fully evacuate the 10-mile EPZ. Taking into consideration the above factors, declaring a General Emergency leaves sufficient time for the offsite authorities to implement Protective Actions well before a radioactive release would Salem Page 3 of 5 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-213 occur while providing sufficient time for on-site and off-site mitigation activities to restore AC power. CFST status will not be used for event classification until the Control Room Staff has implemented the CFSTs. The Core Cooling CFST is illustrated in Attachment 2, page 4. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05 - SG1 Example EAL #1
2. UFSAR Figure 8.2-2 500 kV Switchyard Diagram
3. UFSAR Figure 8.3-1 Auxiliary Power System Diagram
4. UFSAR 8.1.1 Utility Grid System and Interconnections
5. UFSAR 8.3.1 Power
6. SGS Technical Specifications 3.8.1 A.C. Sources
7. SGS Technical Specifications 3.8.2 Onsite Power Distribution Systems
8. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
9. 1(2)-EOP-LOPA-1 Loss of All AC Power
10. S1(S2).OP-AB.LOOP-0001(Q) Loss of Off-Site Power
11. S1 (S2).OP-AB.4KV-0001 (Q) Loss of 1A(2A) 4KV Vital Bus
12. S1 (S2).OP-AB.4KV-0002(Q) Loss of 1 B(2B) 4KV Vital Bus
13. S1(S2).OP-AB.4KV-0003(Q) Loss of 1C(2C) 4KV Vital Bus 4-214.UFSAR 3.12.1.1 Conformance to NRC Rule on Station Blackout 1-315.ES-45.003(Q) Station Blackout Duration Calculation 1-416.1(2)-EOP-CFST-1 Critical Safety Function Status Trees - Figure 2 Core Cooling Status Tree 4-517.PSE&G Emergency Operating Procedure Setpoint Document Salem Units 1 & 2 Salem Page 4 of 5 Rev. 0 (draft E)

EAL#: SG 1i

SGS ECG - EAL Technical Bases EP-SC-1 11-213 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#: S(M

SGS ECG - EAL Technical Bases EP-SC-1 11-214 EAL Category: S - System Malfunction EAL Subcategory: 2 - Loss of bC Power Initiating Condition: Loss of all vital DC power for 15 minutes or longer Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SS2.1 - SITE AREA EMERGENCY EAL: <114 VDC bus voltage indications on All 125 VDC vital buses for> 15 minutes (Note 3) OR

  • 25 VDC bus voltage indications on both 28 VDC vital buses for > 15 minutes (Note 3) AND loss of control of Safety Related Equipment from the Control Room has been confirmed Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

Basis: Loss of all DC power compromises ability to monitor and control plant safety functions. Prolonged loss of all DC power will cause core uncovering and loss of containment integrity when there is significant decay heat and sensible heat in the reactor system. [Site specific bus voltage should be base.d on the mi.n-irmn.bus voltag. neessarf*ir the oper-ation of safety related equiprnent. This voltage vaIue soul7 d :n corporate a margin of ai 

             . .. ..... z ..     .... .. .. ..      ..  .  ...i-'       i-"  i... . .............. i i  S JL  id.d... ii~..    Li 1"-   i i.. i..... .       I* ,id i ÷1i
                                                                                                                                                                     , ,.i is u4sua!y n3ear the minimum voltags solo "h d whon ha tForI szi'g is porformed. Typicall the vatse f,ofo th~e enitire   y'~iy.               i-s approxiately 105 battery setSLJj.I~            .di.I~               .       ~l4.~VDC.      Fora6 olsrn fbtoistei
                                                                                                       ~i ~1.~'dyLitL                     i     u     ii~l4~i           i typically 1.891 Volts Per Ceg.]

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Escalation to a General Emergency would occur by EALs in Category R, Abnormal Rad Levels/Radi..egiGa. Effluent, or Category F, Fission Product Barrier Degradation. Explanation/Discussion/Definitions: Salem Page 1 of 3 Rev. 0 (draft E) EAL#:332.]

SGS ECG - EAL Technical Bases EP-SC- 111 -214 The specified bus voltage indications (rounded for readability on Control Room instrumentation) are the minimum voltage requirements for operability of the 125 VDC buses and 28 VDC buses following battery discharge tests. Although continued operation may occur with degraded voltage, these values signify the minimum operable voltages allowed. This Site Area Emergency EAL is the hot condition equivalent of the cold condition loss of DC power Unusual Event EAL CU2.1. Salem Page 2 of 3 Rev. 0 (draft E) EAL#:SS2.1

SGS ECG - EAL Technical Bases EP-SC-1 11-214 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SS3 Example EAL #1
2. SC.MD-ST.125-0004 (Q) 125 Volt Station Batteries 18 Month Service Test and Associated Surveillance Testing Using BCT-2000
3. SC.MD-ST.28D-0004 (Q) 28 Volt Station Batteries 18 Month Service Test and Associated Surveillance Using BCT-2000
4. UFSAR 8.3.2 DC Power
5. SGS Technical Specifications 3.8.2.3 125 Volt DC Distribution - Shutdown
6. SGS Technical Specifications 3.8.2.5 28 Volt DC Distribution - Shutdown
7. S1($2).OP-SO.125-0005 1(2)A 125VDC Bus Operation
8. S1(S2).OP-SO.125-0006 1(2)B 125VDC Bus Operation
9. S1($2).OP-SO.125-0007 1(2)C 125VDC Bus Operation Salem Page 3 of 3 Rev. 0 (draft E)

EAL#: S 2.1]

SGS ECG - EAL Technical Bases EP-SC-1 11-215 EAL Category: S - System Malfunction EAL Subcategory: 3 - ATWT / Criticality Initiating Condition: Inadvertent Criticality Mode Applicability: 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SU3.1 - UNUSUAL EVENT EAL: UNPLANNED sustained positive startup rate observed on nuclear instrumentation Basis: This 4-GEAL addresses inadvertent criticality events. This I-CEAL indicates a potential degradation of the level of safety of the plant, warranting a NGUE classification. This lr-GEAL excludes inadvertent criticalities that occur during planned reactivity changes associated with reactor startups (e.g., criticality earlier than estimated). [This co-ndition.an. be i,,entifcd using priod morator..t..teup m.nito. The tem 

;ýsustah~d"is' usdi n order- to aug"      eKGU~G    of ex'-pete shor terp pG&H 7
                                                                              "L ,  pe Ha r÷ates from plann*ed
              .        o. tro! rod ... vemenits for PWRs and 9Rs (such a& shutdown ban.

withdr-aws! for-P!4'Ps). The se short tetrnj pesitfvc periods-.startu rote ac' the tre rnut of te

nc.ease n neutron population due to isubcr-ttal multipliGc tietn.j Escalation would be by the Fission Product Barrier Table, as appropriate to the operating mode at the time of the event.

Explanation/Discussion/Definitions: The term "sustained" is used in order to allow exclusion of expected short term positive startup rates from planned fuel bundle or control rod movements during core alteration. These short term positive startup rates are the result of the increase in neutron population due to subcritical multiplication. Positive reactor startup rate may be identified by: o Source range startup rate indicators N131 D and N132D o NIS Recorder NR45 o Audio count rate o SPDS o Process Computer Salem Page 1 of 3 Rev. 0 (draft E) EAL#: SU3o I

SGS ECG - EAL Technical Bases EP-SC-1 11-215 This EAL is the hot condition equivalent of the cold condition EAL CU6.1. Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. Salem Page 2 of 3 Rev. 0 (draft E) EAL#: SUM

SGS ECG - EAL Technical Bases EP-SC-1 11-215 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU8 Example EAL #1
2. Technical Specifications 3.3.1.1 Reactor Trip System Instrumentation
3. UFSAR Table 7.5-2 Main Control Room Indicators and/or Recorders Available to Plant Operators to Monitor Significant Plant Parameters During Normal Operations
4. SC.IC-CC.NIS-0011(Q) N31 Source Range
5. SC.IC-CC.NIS-0012(Q) N32 Source Range Salem Page 3 of 3 Rev. 0 (draft E)

EAL#:SU3.1

SGS ECG - EAL Technical Bases EP-SC'1 11-215 EAL Category: S - System Malfunction EAL Subcategory: 3 - ATWT / Criticality Initiating Condition: Automatic trip fails to shut down the reactor and the manual actions taken from the reactor control console are successful in shutting down the reactor Mode Applicability: 1 - Power Operations, 2 - Startup EAL# & Classification Level: SA3.1 - ALERT EAL: An automatic trip failed to shut down the reactor AND Manual trip actions taken at the reactor control console (reactor trip switches, trip bkr bezels, supply breakers 1/2E6D and 1/2G6D) successfully shut down the reactor as indicated by reactor power < 5% Basis: [The reactor should be considered shutdown when it producing less heat than the maximum decay heat load for which the safety systems are designed %,l("'"ly- 3 te-5% power). Fef u6ing

  • plantS.SFSTs, this EAL equates to the criteria used to determine a valid CFST SUbP,,tiei*tyShutdown Marqin Red Path. For BWRs this EAL should be the APRM doWrScale trip setporint Manual serarm (trip) actions taken at the reactor control console are any set of actions by the reactor operator(s) which causes or should cause control rods to be rapidly inserted into the core and shuts down the reactor.
               ...l.:.*;*-
                   . ..* * *M
                            ,* .T
                               .,*  .    . :.   ""."  . .... /* ,::* h F,,"*+*,  .. "..... .. .' .... . . . ."  .'

FTPhe. ma..uaI-s.... 

          ..        s             reactor trip switcheshltO),.                . on the Ceontrol.R-oom console paR4es-are reensiddedan automatic input into the Reactor Protection System-a. A failure to ee8ra,,(trip) after actuating both reactor trip switches withoiut any other auto.atic input. would make this threshold appblicable.j[McDl]

This condition indicates failure of the automatic protection system to scram (trip) the reactor. This condition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient. Thus the plant safety has been compromised because design limits of the fuel may have been exceeded. An ALERT is indicated because conditions may exist that lead to potential loss of fuel clad or RCS and because of the failure of the Reactor Protection System to automatically shutdown the plant. Salem Page 1 of 4 Rev. 0 (draft E3) EAL#:SA3.]

SGS ECG - EAL Technical Bases EP-SC-1 11-215 If manual actions taken at the reactor control console fail to shut-down the reactor, the event would escalate to a SITE AREA EMERGENCY. Explanation/Discussion/Definitions: This EAL identifies the need to cease critical reactor operations by actuation of the automatic Reactor Protection System (RPS) trip function. A reactor trip is automatically initiated by the Reactor Protection System (RPS) when certain continuously monitored parameters exceed predetermined setpoints. Following a successful reactor trip, rapid insertion of the control rods occurs. Nuclear power promptly drops to a fraction of the original power level and then decays to a level several decades less with a negative period. The reactor power drop continues until reactor power reaches the point at which the influence of source neutrons on reactor power starts to be observable. A predictable post-trip response from an automatic reactor trip signal should therefore consist of a prompt drop in reactor power as sensed by the nuclear instrumentation and a lowering of power into the source range. A successful trip has therefore occurred when there is sufficient rod insertion from the trip of RPS to bring reactor power to below 5%, the value used to determine a valid Shutdown Margin Status Tree Red Path. CSFST Shutdown Margin red path is illustrated in Attachment 2, page 5. For the purposes of emergency classification at the Alert level, successful manual trip actions are those which can be quickly performed from the reactor control console (i.e., reactor trip switches, trip bkr bezels, supply breakers 1/2E6D and 1/2G6D). EOP-FRSM-1 requires an Equipment Operator to locally open the Reactor Trip Breakers and trip the Rod Drive MG Sets. These actions are performed outside the Main Control Room and are NOT to be credited as a successful manual trip. Following any automatic RPS trip signal EOPs prescribe insertion of redundant manual trip signals to back up the automatic RPS trip function and ensure reactor shutdown is achieved. Even if the first subsequent manual trip signal fully inserts all control rods immediately after the initial failure of the automatic trip, the lowest level of classification that must be declared is an Alert. In the event that the operator identifies a reactor trip is imminent and initiates a successful manual reactor trip before the automatic trip setpoint is reached, no declaration is required. The successful manual trip of the reactor before it reaches its automatic trip setpoint or reactor trip signals caused by instrumentation channel failures do not lead to a potential fission product barrier loss. If manual reactor trip actions fail to reduce reactor power below 5%, the event escalates to the Site Area Emergency under EAL SS3.1. If by procedure, operator actions include the initiation of an immediate manual trip following receipt of an automatic trip ýsignal and there are no clear indications that the automatic trip failed (such as a time delay following indications that a trip setpoint was exceeded), it may be Salem Page 2 of 4 Rev. 0 (draft E3) EAL#:SA3o1

SGS ECG - EAL Technical Bases EP-SC-1 11-215 difficult to determine if the reactor was shut down because of automatic trip or manual actions. If a subsequent review of the trip actuation indications reveals that the automatic trip did not cause the reactor to be shut down, consideration should be given to evaluating the fuel for potential damage, and the reporting requirements of 10CFR50.72 should be considered for the transient event. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SA2 Example EAL #1
2. UFSAR 7.1.1.1 Reactor Trip Systems
3. UFSAR Table 7.2-1 List of Reactor Trips, Engineered Safety Features, Containment and Steam Line Isolation and Auxiliary Feedwater
4. Technical Specifications Table 3.3-1 Reactor Trip System Instrumentation
5. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
6. 1(2)-EOP-CFST-1 Critical Safety Function status Trees - Figure 1 Shutdown Margin Status Tree
7. 1(2)-7EOP-FRSM-1 Response to Nuclear Power Generation Salem Page 3 of 4 Rev. 0 (draft E3)

EAL#:SA3.1

SGS ECG - EAL Technical Bases EP-SC-1 11-215 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E3) EAL#: SA3.1

SGS ECG - EAL Technical Bases EP-SC-1 11-215 EAL Category: S - System Malfunction EAL Subcategory: 3 - ATWT / Criticality Initiating Condition: Automatic trip fails to shut down the reactor and manual actions taken from the reactor control console are not successful in shutting down the reactor. Mode Applicability: 1 - Power Operations, 2 - Startup EAL# & Classification Level: SS3.1 - SITE AREA EMERGENCY EAL: An automatic trip failed to shut down the reactor AND Manual trip actions taken at the reactor control console (reactor trip switches, trip bkr bezels, supply breakers 1/2E6D and 1/2G6D) do NOT shut down the reactor as indicated by reactor power > 5% Basis: {The reactor should be considered shutdown when i4-producing less heat than the maximum decay heat load for which the safety systems are designed (typially-3 t9-5% power). F-r plantS using CSFSTs, tThis EAL equates to the criteria used to determine a valid CFST SPriti.aity Shutdown Margin Red Path. For BWRs this EAL should be the APRM dnscaleI, trip setpo*"t.] Under these conditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed and efforts to bring the reactor subcritical are unsuccessful. A SITE AREA EMERGENCY is warranted because conditions exist that lead to IMMINENT loss or potential loss of both fuel clad and RCS. [The raac-tor should bie coneidcred shutdcwn4 i ep it pr-dhf~i~g 'is' heat than the Rnax4,mur decay heat !oadfor-Whh:ethe Safc ty cyternS are dee'gned (typically 3 to 5% Power). FoGr 

 /nmfI  taj4 al~ i     ~

LIL=f iQ cI I. n ýnýsfla--tT.-nf fiTrnarV-' -) nr -frinJ-L ~1i tcn /4fi- r I LLI I inn LI M V li ltL IL I IILII .) Red Path. For B/'S this E*AL .shoudbe the APR4d.w..ale trp ,etpof,-,] Manual sGam (trip) actions taken at the reactor control console are any set of actions by the reactor operator(s) at which causes or should cause control rods to be rapidly inserted into the core and shuts down the reactor. conRtrl oe- iSrequire tocAm (trffiDn-ý the reactr. This EAl is still even if Salem Page 1 of 3 Rev. 0 (draft E) EAL#:SS3,

SGS ECG - EAL Technical Bases EP-SC-1 11-215 "ctiRnS taken 

          ÷       Away from the reaGcOtr control -cnSole are succeSsful in shutting the reactor down because the deSign limits of the fuel may have been exceeded or becauýse of the groGss failure of the Reacto~r Protection System to shut-down the plant.

[Althou4gh this 1C may be viewed as redun~dant to the F~ission Proeduct Barrier DegradationIC 48 iG44iG-Ru~o iS Rece&Saryý t9 bet'9 njn ass4, tirn~ ri-en~i 

                                                          ~gnition and OPmFeRGoncy roPe.]e Escalation of this event to a GENERAL EMERGENCY would be due to a prolonged condition leading to an extreme challenge to either core-_cooling or heat removal.

Explanation/Discussion/Definitions: This EAL addresses any automatic reactor trip signal followed by a manual trip that fails to shut down the reactor to an extent the reactor is producing energy in excess of the heat load for which the safety systems were designed. For the purposes of emergency classification at the Site Area Emergency level, successful manual trip actions are those which can be quickly performed from the reactor control console (i.e., reactor trip switches, trip bkr bezels, supply breakers 1(2)E6D and 1(2)G6D). EOP-FRSM-1 requires an Equipment Operator to locally open the Reactor Trip Breakers and trip the Rod Drive MG Sets. These actions are performed outside the Main Control Room and are not to be credited as a successful manual trip. For emergency classification purposes, the reactor should be considered shutdown when it is producing less heat than the maximum decay heat load for which the safety systems are designed. This equates to < 5% power, the value used to determine a valid Shutdown Margin Status Tree Red Path. CSFST Shutdown Margin red path is illustrated in Attachment 2, page 5. Entry into EOP-FRSM-1 will be required if the manual trip from the console "trip handles" or Turbine Trip and P-9 (> 49% Power) is not successful. EOP-FRSM-1 requires an Equipment Operator to locally open the Reactor Trip Breakers and trip the Rod Drive MG Sets. Since this action is outside the Control Room, a successful remote Reactor Trip will still require classification under this EAL because the design limits of the fuel may have been exceeded or because of the gross failure of the RPS to shut down the plant. The threshold value of < 5% reactor power was selected to be consistent with CFST EOP-FRSM-1 entry criteria. Mode 2 is included in this EAL to include events which result in a return to > 5% reactor power from some lower value. Escalation of this event to a GENERAL EMERGENCY would be under EAL SG3.1 or Emergency Coordinator judgment. Definitions: Salem Page 2 of 3 Rev. 0 (draft E) EAL#:S83o

SGS ECG - EAL Technical Bases EP-SC-1 11-215 IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SS2 Example EAL #1
2. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
3. 1(2)-EOP-FRSM-1 Response to Nuclear Power Generation
4. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - Figure 1 Shutdown Margin Status Tree Salem Page 3 of 3 Rev. 0 (draft E)

EAL#:SS3,

SGS ECG - EAL Technical Bases EP-SC-1 11-21 5 EAL Category: S - System Malfunction EAL Subcategory: 3 - ATWT / Criticality Initiating Condition: Automatic trip and all manual actions fail to shut down the reactor and indication of an extreme challenge to the ability to cool the core exists Mode Applicability: 1 - Power Operations, 2 - Startup EAL# & Classification Level: SG3.1 - GENERAL EMERGENCY EAL: An automatic trip failed to shut down the reactor AND All manual actions do NOT shut down the reactor as indicated by reactor power ? 5% AND EITHER of the following: o CFST Core Cooling RED path exists o CFST Heat Sink RED path exists due to actual loss of secondary heat sink and heat sink is required Basis: IThe reactor should be considered shutdown when it producing less heat than the maximum decay heat load for which the safety systems are designed (typ,,ally 3.4,-5% power). F-plaRts using CSFSTs. tThis EAL equates to the criteria used to determine a valid CFST 

    ,,hu.GtiGal.ty-Shutdown Marqin Red Path. Fcr BEARs this EAL should be the A PRM Under these conditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed and efforts to bring the reactor subcritical are unsuccessful.

kob'f f VVf H-H i if f if f if if i I if;(; if I`eSe-ý i it i r4I I* k L.'+,* 1 l r4:,,U 

                               !F  ,'! l .kk'*/ *; L,* 4ý OF  .+k I   r               ......... r-.      ........              ..................

plants using CSFS T-s h-sE4 eq"'---te toP t'he cr/tein ued to determ.'ne a valid Sub iti~a44t I~~~~~~~ 1.4ff 1 1. -11. - I'J.41 - -5 Ia -P1 tI111 V

1. 1-1~ .A,- 15I -5~1.41 - I Ij. 15' L-.II I.j Salem Page 1 of 3 Rev. 0 (draft E)

EAL#:SG3.i

SGS ECG - EAL Technical Bases EP-SC-1 11-215 [Foer PW4I, the 

                   ,     ex.....         Ghap    .... to*h,    abof;÷, ÷,-,      the .o.e i& ,n,,,,ed         to m.ean that the cre   exi tet fna-,            ,r-ao nts      n   or   -*pr-,roaangM      I2f,'l dere     Fraor t/hat th     rerator    vescsel lvata r lain tevb       tehw the            h acive sf         fAel. Fe     piants aSFS using         Th, this EAcL equates to a Cbro Cooling RED ooAnditionA com1bined With a Sub e4riicalty RE=D oon dition.

RP Ao ,j, * .. J.. o CI.,4 

                                      .. ;,4 CU          ÷*   EOP                              u°°.4

[FoerlwRs,p the erassoatIGed e totthe abifity to Go9ithecGoreismelded tosane thet the reactor-ves1selZ e / /e.ah It~a r-qp-gl be ,r9&tot-ed and,manptaiýed above Minimum"R steamq Coofing RtV Wtater Level asdeagrabed in the EoOP bases.F i EMntheRGcNCYdeclarationS the s inabilityf o iiihent thssie eaprl stagesir tl dclaur'atn to p if maximum of-einter , vet ios nSUi nove the aeun of he~~~~~~~~~ yds~nfo atr6ur tlate ste Pm gener-ator-, an exteme c-hallenge should b considered to eaW& Fo-r-plaots u&47g CSIFS T-, this E-Lequae toaGa in ucn~On Gembinedl Aith a SubGertieality REED condeition.] [Fo~r 914VRs, co9ýýsider-atiops ý3Glude iý7abilit to remoeve heat via the main GeordareF 9cr orva the suppr-ession pool or tor-us (e.g., due to high pool water- temperatur-e).] In the event either of these challenges exists at a.time that the reactor has not been brought below the power associated with the safety system design, a core melt sequence exists. In this situation, core degradation can occur rapidly. For this reason, the GENERAL EMERGENCY declaration is intended to be anticipatory of the fission product barrier table' declaration to permit maximum off-site intervention time. Salem Page 2 of 3 Rev. 0 (draft E) EAL#:S(3.i

SGS ECG - EAL Technical Bases EP-SC-1 11-215 Explanation/Discussion/Definitions: For emergency classification purposes, the reactor should be considered shutdown when it is producing less heat than the maximum decay heat load for which the safety systems are designed. This equates to < 5% power, the value used to determine a valid Shutdown Margin Status Tree Red Path. CSFST Shutdown Margin red path is illustrated in Attachment 2, page 5. Entry into EOP-FRSM-1 will be required if the manual trip from the console "trip handle" or Turbine Trip and P-9 (> 49% Power) is not successful. EOP-FRSM-1 requires an Equipment Operator to locally open the Reactor Trip Breakers and trip the Rod Drive MG Sets. Since this action is outside the control room, a successful remote Reactor Trip will require classification under this EAL. The threshold value of 5% reactor power was selected to be consistent with CFST EOP-FRSM-1 entry criteria. For events, which result in a return to > 5% reactor power from some lower value, classification under this EAL would be required. Further degradation is indicated by the occurrence of valid CFST Core Cooling red path or Heat Sink red path. The Core Cooling red path is indicative of a loss of core cooling and the Heat Sink red path of a potential loss of core cooling. CFST status will not be used for event classification until the Control Room Staff has implemented the CFSTs. CFST Core Cooling and CFST Heat Sink are illustrated in Attachment 2 page 4 and 6, respectively. If the Heat Sink red path is due to a procedurally directed action, classification under this EAL is not required. EOP-FRSM-1 directs the operators to minimize feedwater flow to the steam generators in order to minimize cooldown and control reactivity. A heat sink red path is generated as a result of this operator action. However, actual loss of control of the heat sink does not occur due to these actions. In addition, the heat sink red path is precursor to a loss of core cooling and is backed up by the core cooling red path. Declaration of a General Emergency is not justified if the heat sink red path is a result of procedurally directed actions. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SG2 Example EAL #1
2. 1(2)-EOP-FRSM-1 Response to Nuclear Power Generation
3. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
4. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - Figure 1 Shutdown Margin Status Tree
5. PSE&G Emergency Operating Procedure Setpoint Document Salem Units 1 & 2
6. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - Figure 2 Core Cooling Status Tree
7. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - Figure 3 Heat Sink Status Tree Salem Page 3 of 3 Rev. 0 (draft E)

EAL#:SG3o1

SGS ECG - EAL Technical Bases EP-SC-1 11-216 EAL Category: S - System Malfunction EAL Subcategory: 4 - Inability to Reach or Maintain Shutdown Conditions Initiating Condition: Inability to reach required shutdown within Technical Specification limits Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Shutdown EAL# & Classification Level: SU4.1 - UNUSUAL EVENT EAL: Plant is NOT brought to required operating mode within Technical Specifications LCO action statement time Basis: Limiting Conditions of Operation (LCOs) require the plant to be brought to a required operating mode when the Technical Specification required configuration cannot be restored. Depending on the circumstances, this may or may not be an emergency or precursor to a more severe condition. In any case, the initiation of plant shutdown required by the site Technical Specifications requires a four hour report under 10 CFR 50.72 (b) Non-emergency events. The plant is within its safety envelope when being shut down within the allowable action statement time in the Technical Specifications. An immediate NQUE is required when the plant is not brought to the required operating mode within the allowable action statement time in the Technical Specifications. Declaration of a NIQUE is based on the time at which the LCO-specified action statement time period elapses under the site Technical Specifications and is not related to how long a condition may have existed. [Othe.r r-quired Techical lr*SGificGagon ShUtd'owns that inVolve precursors to mor.e Se..O.. event8 are addr.e.Sed by other Sy.tem M* 4,alunc*t*ion. Hazards,or Fission RrodFGu.t-r,;, Degradation !Gs.] Explanation/Discussion/Definitions: Depending on the circumstances, this may or may not be a precursor to a more severe condition. A shutdown required by the Technical Specifications requires a report under 10 CFR 50.72 (b) non-emergency events. The plant is within its safety envelope when actions are completed within the allowable Action Statement time in the T/S. If the times specified within the Action Statements are not met, the plant may be in an unsafe condition. EAL Bases Reference(s): Salem Page 1 of 2 Rev. 0 (draft E) EAL#: SU4.1

SGS ECG - EAL Technical Bases EP-SC-1 11-216

1. NEI 99-01, Rev. 05, SU2 Example EAL #1
2. SGS Technical Specifications This page intentionally blank.

Salem Page 2 of 2 Rev. 0 (draft E) EAL#: SUM4o 1

SGS ECG - EAL Technical Bases EP-SC-1 11 -217 EAL Category: S - System Malfunction EAL Subcategory: 5 - Instrumentation Initiating Condition: UNPLANNED loss of safety system annunciation or indication in the Control Room for 15 minutes or longer Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SU5.1 - UNUSUAL EVENT EAL: UNPLANNED loss of > approximately 75% of Control Room Overhead Annunciators for > 15 minutes (Note 3) OR UNPLANNED loss of > approximately 75% of Control Room Indications associated with the following safety functions for > 15 minutes (Note 3): o Reactivity Control o RCS Inventory o Decay Heat Removal o Fission Product Barriers Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: This IC and its associated EAL are-isintended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. Recognition of the availability of computer based indication equipment is considered-[a&gL 

 ýT W1/4J) Ir-t~ Lt - , '1- 4t .1 t-
"Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.

Salem Page 1 of 5 Rev. 0 (draft E) EAL#: SU5o1

SGS ECG - EAL Technical Bases EP-SC-1 11-217 Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety, system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is mote likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the Specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported-via 10 CFR50.72.- If the shutdown is not in compliance with the Technical Specification action, the NOUE is based on SU4.12-"Inability to Reach Required Shutdown Within Technical Specification Limits." [Site SPEcGifi annunciatorS Or ihdi atorS for thiS EAL 1m"t 43GI'de those identifiqd in the AbPoFbMal Operating Proc~edur-es, 44 th E-mignrgýq Qpe at43g PFroeh4FE?, and ing other E4Ls (e.g., area, press, and/or effluent rad m..nit*... et..). . Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. [Due to the 4mirted number-of safety systems in oper-aton during coGld Shutdoewn, r-e fue!:g, and do fueled,P0deS, Po 1Gs~ Pc4atcG dS ddUring theSe ,ode& Of operation.] This NOUE will be escalated to an ALERT based on a concurrent loss of compensatory indications or a SIGNIFICANT TRANSIENT is occurring during a loss of annunciators/indications. [9ther-regui~ed Technicalý Specification Shutdon-, that precuroors to mor.e. 8.r...o even ts arc alddressed by'oth e Sy'Stem Malfuncl tion, Ha ZardS, Or Fission6 Pro-d-uct Bar-rier Degradation ICs.] Explanation/Discussion/Definitions:- This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. A UNPLANNED loss of most or all Control Room Overhead Annunciators or other key control room safety function indicators without a plant transient in MODES1, 2, 3, or4 for > 15 minutes warrants a heightened awareness by Control Room Operators. Quantification: of > 75% is left to the discretion of the Shift Manager (SM),. and is considered approximately 75%. It is not intended that a detailed dount be performed,'but that a rough approximation be used to determine the severity of the loss. OP-AB.ANN-0001 (Q) details increased monitoring and surveillance requirements as well as alternate indicators. 15 minutes is used as a threshold to exclude transient or momentary Saiem Page 2 of 5 Rev. 0 (draft E) EAL#: 3 U 1o ]

SGS ECG - EAL Technical Bases EP-SC-1 11-217 power losses. The 15 minutes clock starts when the annunciators or other key Control Room safety function indications have been lost, or are determined to have been lost. If upon time of discovery it is determined that the annunciators or key safety function indications have been lost for at least 15 minutes prior to discovery, classification should be made under this EAL regardless of time required for restoration. If it is determined that the annunciators were lost for at least 15 minutes with the annunciators now available at the time of discovery, classification is not required under this EAL, but a review of the "After The Fact" RAL (11.6) should be completed. Salem Page 3 of 5 Rev. 0 (draft E) EAL#:SU5o

SGS ECG - EAL Technical Bases EP-SC-1 11-217 Definitions: UNPLANNED: a parameter change or an event that is. not the result of an intended evolution and requires corrective or mitigative actions. An UNPLANNED loss of annunciators and loss other key control .room indication systems excludes scheduled maintenance and testing activities. SIGNIFICANT TRANSIENT: An UNPLANNED event based on EC judgment, but includes as a minimum any one of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, or (4) Safety Injection Activation. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU3 Example EAL #1
2. S1(S2).OP-AB.ANN-0001(Q) Loss of Overhead Annunciator System
3. UFSAR 7.7.2.10 Plant Alarm and Annunciator Systems
4. UFSAR Table 7.7-2 Overhead Annunciator Groupings Salem Page 4 of 5 Rev. 0 (draft E)

EAL#: S USA

SGS ECG - EAL Technical Bases EP-SC-1 11-217 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#: SUSo

SGS ECG - EAL Technical Bases EP-SC-1 11-217 EAL Category: S - System Malfunction EAL Subcategory: 5 - Instrumentation Initiating Condition: UNPLANNED loss of safety system annunciation or indication in the Control Room with either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SA5.1 - ALERT EAL: UNPLANNED loss of > approximately 75% of Control Room Overhead Annunciators for > 15 minutes (Note 3) OR UNPLANNED loss of > approximately 75% of Control Room Indications associated with the following safety functions for > 15 minutes (Note 3): o Reactivity Control o RCS Inventory o Decay Heat Removal o Fission Product Barriers AND EITHER of the following: o A SIGNIFICANT TRANSIENT is in progress, Table S-1 o Compensatory indications are NOT available per OP-AB.ANN-0001(Q) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Salem Page 1 of 5 Rev. 0 (draft E) EAL#: 345. 1

SGS ECG - EAL Technical Bases EP-SC-1 11 -217 Table S-1 SIGNIFICANT TRANSIENTS o Automatic turbine runback > 25% thermal reactor power o Electrical load rejection > 25% full electrical load o Reactor Trip o Safety Injection Activation Basis: This 4C-EAL is intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a SIGNIFICANT TRANSIENT. r r-)- -- -- 4.'- - -r 4 - - .- ;I :14, , -f -- - - , -ý- - I- - - - -J *- -/:-- 4:_ I :- - - .- J. I,- i F-- ýýi If A ji HHE )f i ul u ltý (2 V, citaulittv ut iýhl --.- 1.." 11 S, pl-Gemputer-, atc-.-)ý "Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities. Quantification is arbitrary, however, it is estimated that if approximately 75% of the-safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift S.u.pe -*,*,, Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation. It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the N-OUE is based on SU2-SU4.1_"Inability to Reach Required Shutdown Within Technical Specification Limits." [-Sit,? S.r,7,-, ........  ; . ..... iP, i t.or÷,-,rc& f ÷prS EAL iR3 * ý,G.,,,e t K e i... , ed,4 I, the k -, o ,* .. .- S~ nmo~s~s> nnrf'cr effk*~nt ~d rnon!tnrs-3 ~- 1 

                                                                                                            "/V Salem                                                                                 Page 2 of 5                                                        Rev. 0 (draft E)

EAL#:SA5oi

SGS ECG - EAL Technical Bases EP-SC-1 11-217 "Compensatory indications" in this context includes computer based information such as the preeess-Plant CeomPputer Ssyst6m and SPDS (see OP-AB.ANN-0001 (Q)). [This should "7 ci" dc a/! GG-_p'- 

                 "cr s"thrn all ablo for this use depending on &pecificplant de sign an-d sbg....*t retro-fi" s If both a major portion of the annunciation system and all computer monitoring are unavailable, the ALERT is required.

[Due to the limited number of safety systemns i.n oper-ation dlurýng cold-shutdown, refueling and efueledrmodes, no !Q is in dcaqtcd dur~g these modles of apertion*.].. Fifteen minutes was selected as a threshold to exclude.transient or momentary power losses. This ALERT will be escalated to a SITE AREA EMERGENCY if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a SIGNIFICANT TRANSIENT in progress during the loss of annunciation or indication. [Other .. .i.., Te*,hpiý.i . pec-ifl-at' 

                                   ',otdov.n.  , .      that
                                                          .  , , ,.. .- CL . &. to m.
                                                             .vGo                             .".t
   'evensare addcs so dby,athor 3yst hr     aifunction, Hazards, or Fis~sion Proqduct Barrne.

Deg adation I s. . Explanation/Discussion/Definitions: OP-AB.ANN-0001(Q):details'increased monitoring and surveillance requirements as well as alternate indicators during a loss of Control Room Overhead Annunciators. The 15. minute clock starts when the annunciators or other key control room safety function indications have been lost, or are determined to have been lost. If upon time of discovery it is determined that the annunciators or key safety function indications have been lost for at least 15 minutes prior to discovery, classification should be made under this EAL regardless of time required.for restoration. SIGNIFICANT TRANSIENTS are listed in Table S-1 and include 'response to automatic or manually initiated functions such as reactor trips, automatic turbine runback greater than 25% thermal reactor power, electrical loaid re.jection greater than 25% full electrical load, or Safety Injection activation. The Plant Computer System and Safety Parameter bDisplay Sy.stem (SPDS) serve as redundant indicators which may be utilized as compensatory measures in lieu of the Control Room Overhead Annunýciators and Control Room indicators associated with safety functions. The judgment of the Shift Manager should be used as the threshold for determining the severity of the plant conditions. If the operating crew cannot monitor the transient in progress, the ALERT escalates to a SITE AREA EMERGENCY under EAL SS5.1. Definitions: Salem Page 3 of 5 Rev. 0 (draft E) EAL#:SA5o

SGS ECG - EAL Technical Bases EP-SC-1 11-217 UNPLANNED: a parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. An UNPLANNED loss of annunciators and loss other key control room indication systems excludes scheduled maintenance and testing activities. SIGNIFICANT TRANSIENT: An UNPLANNED event based on EC judgment, but includes as a minimum any one of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, or (4) Safety Injection Activation. Salem Page 4 of 5 Rev. 0 (draft E) EAL#: SA5iIJ

SGS ECG - EAL Technical Bases EP-SC-1 11-217 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SA5 Example EAL #1
2. S1(S2).OP-AB.ANN-0001(Q) Loss of Overhead Annunciator System
3. UFSAR 7.7.2.10 Plant Alarm and Annunciator Systems
4. UFSAR Table 7.7-2 Overhead Annunciator Grouping Salem Page 5 of 5 Rev. 0 (draft E)

EAL#:S*5ol

SGS ECG - EAL Technical Bases EP-SC-11 11-217 EAL Category: S - System Malfunction EAL Subcategory: 5 - Instrumentation Initiating Condition: Inability to monitor a SIGNIFICANT TRANSIENT in progress 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Mode Applicability: Shutdown EAL# & Classification Level: SS5.1 - SITE AREA EMERGENCY EAL: Loss of > approximately 75% of Control Room Overhead Annunciators for > 15 minutes (Note 3) OR Loss of > approximately 75% of Control Room Indications associated with the following safety functions for > 15 minutes (Note 3): o Reactivity Control o RCS Inventory o Decay Heat Removal o Fission Product Barriers AND A SIGNIFICANT TRANSIENT is in progress, Table S-1 AND Compensatory indications are NOT available per OP-AB.ANN-0001(Q) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Salem Page 1 of 5 Rev. 0 (draft E) EAL#:SS5ol

SGS ECG - EAL Technical Bases EP-SC-1 11-217 Table S-1 SIGNIFICANT TRANSIENTS o Automatic turbine runback > 25% thermal reactor power o Electrical load rejection > 25% full electrical load o Reactor Trip o Safety Injection Activation Basis: This 19-EAL is intended to recognize the threat to plant safety associated with the complete loss of capability of the control room staff to monitor plant response to a SIGNIFICANT TRANSIENT. "Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not a-R aneIGatPg-a_factor.. Quantification is arbitrary, however, it is estimated that ifapproximately 75% of the safety system-annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the-severity of the plant conditions. It is also not intended that the Shift SpeRser*-Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation. It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated'with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical*. Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via10 CFR 50.72. Ifthe shutdown is not in Compliance with the Technical Specification action, the NQUE is based on SIJ2 SU4.1 "Inability to Reach Required Shutdown Within Technical Specification Limits." A SITE AREA EMERGENCY is considered to exist if the Ceontrol Rroom staff cannot monitor safety functions needed for protection of the public while a significant transient is in progress. [eSt ..... ........ P o ,*, r' tis EL .*,,,*ud be lR39,d tG irP,.l,,,4r ,* 'd'-,"dt'fie,d , the Abnor-Mal Oper:ating PrFocedUreS, in bth E43,'erg&Rnc Op cratig Procedures8, and in other EA L (.g., area, pr.eSS.. and/or eff"uent r-ad *monit.s, etc.)] Salem Page 2 of 5 Rev. 0 (draft E) EAL#:

SGS ECG - EAL Technical Bases EP-SC-1 11-217 Site specific indications needed to monitor safety functions necessary for protection of the public must include Coontrol Rmoom indications, computer generated indications and dedicated annunciation capability. [The SpeGfk. ind-i~ations ShouIld be thoSe usedl to determine3 such functions aS The? ability to shut down the re acntor, maintain the Gore cooled, to m~aiptain the r-eactor Goolant sysGtem intact, maintain the spent fuel coo~led, ande to mom ta/nconainen intact.] "Compensatory indications" in this context includes computer based information such as the PGoes-Plant CGomputer Ssystem and SPDS (see OP-AB.ANN-0001(Q)). This should include all computer systems available for this use depending on specific plant design and subsequent retrofits. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. [Due to the limite-d nu4mber-of safety systems/n4 oper:at/on3 during coldl shutdownR, ro fuc::ein gand dofuled4ie mo3(des, noe 4C is indicnate d during these m~edes of op er-ageno~ [Due to the imited numbeF Of Safety *4 &ý' h .. P a.... durin, g col!d 

                                                                    .hutdown,        .. *,,9-g and do fuee~le modeS, Po IC/cS i:(4icatPedd4(4FgtheSe m~d-es- o-foprtn [hreqid TechnicalSpecification shutdwns_ that i*veove pre cursors to more seri           vents ar!e adoe ... d b*y other 2S,,, Moaf co, Haz'r-ds, or. Fission Product g"aSer Dgr-adti ns.]

Explanation/Discussion/Definitions: OP-AB.ANN-0001(Q) details increased monitoring and surveillance requirements as well as alternate indicators during a loss of Control Room Overhead Annunciators. The 15 minute clock starts when the annunciators or other key control room safety function indications have been lost, or are determined to have been lost. If upon time of discovery it is determined that the annunciators or key safety function indications have been lost for at least 15 minutes prior to discovery, classification should be made under this EAL regardless of time required for restoration. SIGNIFICANT TRANSIENTS are listed in Table S-1. The Plant Process Computer System (PPC) and Safety Parameter Display System (SPDS) serve as redundant indicators which may be utilized as compensatory measures in lieu of the Control Room Overhead Annunciators and Control Room indicators associated with safety functions. The judgment of the Shift Manager should be used as the threshold for determining the severity of the plant conditions. Definitions: Salem Page 3 of 5 Rev. 0 (draft E) EAL#: 335o

SGS ECG - EAL Technical Bases EP-SC-1 11-217 UNPLANNED: a parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. An UNPLANNED loss of annunciators and loss other key control room indication systems excludes scheduled maintenance and testing activities. SOGNIFICANT TRANSIENT: An UNPLANNED event based on EC judgment, but includes as a minimum any one of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, or (4) Safety Injection Activation. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SS6 Example EAL #1
2. S1(S2).OP-AB.ANN'0001(Q) Loss of Overhead Annunciator System
3. UFSAR 7.7.2.10 Plant Alarm and Annunciator. Systems
4. UFSAR Table 7.7-2 Overhead Annunciator Grouping Salem Page 4 of 5 Rev. 0 (draft E)

EAL#: 335.]

SGS ECG - EAL Technical Bases EP-SC-1 11 -217 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#:SS5.1

SGS ECG - EAL Technical Bases EP-SC-1 11-218 EAL Category: S - System Malfunction EAL Subcategory: 6 - Communications Initiating Condition: Loss of all onsite or offsite communications capabilities Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SU6.1 - UNUSUAL EVENT EAL: Loss of all Table S-2 Onsite communication methods affecting the ability to perform routine operations OR Loss of all Table S-2 Offsite communication methods affecting the ability to perform offsite notifications Table S-2 Communications Systems System Onsite Offsite Direct Inward Dial System (DID) X X Station Page System (Gaitronics) X Station Radio System X Nuclear Emergency Telephone X System (NETS) Centrex Phone System (ESSX) X NRC (ENS) X Salem Page 1 of 4 Rev. 0 (draft E) EAL#: S ( .U

SGS ECG - EAL Technical Bases EP-SC-1 11-218 Basis: The purpose of this 1C aRnd its associated EALs is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate issues with off-site authorities. [The !oaa of Gff .Site com4municationR abi~ity is expected to be sign~ific-at#4' more compreh on av t*h*n t*e.. nition addressed dby 10 ,R50.72A The availability of one method of ordinary off-site communications is sufficient to inform federal, state, and local authorities of plant problems. This EAL is intended to be used only when extraordinary means (e.g., relaying of information from non-routine radio transmissions, individuals being sent to off-site locations, etc.) are being used to make communications possible. [Site Spe~ig 4t fo GP Site coMMUniCatiGP onal ~U~ neRGMPaSteisofl M 3G t I:r-1~ UIILAI t tL.CI.J"O -' 1 1S.J 1 1-W IItV v'Jf.~ up ' I~pI., c~~r I F.4 K;7~=~ F% C7.' S W~' uy CY ULJI7_UY4 '.4Y 6syatem (Gaitronic-s) and rad~ipa / walkie talkiesa) roGutin el useedfor-operationa.] [Site Spefi' 98t for-9f Sit comPMU~n ratgops les 144ut encompass the 19aa of all meanaptf coGmmunicationa With off aite author~itea. Ths  : houldi include the ENS, coemmercial telephone /lpýn t~e~j~bp~y4ft,-ansMf'Sa:6ha, and d6d1 'cated ~hn yt th~td 69:1/2~~6 oPbf' em~erg9encyPntificat-:onaP.] Explanation/Discussion/Definitions: Onsite and offsite communications include one or more of the systems listed in Table S-2. Direct Inward Dial System (DID) Direct Inward Dial (DID) system is named for the dominant feature of the commercial telephone service provided by the local telephone company for the site. DID allows station telephones to be extensions or tied lines of the same systems. These exchanges can take advantage of backup power supplies provided to the stations, and may use either PSEG microwave, commercial telephone system microwave, or buried cable transmission systems to maintain external communications. This commercial telephone' service is available as an additional backup for the NETS and Centrex/ESSX 1 system. Station Page System (Gaitronics) Gaitronics is a completely transistorized voice communication system with five' voice channels: one page and five party. The system is-design ed for use in extreme environmental conditions such as dust, moisture, heat and noise. The system consists of handsets, speakers and their associated amplifiers. The power for this system is 120 volts AC from an inverted DC source to provide reliable communications during an emergency. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: SU a. ]

SGS ECG - EAL Technical Bases EP-SC-1 11 -218 Station Radio System The Operations and Fire Protection Department UHF radio system is a multi-frequency system used routinely by both station Operations Departments and the Fire Protection Department. When an emergency event is declared, these radio frequencies serve both station Operations Support Centers (OSC). Nuclear Emergency Telephone System (NETS) The Nuclear Emergency Telecommunications System (NETS) is a privately controlled, self-contained telephone exchange that operates as a closed system, not accessible from other phone exchanges. This feature allows the system to be dedicated to emergency response use. The system may use PSEG microwave, commercial telephone system microwave, fiber optics, or buried cable transmission as needed. The exchange switching equipment is maintained at the Environmental & Energy Resource Center (EERC). As an independent system with an uninterruptible power supply, it may operate with or without local phone service or external power. Centrex Phone System (ESSX) The Centrex/Electronic Switch System Exchange 1 (CentrexiESSX 1) is also a privately controlled exchange, which PSEG operates with its own microwave signal system. This system is also independent of local phone service, since each circuit is independently wired. The microwave signal is generated from corporate facilities in Newark, NJ, separated from any local effects of weather or telephone use. The exchange is accessible from other exchanges, but circuits are located only in PSEG facilities. It is considered the primary backup for the NETS system. NRC (ENS) The Emergency Notification System (ENS) is a dedicated communications system with the NRC, which is part of the Federal Telecommunications System (FTS) and consists of direct lines to the NRC. FTS lines are used to provide general accident information. These telephones are installed in the Control Room, TSC, and the EOF. This EAL is the hot condition equivalent of the cold condition EAL CU5.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU6 Example EAL #1, #2
2. PSEG Nuclear Emergency Plan, Section 7
3. UFSAR 9.5.2 Communications System Salem Page 3 of 4 Rev. 0 (draft E)

EAL#:S .1

SGS ECG - EAL Technical Bases EP-SC-1 11-218 This page intentionally blank Salem Page 4of4 Rev. 0 (draft I-) E :a ýIJzý, , . C'L

SGS ECG - EAL Technical Bases EP-SC-1 11-219 EAL Category: S - System Malfunction EAL Subcategory: 7 - Fuel Clad Degradation Initiating Condition: Fuel clad degradation Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SU7.1 - UNUSUAL EVENT EAL: VALID Letdown Line Monitor readings indicating fuel clad degradation greater than EITHER of the following Technical Specification allowable limits: o 1R31A in warning o 2R31 in alarm Basis: This EAL is included because it is a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant. Escalation of this EAL to the ALERT level is via the Fission Product Barriers. E A-L 1 This threshold addresses letdownSite-spe-ific radiation monitor readings that provide indication of a degradation of fuel clad integrity. [Such as BW* air eje.tor monito01-." PWP,, failed fuel mn,,trs, etc.] [Site .p.ifi list for . on ' .. .' s' 't en..o..pa&. the loss 1S8*U".o'7 

                                                          .                           ..        ll means E.f commn,'at~ns e~g. comeria tele p'hion c sound powerý-ed phone Sy'Stems,                   ae at
-system (Girnla)           ad radie-sl w-v4 talkiesa) rcutýn      ýE?4 used for operations.]

[Site &p4.... ;4;. ,8 - ,  ;....... . , . mus 

                                                              .... t.Mn on.. .. the le!!    f a/ ..       of Gco3Pun '~atons        wi:th off site authorities. This shQ,,e in-Gude t~e E=Ns, corn Fia tel               oep lines, telecopy trnC7:a~~,and dledlicated phone systems that are Foeutin,ely used fo9r Gfat Explanation/Discussion/Definitions:

Salem Page 1 of 2 Rev. 0 (draft E) EAL#: SUM

SGS ECG - EAL-Technical Bases EPa-SC-l 11 -219 Letdown Line Monitors serve as a failed fuel detector by monitoring gamma levels in the reactor coolant letdown line. Unit 1 Letdown Line Monitor (1 R31A) is a gross iodine monitor. The Unit 2 Letdown Line Monitor (2R31) is an ion chamber which measures letdown line activity. The Letdown Line Monitor "warning" setpoints are administratively set at 50% of the "alarm" setpoints. o 1R31A "alarm" setpoint is based on 1% failed fuel. The "warning" setpoint represents about 0.5% failed fuel and has been selected because the setpoint would be readily identifiable on Control Room instrumentation. o 2R31 "alarm" setpoint is based on"0. 1% failed fuel. This setpoint is'readily identifiable and also representative of typical values of coolant activity at Technical Specification lim its.

  • Read-outs for these monitors can .be obtained in .the Control Room.

Other radiation monitors that may be used to confirm a valid Letdown Line Monitor alarm include: o 1(2)R4 Charging Pump Room o 1(2)R26 Reactor Coolant Filter o Containment Area Rad Monitors (1(2)R2, 1(2)7, 1(2)1OA, 1(2)10B) Definitions: VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. - .- EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU4 Example EAL #1
2. PSBP 315733 Radiation Monitoring System Manual, Unit 1
3. PSBP 315734 Radiation:Monitoring System Control Manual, Unit 2
4. UFSAR 9.3.5.3 Safety Evaluation (Failed fuel Detection System)
5. UFSAR 11.4 Radiological Monitoring
6. Sl(S2).OP-AB.RC-0002 (Q) High Activity in the Reactor Coolant System Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:SUL 7DI1

SGS ECG - EAL Technical Bases EP-SC-1 11-219 EAL Category: S - System Malfunction EAL Subcategory: 7 - Fuel Clad Degradation Initiating Condition: Fuel clad degradation Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SU7.2 - UNUSUAL EVENT EAL: Basis: This EAL is included because it is a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant. Escalation of this EAL to the ALERT level is via the Fission Product Barriers. EAL-- This threshold addresses coolant samples exceeding coolant technical specifications for transient iodine spiking limits (Technical Specification Figure 3.4-1 ). [Such aS 5BAR air ejector m..nit.S. PV.. failed fuel P30It4OFS. etC-, [Site Specif4c *8tt for on Site cM'..... cat'o8 loSS m2,,ust e.co.mpaSs the loGS o9f a! "mpeanSof coGmmunication (-e.g., com,4mercGial telephones, sound powered phone system~s, page party system (Gaitronilos) and radios./ v'a/ke talkies) rout iae4y used for- oper-ations.] [Site specific-4st for-Off Site commun4icationS leS& must eomasthe 1G88 Of all m~eanS Off communic.ations with off site authities..d.e. Th.is should 43G1 th. E.NS, comRmer.ia tel.ph..O lines. teleGco'py tansm~issionS, and ndediad phonýe systm that are ruin "used for Gffsi'te Explanation/Discussion/Definitions: An Unusual Event is only warranted when actual fuel clad damage is the cause of the elevated coolant sample (as determined by RCS sample analysis confirmation). Escalation to an ALERT or higher emergency classification occurs if a sample analysis of reactor coolant activity exceeds 300 [Ci/gm DEI-131 via EAL FB4-L. Salem Page 1 of 3 Rev. 0 (draft E) EAL#: SU7.2

SGS ECG - EAL Technical Bases EP-SC-1 11 -219 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU4Example EAL #2
2. SGS Technical Specification Section 3.4.8 - Unit 1 Specific Activity
3. SGS Technical Specification Section 3.4.9 - Unit 2 Specific Activity
4. SI(S2).OP-AB.RC-0002(Q) High Activity in Reactor Coolant System Salem Page 2 of 3 Rev. 0 (draft E)

EAL#:SU7.2

SGS ECG - EAL Technical Bases EP-SC-1 11-219 This page intentionally blank Salem Page 3 of 3 Rev. 0 (draft E) EAL#: SU7.2

SGS ECG - EAL Technical Bases EP-SC-1 11-220 EAL Category: S - System Malfunction EAL Subcategory: 8 - RCS Leakage Initiating Condition: RCS Leakage Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SU8.1 - UNUSUAL EVENT EAL: UNIDENTIFIED LEAKAGE or PRESSURE BOUNDARY LEAKAGE > 10 gpm (Note 6) OR IDENTIFIED LEAKAGE > 25 gpm (Note 6) Note 6: See the Fission Product Barrier Table for possible escalation above the UNUSUAL EVENT due to RCS Leakage Basis: This 1,-EAL is included as a NQUE because it may be a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant. The 10 gpm value for the UNIDENTIFIED or PRESSURE BOUNDARY LEAKAGE was selected as it is observable with normal Ceontrol Rfoom indications. Lesser values must generally be determined through time-consuming surveillance tests (e.g., mass balances). Relief valve normal operation should be excluded from this IGEAL. However, a relief valve that operates and fails to close per design should be considered applicable to this IG-EAL if the relief valve cannot be isolated. The EAL for identified leakage is set at a higher value due to the lesser significance of IDENTIFIED LEAKAGE in comparison to UNIDENTIFIED or PRESSURE BOUNDARY LEAKAGE. In either case, escalation of this 4G-EAL to the ALERT level is via Fission Product Barrier Degradation -GsEALs. [Such as B4R ai,rejoctor o,* nitor,1 PW44R faiiod fuel mo.nitors, etc.] M r-t*"  : -;: U r r, q-q-;*. r;(e f:fi :jin f no t. q: p.*:."" q>!' q Iq.*' 

                                                                                                                                    !. q.       q   T 9 ./ rI... - q. n. , TF C~ flfl f-fl~~ ,fl ~fl fi ~-   f-, C'    /N   C' C' f-fl ~    f-C' ;-, I &-~ i-, ~    ~         tfl~~~f-~ ~ ~I A -~J .-. r-. ,-,r%     ~ Jr. tr.

sy'stem (Gaitron3icS) anld radios/~Walkie ta~ia r-eutn~eused fOr eperatien.], Salem Page 1 of 4 Rev. 0 (draft E) EAL#: SUM

SGS ECG - EAL Technical Bases EP."SC-1 11-220 [Site specnf4 list for-off-site comm14unioatiGns loSs muýst enoom1-pas the loss of a!! 'noons of c-*mmuninations with off site author/ite,. This should n helude the ENS, Gommer' 'il tel ehone lines, telecopy trnmsinand doedicatedp 1phon systems tha t roe i-eutie 4 e/use d for ofat Explanation/Discussion/Definitions: RCS Leakage is defined as any leakage of Reactor Coolant this is unisolable or affects Pressurizer level. RCS Leakage of the magnitude described in this EAL is consistent with an Unusual Event classification and should be. declared immediately. The Technical Specification definitions for UNIDENTIFIED LEAKAGE, IDENTIFIED LEAKAGE-and PRESSURE BOUNDARY LEAKAGE are provided below.- Relief valve normal operation (e.g., PZR PORV or safety valves) should be excluded from emergency classification under this EAL. A relief valve that fails to close per design and cannot be isolated from the Control Room, however, should be considered applicable to this EAL. Utilizing the leak before break concept, it is anticipated that there will be indications of minor RCS boundary leakage prior to a fault escalating to a major leak or rupture, Detection of low levels of leakage while pressurized permits monitoring for catastrophic failure or rupture precursors. The Control Room staff is equipped with the Plant Computer (PRIM SYS LEAK RATE program) and manual methods of determining the extent of RCS leakage. Examples of RCS leakage and applicability include: . Example #1: A. rapidly Iover'ing Volume Con'trol Tank (VCT) level is identified during a Radwaste evolution involving the draining of the #12 Mixed Bed Demineralizer (MBD). The Control Room .s.taff identifies the condition and the drain valve on the MBD is closed. Charging. flow has not changed and VCT level is stabilized Within 3 minutes. The calculated leak rate is 73 gpm for 3 minutes. This is not reportable because the leakage did not affect pressurizerlevel and the leak was isolable from the RCS. Note that Tech. Spec limits still apply. Example #2: A Unit 2 RCS leakrate 'calculatioh identified a 30-gpm leak. VCT level has started to drop unexpectedly and enough time has passed that there are minor variations in pressurizer level. The source of the leak is unknown. After about 20 minutes, it was determined that the source of the lealk was the st'em leakoff line from the 2CV55. This event shulud'ebe classified within the 15 minute clock and declared an Unusual. Event even'though-the leak could have been isolated. Any reduction in pressurizer level, which can' be :attributed to a Reactor Coolant System leak should be quantified and the Technical Specification entered and the applicable EAL entered as appropriate. Salem Page 2 of 4ý Rev. 0 (draft E) EAL#:SU8.1

SGS ECG - EAL Technical Bases EP-SC-1 11-220 The use of increasingcharging flow to quantify Reactor Coolant System leakage is acceptable provided there is an actual Reactor Coolant System leak. This could result in a stable pressurizerlevel and should be reviewed against Technical Specifications and the ECG as applicable. If at any time the source of the leakage is unknown and it meets the ECG criteria, the Emergency Coordinatorshould classify the event. Escalation to the ALERT emergency classification level is via EALs in Category F. Note 6 has been added to remind the EAL-user to review the Fission Product Barrier EALs for possible escalation to higher emergency classifications. Definitions: UNIDENTIFIED LEAKAGE: As defined in T/S, shall be all leakage which is not IDENTIFIED LEAKAGE. PRESSURE BOUNDARY LEAKAGE: As defined in T/S, shall be leakage (except steam generator tube leakage) through a non-isolable fault in a Reactor Coolant System component body, pipe wall or vessel wall. IDENTIFIED LEAKAGE: As defined in T/S, shall be leakage (except Reactor Coolant Pump Seal Water Injection) into closed systems, such as pump seal or valve packing leaks that are captured and conducted to a sump or collecting tank, or, shall be leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of the leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE, or, shall be Reactor coolant system leakage through a steam generator to the secondary system (primary-to-secondary leakage). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU4 Example EAL #2
2. Technical Specifications, Definitions
3. Technical Specifications 3.4.6.2 - Unit 1 Operational Leakage
4. Technical Specifications 3.4.7.2 - Unit 2 Operational Leakage
5. UFSAR 5.2.7.2 Indication in Control Room
6. S1 (S2).OP-AB.RC-0001 (Q) Reactor Coolant System Leak
7. S1(S2).OP-SO.RC-0004(Q) Identifying and Measuring Leakage
8. SC.RA-AP.ZZ-0051 Leakage Monitoring and Reduction Program
9. Sl(S2).OP-ST.RC-0008(Q) Reactor Coolant System Water Inventory Balance Salem Page 3 of 4 Rev. 0 (draft E)

EAL#:SU8.1

SGS ECG - EAL Technical Bases EP-SC-1 11-220 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: SUB. 1

EALs forl 0 F0 Fission Product Barulers

SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: CFSTs Initiating Condition: Potential Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FBi-P (4 points) EAL: CFST Core Cooling PURPLE path exists Basis: 

          .,    thr....ld... are f.. PW    ,,_,,   ,'a,,
                                                     *9--   F',,,"    Fn to,,,,

3ti . uS,,4 Tio' (, SFS=TS Monitoring ai3G fUnctions! F98tGor-tiG pr "'G44F, . Fopolenomain~ age Fofc- to Sec-tion 3.9 of this documenet.] I - k,-,-I' Core Cooling ORANGE-PURPLE indicates subcooling has been lost and that some clad damage may occur. Potential Loss Thresheld B HPost Sink RE- ,hh-eateiat-4s-requated i GS the ul__ohe SiRk functienis under extreme challcngc.- Explanation/Discussion/Definitions: CFST status will not be used for event classification until the Control Room staff has implemented the CFSTs. The Core Cooling CFST is illustrated in Attachment 2, page 4. Adverse Containment setpoints appear in the Heat Sink CFST. Adverse Containment conditions exist if Containment pressure exceeds 4 psig or R44 Containment radiation dose rates exceed 1 E05 R/hr or R44 dose exceeds 1 E06 R. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Potential Loss 1 .A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree
3. NC.EP-EP.ZZ-0201 (Q) TSC - Integrated Engineering Response Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: FIBI] P

SGS ECG - EAL Technical Bases EP-SC-1 11-221 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: FBI-P

SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: CFSTs Initiating Condition: Potential Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup,.3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB2-P (4 points) EAL: Basis: Heat Sink RED when heat sink is required indicates the ultimate heat sink function is under extreme challenge. Explanation/Discussion/Definitions: CFST Heat Sink RED Path entry conditions affects both the Fuel Clad and RCS Barriers. Therefore, minimum classification would be SAE. A barrier loss classification should not be made if the Heat Sink RED Path is the result of procedurally required Auxiliary Feedwater Flow control. CFST status will not be used for event classification until the Control Room staff has implemented the CFSTs. The Heat Sink CFST is illustrated in Attachment 2, page 6. Adverse Containment setpoints appear in the Heat Sink CFST. Adverse Containment conditions exist if Containment pressure exceeds 4 psig or R44 Containment radiation dose rates exceed 1E05 R/hr or R44 dose exceeds 1E06 R. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Potential Loss 1 .B
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.03 Heat Sink Status Tree
3. 1(2)-EOP-FRHS-1 Response to Loss of Secondary Heat Sink
4. NC.EP-EP.ZZ-0201 (Q) TSC - Integrated Engineering Response Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: FB2-P

SGS ECG - EAL Technical Bases EP-SC-1 11-221 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: [FB2=P

SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: Core Exit TCs Initiating Condition: Potential Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB3-P (4 points) EAL: 5 or more CETs > 700OF Basis: [Coroe E44 T43etýýGGiple 9edig 3m uw/!UdP-dn44dditiGn to the CritG-i safety 

                                                                                                                        ;1 r-plai-4 -'which do noet 4ave a CSF sGe"e~

LoSS ThE.solh* *A The site specific reading she~ld correspond to significant superheating of thc coolant RED in Fuel C4dA "'*'14 is uo al a.t..20 d e. ].

i II:

Il I I Li 1I-.-~.-d-~-J.-J L A The site specifiGc eading should correspcd* tefive core exit thermocouple (CET) temperatures > 700°F indicates a loss of subcooling. 

     -[This         value typioally Georresponds to the teRmper-ature Feading that indicateS core Gooling ORANGE_        i Fuel Clad Barrr potent/a' loS. tht..Sh.old 1.,. A..ic. is usual.. abou, 700 to 900 Explanation/Discussion/Definitions:

Core exit thermocouple (CET) readings greater than 700°F signal a CFST Core Cooling PURPLE path condition. CET readings are used as a fission product barrier threshold in addition to the CFST thresholds to address events in which the CFSTs may not yet be in use. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Potential Loss 3.A Salem Page 1 of 3 Rev. 0 (draft E)

EAL#: FB3-P

SGS ECG - EAL Technical Bases EP-SC-1 11-221

2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree Salem Page 2 of 3 Rev. 0 (draft E)

EAL#: F[3-P

SGS ECG - EAL Technical Bases EP-SC-1 11-221 This page intentionally blank Salem Page 3 of 3 Rev. 0 (draft E) EAL#: J 1 -P

SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcateg ory: Inventory Initiating Condition: Potential Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB4-P (4 points) EAL: RVLIS < Table F-1 thresholds Table F-I RVLIS Thresholds RVLIS RCPs Full Range 39% None 44% 4 30% 3 Dynamic Range 20% 2 13% 1 Basis: There is no Loss threshold associated with this item. The site-specific values for the Potential Loss thresholds corresponds to approximately the top of the active fuel. r r--- -;4- - , , -;-- it- - rn-j- .- 4,.,- 1 1 44,  ;- - J k- , ft, tL-f l ;,Ivt  ;'f'IV* U F-0 ; t,' Ltft t=u'L t;;utCf-; L. ,,, Ui, 1 ! ;;.Y*;*it U i IV Lf u.[v k:;u v.;' ", :ýu II ORANGE= path. The sites~pecific-value in thi threshold should be Gconabteit with the GSF Explanation/DiscussionfDefinitions: The specified RVLIS readings (Table F-i) and the associated number of running RCP pumps are used in the CFSTs to signal core uncovery and are, therefore, indication of inadequate Salem Page 1 of 2 Rev. 0 (draft E) EAL#: FB4IP

SGS ECG - EAL Technical Bases EP-SC-1 11-221 coolant inventory. If the RVLIS thresholds are exceeded, a core covered condition cannot be confirmed. According to the CFST Core Cooling PURPLE path, this water level indicates subcooling has been lost and that some fuel clad damage may occur. RVLIS readings are used as a fission product barrier threshold in addition to the CFST thresholds to address events in which the CFSTs may not yet be in use. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Potential Loss 4.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: FB4oP

SGS ECG - EAL Technical Bases EP-SC-1 11 -221 EAL Category: F - Fission Product Barrier Degradation Subcategory: EC Judgment Initiating Condition: Potential Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB5-P (4 points) EAL: ANY condition in the opinion of the Emergency Coordinator that indicates potential loss of the Fuel Clad barrier Basis: Thisese thresholds addresses any other factors that are to be used by the Emergene Di-reeteGEmergency Coordinator in determining whether the Fuel Clad barrier is lest-eG potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this threshold as a factor in EMe.gcncY Dirc...Emergency Coordinator judgment that the barrier may be considered lest-er-potentially lost. Explanation/Discussion/Definitions: The Emergency Coordinator judgment threshold addresses any other factors relevant to determining if the Fuel Clad barrier is potentially lost. Such a determination should include IMMINENT barrier degradation, barrier monitoring capability and dominant accident sequences. o Barrier degradation exists if the degradation will likely occur within two hours based on a projection of current safety system performance. o Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration of offsite monitoring results. o Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of AC power (Station Blackout) and ATWT EALs to assure timely emergency classification declarations. Salem Page 1 of 2 Rev. 3(draft E) EAL#: F[S-P

SGS ECG - EAL Technical Bases EP-SC-1 11-221 Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Potential Loss 8.A Salem Page 2 of 2 Rev. 3(draft E)

EAL#: FB5-P

SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: CFSTs Initiating Condition: Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FBI-L (5 points) EAL: CFST Core Cooling RED path exists Basis: [Thesew ~7od ar,- for PW~s us4, ig 049GifI ftyFcio StatU& Tmý9 (OSF-S-T monpito4rig and functional restomation proc-edures. ForF moro inforrnpatien, plea cc efer to SeCtion 3.9 of thig docGUMent.] Loss Thrcshold-A Core Cooling- RED indicates significant superheating and core uncovery and is considered to indicate loss of the Fuel Clad Barrier. Explanation/Discussion/Definitions: CFST status will not be used for event classification until the Control Room Staff has implemented the CFSTs. The Core Cooling CFST is illustrated in Attachment 2, page 4. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Loss 1.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: F -L

SGS ECG - EAL Technical Bases EP-SC-1 11-221 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: FBI -L

SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: Core Exit TCs Initiating Condition: Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB2-L (5 points) EAL: 5 or more CETs > 1200°F Basis: [These th shod, are fop: PAs using Critc-al Safety F*unctie Status Trfec (.SF*SlT) monGitoring and functional restoration proccdurcs. ForF moGre nRformatiqn, ple ase refer to Sect4on 3.9 Of thiS document.] Potential Loss Threhohld A [Core Exi Thrnec-oupeRadtg a~ uw"~de in -9ditiOPto the Critical Safety Fu.nctiops to include c*-ndiGons when the CSFs may. n..t be in U39 (,i:;at407 a..E. S! ig blocke-qd) or-plants whýich do not haVe a CSF= scheme.] Loss Th-rchold A The five core exit thermocouple (CET) temperatures > 1200'F indicates site speGif;Gc readi* should correspond to significant superheating of the coolant. valisýýue typica/4y cor-respo~ds to the tempe'a ture reading that indicates core coolin 

- RED in Fuel Clad BaPrier-o,        tesh*o Ald        1.,4A '44'?i7is usu64Al about 1200 degrees F.]

Explanation/Discussion/Definitions: Core exit thermocouple (CET) readings greater than 1,200°F signal a CFST Core Cooling RED path condition. CET readings are used as a fission product barrier threshold in addition to the CFST thresholds to address events in which the CFSTs may not yet be in use. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Loss 3.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree Salem Page 1 of 3 Rev. 0 (draft E)

EAL#: FB 2-L

SGS ECG - EAL Technical Bases EP-SC-'l 11-221 Salem Page 2 of 3 Rev. 0 (draft E) EAL#: 7

SGS ECG - EAL Technical Bases EP-SC-1 11-221 This page intentionally blank Salem Page 3 of 3 Rev. 0 (draft E) EAL#: FS2oL

SGS ECG - EAL Technical Bases EP-SC-1 11 -221 EAL Category: F - Fission Product Barrier Degradation Subcategory: Radiation Initiating Condition: Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB3-L (5 points) EAL: Containment radiation monitor R44A or R44B reading > 300 R/hr Basis: The site specific reading is a value which indicates the release of reactor coolant, with elevated activity indicative of fuel damage, into the containment. [0 e' " g ,9 e Gt3d d. .. f the reactor- Goolant noble gas and iediiqe "'2"c"2tery aS8o~iatE~d wih a OfleRn~traticn of CO0 C dose equival"ent 1 ThCdgm .131the .nt' atmoph.ere. 

                                                                 .ontainment Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within technical specifications and are therefore indicative of fuel damage.

This value is higher than that specified for RCS barrier Loss threshold #6RB1-L. Thus, this threshold indicates a loss of both the Fuel Clad barrier and RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency. [Caution; it is'im'portnt treoginnf .g'ze t'7at in ther eV1 the rad'-'ti'c:' MOnito iS Se citiv to shine fromt: the r-eactor vessel oir pi'ipi ng,spru readings wiglb e piresont an~d another indicator Of fuel clad damage is n~ecessary,or-compensated for in3 the thr-eshold,,value.] There is no Potential Loss threshold associated with this item. Explanation/Discussion/Definitions: 1(2)R44A and 1(2)R44B are the Containment High Range area radiation monitors. The threshold value of 300 R/hr has been calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration of 300 pCi/gm Dose Equivalent I-131 into the Containment atmosphere. 300 pCi/gm Dose Equivalent Iodine-1 31 (DEl-1 31) corresponds to approximately 2.8% fuel clad damage. Salem Page 1 of 3 Rev. 0 (draft E) EAL#: F833L

SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Loss 6.A
2. Calculation by Nuclear Fuels Group file title DS1.6-0098 "Verification of Emergency Action Levels for Event Classification" date 02/10/95 Salem Page 2 of 3 Rev. 0 (draft E)

EAL#: F[3=L

SGS ECG - EAL Technical Bases EP-SC-1 11-221 This page intentionally blank Salem Page 3 of 3 Rev. 0 (draft E) EAL#: FB3=L

SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: Other Initiating Condition: Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB4-L (5 points) EAL: Coolant activity > 300 pCi/gm dose equivalent 1-131 Basis: The site specific value .e.rreSPeGn-s-is te-300 I-Ci/grn dose equivalent 1-131-equivale-t. Assessment by the NEI EAL Task Force indicates that this amount of coolant activity is well above that expected for iodine spikes and ... r6SPG.dS to) leSS tha* 5% 41'fue cad d.amage. This amount of radioactivity indicates significant clad damage and thus the Fuel Clad Barrier is considered lost. [The vaiuo c-an be eoxpresed either-in Rn3'hr o eb~eAe don thJe sample Or as #Ci/gm results from anpa4sis.] There is no Potential Loss threshold associated with this item. Explanation/Discussion/Definitions: The threshold value of 300 pCi/gm Dose Equivalent Iodine-131 (DEl-1 31) is based upon an engineering calculation and corresponds to approximately 2.8% fuel clad damage. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Loss 2.A
2. Calculation by Nuclear Fuels Group file title DS1.6-0098 "Verification of Emergency Action Levels for Event Classification" date 2/10/95
3. S1(S2).OP-AB.RC-0002 (Q) High Activity in Reactor Coolant System Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: F[4==

SGS ECG - EAL Technical Bases EP-SC-1 11 -221 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: FlB4oL

SGS ECG " EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: EC Judgment initiating Condition: Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB5-L (5 points) EAL: Basis: These-This thresholds addresses any other factors that are to be used by the Emergeqey DireGtG Emergency Coordinator in determining whether the Fuel Clad barrier is lost-eGr ,-teRta4y4G-&t. In addition, the inabilityto monitor the barrier should also be incorporated in this threshold as a factor in Em.ergency Dirc....Emergency Coordinator judgment that the barrier may be considered lost or ptentiall lot Explanation/Discussion/Definitions: The Emergency Coordinator judgment threshold addresses any other factors relevant to determining if the Fuel Clad barrier is lost. Such a determination should include IMMINENT barrier degradation, barrier monitoring capability and dominant accident sequences. o Barrier degradation exists if the degradation will likely occur within two hours based on a projection of current safety system performance. o Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration of offsite monitoring results. o Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of AC power (Station Blackout) and ATWT EALs to assure timely emergency classification declarations. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: F[5-[

SGS ECG - EAL Technical Bases EP-SC-1 11-221 Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Loss 8.A Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: FB52 L

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: Isolation Initiating Condition: Potential Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RBI-P (4 points) EAL: CFST Thermal Shock RED path exists Basis: monitoring and f,,n. tional restorGotionp,,,, .... m..e io infRmPation. r...o to Se"tion 3.0 a p,-t÷etial ILess Thr~ehelrd A RCS integrity-Thermal Shock -RED indicates an extreme challenge to the safety function derived from appropriate instrument readings. Potenti-l Loss Threshod B Heat SiRk RE',When heat sink iS 'equi*red indiGateS the ultimate heat sink fu*ction a undcr extreme challeng-e. There is no Loss threshold associated with this item. Explanation/Discussion/Definitions: CFST status will not be used for event classification until the Control Room staff has implemented the CFSTs. The Thermal Shock CFST is illustrated in Attachment 2, pages 7 and

8. The Heat Sink CFST is illustrated in Attachment 2, page 6. Adverse Containment setpoints appear in the Heat Sink CFST. Adverse Containment conditions exist if Containment pressure exceeds 4 psig or R44 Containment radiation dose rates exceed 1 E05 R/hr or R44 dose exceeds 1E06 R.

EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Barrier Potential Loss 1.A Salem Page 1 of 3 Rev. 0 (draft E)

EAL#:RBI P

SGS ECG - EAL Technical Bases EP-SC-1 11-222

2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.04 Thermal Shock Status Tree
3. NC.EP-EP.ZZ-0201 (Q) TSC - Integrated Engineering Response salem-..-.. Page 2 of 3 Rev. 0 (draft E)

EAL#: RB[ oP

SGS ECG - EAL Technical Bases EP-SC-1 11-222 This page intentionally blank Salem Page 3 of 3 Rev. 0 (draft E) EAL#:RBI P

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: Isolation Initiating Condition: Potential Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RB2-P (4 points) EAL: Basis: Heat Sink RED when heat sink is required indicates the ultimate heat sink function is under extreme challenge. There is no Loss threshold associated with this item. Explanation/Discussion/Definitions: CFST Heat Sink RED Path entry conditions affects both the Fuel Clad and RCS Barriers. Therefore, minimum classification would be SAE. A barrier loss classification should not be made if the Heat Sink RED Path is the result of procedurally required Auxiliary Feedwater Flow control. CFST status will not be used for event classification until the Control Room staff has implemented the CFSTs. The Thermal Shock CFST is illustrated in Attachment 2, pages 7 and

8. The Heat Sink CFST is illustrated in Attachment 2, page 6. Adverse Containment setpoints appear in the Heat Sink CFST. Adverse Containment conditions exist if Containment pressure exceeds 4 psig or R44 Containment radiation dose rates exceed 1E05 R/hr or R44 dose exceeds 1E06 R.

Salem Page 1 of 2 Rev. 0 (draft E) EAL#: RB2-P

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Barrier Potential Loss 1..B
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.03 Heat Sink Status Tree
3. 1(2)-EOP-FRHS-1 Response to Loss of Secondary Heat Sink
4. NC.EP-EP.ZZ-0201 (Q) TSC - Integrated Engineering Response Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: RB2-P

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Potential Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RB3-P (4 points) EAL: Basis: M-4-4.:-l 1 "T" .-,.-^ ^ -.- ^ 1 A This threshold is based on the apparent inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control System which is considered to be the flow rate equivalent to one charging pump discharging to the charging header. Minimizing lse"ati-- letdown is a standard abnormal operating procedure action and may prevent unnecessary classifications when a non-RCS leakage path such as a CVCS leak exists. The intent of this condition is met if the leak is in Letdown and attempts to isolate Letdown are NOT successful. Additional charging pumps being required is indicative of a substantial RCS leak. [ForF plantS With !oW capacity Gharging PUMP~S, a 50 gPR4 indir~ated leak(r-atE Va!L' rM7p be Uced to indicate the Potential Less.] Explanation/Discussion/Definitions: Significant leakage from the RCS requires implementation of S1 (S2).OP-AB.RC-0001(Q). Actions required by this procedure specify the use of one Centrifugal Charging Pump, discharging to the charging header, and Letdown reduced to a minimum. If RCS leakage results in an inability to maintain the specified Pressurizer (PZR) level with a normal charging lineup and minimum Letdown flow using one Centrifugal Charging Pump, an RCS inventory loss is occurring that would require initiation of Reactor Trip and Safety Injection (SI) and entry into EOP-TRIP-1. This RCS Potential Loss assumes that any event that would result in significant RCS mass loss will require at least an Alert emergency classification. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: RB3-P

SGS ECG - EAL Technical Bases EP-SC-1 11-222 Non-RCS leakage events (such as steam or feedwater system breaks) in which no mass is lost from the RCS should not be classified under this RCS barrier Loss. SGTRs that result in entry into 1(2)-EOP-SGTR-1 shall be classified under RCS Barrier Loss RB3-L. If a SGTR does not result in 1(2)-EOP-SGTR-1 entry, it should be classified as a minimum under this RCS barrier Potential Loss if PZR level cannot be maintained above 17%. When PZR level drops to 17%, Letdown isolates and pressurizer heaters deenergize. This condition is signaled by overhead annunciator E-36, PZR HTR OFF LVL LO. Pressurizer level is indicated on LI-459A, LI-460A, LI-461, associated computer points and SPDS. The design flowrate of one centrifugal charging pump is 150 gpm. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Barrier Potential Loss 2.A
2. Sl(S2).OP-AB.RC-0001 (Q) Reactor Coolant System Leak
3. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
4. 1(2)-EOP-SGTR-1 Steam Generator Tube Rupture
5. S1(S2).OP-AR.ZZ-0005(Q) OHA E-36, PZR HTR OFF LVL LO
6. SI(S2).OP-SO.CVC-0002(Q) Charging Pump Operation Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:RB3IP

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: EC Judgment Initiating Condition: Potential Loss of RCS Mode. Applicability: 1- Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot ShutdoWn EAL# & Point Value: RB4=P (4 points) EAL: K ANY condition in the opinion of the Emergency Coordinator that indicates potential loss of the RCS barrier Basis: Thise-se thresholds addresses any other factors that are to be used by the Emergency Coordinator in determining whether the RCS barrier is lest-G potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this threshold as a factor in Em.rgency Dir. . toEmerqency Coordinator judgment that the barrier may be considered lost er-potentially lost. Explanation/Discussion/Definitions: The Emergency Coordinator judgment threshold addresses any other factors relevant to determining if the RCS barrier is potentially lost. Such a determination should include IMMINENT barrier degradation, barrier monitoring capability and dominant accident sequences. o Barrier degradation exists if the degradation will likely occur within two hours based on a projection of current safety system performance. o Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration of offsite monitoring results. o Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of AC power (Station Blackout) and ATWT EALs to assure timely emergency classification declarations. Salem " Page 1 of 2 Rev. 0 (draft E) EAL#: RIB4oIp

SGS ECG - EAL Technical Bases EP-SC-111-222 Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Potential Loss 8.A Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:RB4-P

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: Radiation Initiating Condition: Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RBI-L (5 points) EAL: ANY of the following Containment radiation monitor readings: o 1(2)R2 > 1000 mR/hr o 1(2)R44A > 10 lRhr o 1(2)R44B > 10 R/hr Basis: The s4te-spe-4ie-reading-iss are a-values which indicates the release of reactor coolant to the containment. J V I the r-eactor-coolant noble gas and io dine i:n yentor associated-with normal op crc tin cnorp.e tra tiers (i.a, within T/3) i1#0 th3e containment a tine ph er.] Theis readings will be less than that specified for Fuel Clad barrier threshold 6FB3-L. Thus, this threshold would be indicative of a RCS leak only. Ifthe radiation monitor reading increased to that specified by Fuel Clad barrier threshold, fuel damage would also be indicated. [ if thesite s 

                -hoever,           ficn physica Itiei.      of the containmen radiation mqoio      i sucph that randiation from a cloud of released RCS gases could n ot be distinguished from Fadiýatien from adjacent piping and componGents conta Thing elevated reactor-coolant et       Gv'41ty, this threshold 5zhnxul hp pmiftted qPd othpr sýite srsernr 4idip:tionns of RQS leakeon, iý-. ý SU19tituEd.L4 There is no Potential Loss threshold associated with this item.

Explanation/Discussion/Definitions: Salem Page 1 of 2 Rev. 0 (draft E) EAL#:R[i-L

SGS ECG - EAL Technical Bases EP-SC-1 11-222 130' Containment Area Rad Monitor 1(2)R2 has an instrument scale range of 0.1 mR/hr to 10 R/hr and, therefore, offers the preferred method of assessing this RCS Barrier Loss. 1 R/hr on this monitor is indicative of the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with Technical Specification concentrations into the Containment atmosphere. These readings are less than that specified for Fuel Clad Barrier Loss FB3-L since this EAL attempts to identify RCS leakage assuming RCS activity is at the Technical Specification limit. Classification under this EAL should not be made based upon crud burst evolutions or other non-RCS leakage events. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Barrier Loss 6.A
2. Calculation by Nuclear Fuels Group file title DS1.6-0098 "Verification of Emergency Action Levels for Event Classification" date 2/10/95 Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:Ri]L

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RB2-L (5 points) EAL: Subcooling 5 0<F (as a result of RCS leakage) Basis: Loss ThresholdA~ This threshold addresses conditions where leakage from the RCS is greater than available inventory control capacity such that a loss of subcooling has occurred. The loss of subcooling is the fundamental indication that the inventory control systems are inadequate in maintaining RCS pressure and inventory against the mass loss through the leak. Explanation/Discussion/Definitions: RCS subcooling of 0°F or less is a criterion in the CFST Core Cooling YELLOW path (or higher) and is monitored in the Continuous Action Summary (CAS). Subcooling is indicated in the Control Room on Subcooling Margin Monitor Channel A and Channel B. This threshold focuses on RCS inventory loss due to LOCA conditions. Non-RCS leakage events (such as steam or feedwater system breaks) in which no mass is lost from the RCS should not be classified under this RCS barrier Loss. Subcooling equal to or less than 0°F is indication that leakage from the RCS barrier is greater than the available inventory control capacity. This threshold does not apply to primary-to-secondary leakage events since adequate injection capability should be available for the spectrum of such events including Steam Generator Tube Rupture (SGTR). Refer to RCS barrier Loss RB3-L for SGTR. EOP directed actions resulting in deliberate subcooling reduction (e.g. during SGTR saturated recovery), steam/feedwater line breaks, or momentary reductions below 0°F that are recoverable (e.g. SI flow reduction sequence) should not be classified under this EAL. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Barrier Loss 2.A Salem Page 1 of 3 Rev. 0 (draft E)

EAL#:RB2-L

SGS ECG - EALTechnical Bases EP-SC-111-222

2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree Salem Page 2 of 3 Rev. 0 (draft E)

EAL#:RB2-L

SGS ECG - EAL Technical Bases EP-SC-1 11 -222 This page intentionally blank Salem Page 3 of 3 Rev. 0 (draft E) EAL#:RB2oL

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RB3-L (5 points) EAL: SGTR requiring ECCS (SI) Actuation Basis: This threshold addresses the full spectrum of Steam Generator (SG) tube rupture events in conjunction with Containment barrier Loss thresholds. It addresses RUPTURED SG(s) for which the leakage is large enough to cause actuation of ECCS (SI). This is consistent to the RCS leak rate barrier Potential Loss threshold. [For plpa;nt that have itWastii*. ,ghuse owere Group emergencysresponse guides, this coGnd-ition is descrýbed by 'ntrty io E 3 required by E-OP".] By itself, this threshold will result in the declaration of an Alert. However, if the SG is also FAULTED (i.e., two barriers failed), the declaration escalates to a Site Area Emergency per Containment barrier Loss thresholds. There is no Potential Loss threshold associated with this item. Explanation/Discussion/Defi nitions: This EAL is indicative of a loss of RCS inventory due to a Steam Generator Tube Rupture (SGTR) in which the leakage is large enough to cause actuation of Safety Injection (SI). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Barrier Loss 4.A
2. 1(2)-EOP-SGTR-1 Steam Generator Tube Rupture
3. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection Salem Page 1 of 2 Rev. 0 (draft E)

EAL#:RB3oL

SGS ECG - EAL Technical Bases EP-SC-111-222 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#:R[3-L

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: EC Judgment Initiating Condition: Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RB4-L (5 points) EAL: Basis: Thise-se thresholds addresses any other factors that are to be used by the Eme.e...Y Di...-...rEmerqency Coordinator in determining whether the RCS barrier is lost -pe-te**,-i@ lest. In addition, the inability to monitor the barrier should also be incorporated in this threshold as a factor in ER;c.gGncY Dieto*Emergency Coordinator judgment that the barrier may be considered lost or ,te,,tialaH,, -S,. Explanation/Discussion/Definitions: The Emergency Coordinator judgment threshold addresses any other factors relevant to determining if the RCS barrier is lost. Such a determination should include IMMINENT barrier degradation, barrier monitoring capability and dominant accident sequences. o Barrier degradation exists if the degradation will likely occur within two hours based on a projection of current safety system performance. o Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration of offsite monitoring results. o Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of AC power (Station Blackout) and ATWT EALs to assure timely emergency classification declarations. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: RB4-L

SGS ECG - EAL Technical Bases EP-SC-1 11-222 Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Loss 8.A Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: RB4oL

SGS ECG - EAL Technical Bases EP-SC-1 11 -223 EAL Category: F - Fission Product Barrier Degradation Subcategory: CFSTs Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CBI-P (2 points) EAL: CFST Containment RED path exists Basis: [Thesethre*olds,.re-fer . P,*usi... p , , i l Safoeo, , St;,,*. n,,,,- T,-S (CSFS-T mqonitorin~g and A43qGa Fetratie pi-- t-res For mere inFomatieo3 rafer tesr-q 3. 9 Gt RED path indicates an extreme challenge to the safety function derived from appropriate instrument readings and/or sampling results, and thus represents a potential loss of containment. Conditions leading to a Ceontainment RED path result from RCS barrier and/or Fuel Clad Barrier Loss. Thus, this threshold is primarily a discriminator between Site Area Emergency and General Emergency representing a potential loss of the third barrier. There is no Loss threshold associated with this item. Explanation/Discussion/Definitions: Critical Safety Function Status Tree (CFST) Containment RED path exists if Containment pressure is greater than or equal to 47 psig. The Containment RED path is in the Containment Environment CFST illustrated in Attachment 2, page 9. Containment pressure of this magnitude results from RCS barrier loss or a faulted S/G inside Containment and signifies an extreme challenge to the Containment. For this condition, all Containment isolations, as well as automatic Containment Spray and CFCU "low speed" operation should be initiated before this threshold is reached. The Containment barrier is considered potentially lost at 47 psig even though the Containment yield strength is much higher that 47 psig. Thus, this threshold is primarily a discriminator Salem Page 1 of 2 Rev. 0 (draft E) EAL#: CB ] 'P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 between a Site Area Emergency and a General Emergency (i.e., a potential loss of the third barrier). CFST status will not be used for event classification until the Control Room staff has implemented the CFSTs. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 1.A
2. 1(2)-EOP-CFST-1 Critical Safety FunctionStatusTrees.- F.05 Containment Environment Status Tree
3. UFSAR 6.2 Containment Systems
4. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CI=P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: CFSTs Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB2-P (2 points) EAL: Basis: See discussion below.[This E4L sheouleloer .th. r (-Site.Sp. cif4G, :nei,*oti t*aot m1oay unombguou~y idiGo te less or potenitial !Gss of the con to nment bai-ier-, inc-luding indic-aton from area or vent/a tion monq~tors in containment ann u/us or o~ther-contigue us build4ngs. /fct emer~gencyý oper~atingprocedur-es provi4de fGpr ;, tiny of the contaftnment dur;ý3g an omerýgency as a meanS Of preVenting cata stroPh : fa:!uFre. a LOSS; EAL ShGouidbE? 43c-4ud0e4AFo the containmP-ent barr~er. This EA4L should be do~a~e carc doCseei a s sucsh venting is /AWINEN T. Cont~ainm nt veit64g as par-t of rc coveor actions is cliassified in 3accordancoq withý the r-ad-iological ffluc~ it!C.]I Explanation/Discussion/Definitions: CFST status will not be used for event classification until the Control Room Staff has implemented the CFSTs. The Core Cooling CFST is illustrated in Attachment 2, page 4. This threshold is redundant to Containment Barrier Potential Losses CB3-P and CB-4P. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 1.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Tree - F.02 Core Cooling Status Tree
3. UFSAR 6.2 Containment Systems
4. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection Salem Page 1 of 3 Rev. 0 (draft E)

EAL#: CB2-P

SGS ECG - EAL Technical Bases EP-SC-111-223 Salem Page 2 of 3 Rev. 0 (draft E) EAL#:CB2IP

SGS ECG - FAL Technical Bases EP-SC-1 11-223 This page intentionally blank Salem Page 3 of 3 Rev. 0 (draft E) EAL#:CC11 -2

SGS ECG - EAL Technical Bases EP-SC-111-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Core Exit TCs Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB3-P (2 points) EAL: 5 or more CETs > 1200°F AND Restoration procedure 1(2)EOP-FRCC-1 NOT effective within 15 minutes Basis: There is no Loss threshold associated with this item. The conditions in these thresholds represent an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. In conjunction with the Core Cooling and RCS Leakage criteria in the Fuel and RCS barrier columns, this threshold would result in the declaration of a General Emergency -- loss of two barriers and the potential loss of a third. If the function restoration procedures are ineffective, there is no "success" path. The function restoration procedures are those emergency operating procedures that address the recovery of the core cooling critical safety functions. The procedure is considered effective if the temperature is decreasing or if the vessel water level is increasing. [Fp r unit . us, the QSF= S'ta÷" t r.... a d""tG'rh.. rrne'atigr- ti,-,o st..atus ti.... cs ap. lb qade if the effeG*....... of thea r.... n oat, ..... ,dr.... is also e valuated as stated bew.]. r"o., A I I I M r-/- -4 f Cn I i, - , - - - - -1, , J- -1 '1- 4, , - -f;- . tc~vvt~f efuututn it fi a t;F= U db 1 r?- th u If Irtfu r it t fcf' ton ttf sz o i rgI i ii 

                                                                                                                                                                                 ;ag Frcsrte.~             #1r.ngn              jr,~,-           aref-nnren                 deg-rad#-a-tinn wit-hipn~r                 the     Feam,#tirnrr      vesse                   ,1, s, ar             ian,
   *      /1 1,- ?- # ,         ,,.   ,-   .,'-*.,#-. -; J ,-      U-,;        ;÷ 1-I      h          ,.;    ,- 1 -,,    -.-      , ,     .. -,-, ,--,.1,,     11 i I          ,

4 r-- #,,-,,-,-11 t,, I- -I I- - tufftotttl ft:,btut - -- I " - - tv itivit 0tVtqb1VtfUtV.j Salem Page 1 of 2 Rev. 0 (draft E) EAL#: CI)3-P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 Whether or not the procedures will be effective should be apparent within 15 minutes. The Emergency Director Coordinator should make the declaration as soon as it is determined that the procedures have been, or will be ineffective. Petential Loss Threshold B [The ceactor Vo988e! l Gh Peon shGUld bE consiStEnt With th. e e... onSO*e 

                                                                               -Mency g~'ide-s-appoieabi to the faeiiity.

Explanation/Discussion/Definitions: If core exit thermocouple (CET) readings are greater than 1,200'F, Fuel Clad barrier is lost. CETs provide an indirect indication of fuel clad temperature by measuring the temperature of the reactor coolant that leaves the core region. Although clad rupture due to high temperature is not expected for CET readings less than the threshold, temperatures of this magnitude signal significant superheating of the reactor coolant and core uncovery. Events that result in CET readings above the loss threshold are severe accidents and are a severe accident management "Badly Damaged (BD)" condition. The BD descriptor signifies possible core overheating to the point that clad ballooning/collapse may occur and portions of the core may have melted. Severe accident analysis has concluded that functional restoration procedures can arrest core degradation within the Reactor Vessel in a significant fraction of the scenarios, and that the likelihood of Containment failure in these scenarios is small. It is appropriate; therefore, to allow a reasonable period of time for the functional restoration procedures to arrest the core melt sequence. The functional restoration procedure, 1(2)-EOP-FRCC-1, is the emergency operating procedures that address the recovery an inadequate core cooling condition. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 3.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree
3. 1(2)-EOP-FRCC-1 Response to Inadequate Core Cooling Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CB3oP

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Core Exit TCs Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB4-P (2 points) EAL: ALL of the following: o 5 or more CETs > 700°F o RVLIS < Table F-1 thresholds o Restoration procedure 1(2)EOP-FRCC-1 NOT effective within 15 minutes Table F-I RVLUS Thresholds RVLIS RCPs Full Range 39% None 44% 4 30% 3 Dynamic Range 2 2 20% 2 13%1 Basis: There is no Loss threshold associated with this item. The conditions in these thresholds represent an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. In conjunction with the Core Cooling and RCS Leakage criteria in the Fuel and RCS Paprie Barrier columns, this threshold I would result in the declaration of a General Emergency -- loss Salem Page 1 of 3 Rev. 0 (draft E) EAL#:C[4-P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 of two barriers and the potential loss of a third. If the function restoration procedures are ineffective, there is no "success" path. The function restoration procedures are those emergency operating procedures that address the recovery of the core cooling critical safety functions. The procedure is considered effective if the temperature is decreasing or if the vessel water level is increasing. 

                   .. si,'r the CSF Status treeS, a diýret correlation to thoes status* tree*, a be

[For "units madeI if th fctvn~Of the s-9tore tion Procedum9S i alSo eVa!Uated as stated below,] restorationU~e pro'a"' arFPS Gr 4'dgr-adationvwt'h 1/4 t43e re~acte- vessel in3 a signifian -fractionOf the core damage &eenarios., and that the likelihood of containment failur-e is very small i3 these cvepts. G4e n this, it is apýqra- t9 Gde ar-easone abie per4ed to a~ mtOl-tiOn fi -Stp 77 ProcGedures Ito ai/Test the~ Ge~ 'ne' s~~equi.- Whether or not the procedures will be effective should be apparent within 15 minutes. The Emergency DiheetGF Coordinator should make the declaration as soon as it is determined that the procedures have been, or will be ineffective. Potential Loss Threshold B [Th4e r:eaet or vesse level chos~en should /-e Geep-s'stent with th megaý-ona guides applicable to the facility.] Explanation/Discussion/Definitions: This threshold indicates subcooling has been lost (CET readings > 700 0 F), the core is uncovered and some fuel clad damage may be occurring. The Table F-1 RVLIS thresholds are used in the CFSTs to signal core uncovery and are, therefore, indication of loss of coolant inventory. If the RVLIS thresholds are exceeded, a core covered condition cannot be confirmed. Severe accident analysis has concluded that functional restoration procedures can arrest core degradation within the Reactor Vessel in a significant fraction of the scenarios, and that the likelihood of Containment failure in these scenarios is small. It is appropriate; therefore, to allow a reasonable period of time for the functional restoration procedures to arrest the core melt sequence. The functional restoration procedure, 1(2)-EOP-FRCC-1, is the emergency operating procedures that address the recovery an inadequate core cooling condition Definitions: Salem Page 2 of 3 Rev. 0 (draft E) EAL#:CB4oP

SGS ECG - EAL Technical Bases EP-SC-1 11-223 IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Refe'rence(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 3.B1
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree
3. 1(2)-EOP-FRCC-1 Response to Inadequate Core Cooling Salem Page 3 of 3 Rev. 0 (draft E)

EAL#:CB4-P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Radiation Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB5-P (2 points) EAL: Containment radiation monitor 1(2)R44A or 1(2)R44B reading > 2000 RPhr Basis: There is no Loss threshold associated with this item. The sitespeGi*-*,, reading is a value which indicates significant fuel damage well in excess of the thresholds associated with both loss of Fuel Clad and loss of RCS b-r4er-sBarriers. As stated in NEI 99-01 Section 3.8, a major release of radioactivity requiring off-site protective actions from core damage is not possible unless a major failure of fuel cladding allows radioactive material to be released from the core into the reactor coolant. Regardless of whether Ceontainment is challenged, this amount of activity in CGontainment, if released, could have such severe consequences that it is prudent to treat this as a Ppotential Lloss of Ceontainment, such that a General Emergency declaration is warranted. [NUREG 1228, "SourGe Estit3atiGonc Dur-'7g" 43-de Res'ponse to Severe Nuc-cat Power RtA*nt"cidntse ""*'i at that 

                                        " 6"'rh
                                              ,   Grdoitioc GIG POt c9,44t Whea the aP'3GUn l    f clad dcarage is less thaen 2900. UPIe.. the.e iS a (i*..e..       .ific)aPnSU..*       a,;;,,-

ha,.,-. , u"a

-, recemmend de*...

Fait4q ....... " er-rs4teditg-te-24*, GiTda -a ge-be Th~ife 4÷-h...÷, The Heat Capacity Temperat-ue Limit (HC;TL) is the highs-t*-Up_ýcSSiGo poel t.empei-from which EmergeRncy RPV Dr*essufrizatioR Will not Faise: Suppression chamber temperature above the-- maximumY_ te mperaturFe Gapability of the suppressionR c-hamber and equipment Within the suppFession chamber which may be rcquired to operate wI A the RPV is prS*-uriZed, 

                  +hen SuppreSSion chamber pressure above PRimary Containment Pressure Lim it A, while the rate of energy transfer from the RPV to the containment is greeter than the capacity of the containment vent.

Salem Page 1 of 3 Rev. 0 (draft E) EAL#:CBS=P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 The H-TL is a function of RPV p-'sSUre and su pp..SSin po.. 9 water .el. It it ,utilizedto prelude failure of the on--taimrReRt and ,quipme*t in thc contaiRnRmRt R8,eeSSay for the safe shutdon* of the plant aRd therefoFe, the inability to maintain plant par*ameters belw the limit conStitutes a potential !oss of COntainMert. Explanation/Discussion/Definitions: 1(2)R44A and 1(2)R44B are the Containment High Range area radiation monitors. The threshold value of 2000 R/hr has been calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with 20% fuel clad damage into the Containment atmosphere. EAL Bases Refrence(s):

1. NEI 99-01, Rev. 05,' Table 5-F-3 Containment Potential Loss 6.A
2. Calculation by Nuclear Fuels Group file title DS1.6-0098 "Verification of Emergency Action Levels for Event Classification" date 2/10/95 Salem Page 2 of 3 Rev. 0 (draft E)

EAL#:CB5-F

SGS ECG - EAL Technical Bases EP-SC-11 11 -223 This page intentionally blank Salem Page 3 of 3 Rev. 0 (draft E) EAL#:CB5oP

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB6-P (2 points) EAL: Containment pressure > 47 psig and rising Basis: The si-e-specific pressure is based on the containment design pressure. Explanation/Discussion/Definitions: The specified Containment pressure (47 psig) is the Containment design pressure. Proper actuation and operation of the Containment heat removal system when required should avoid Containment pressures in excess of this threshold. The threshold is therefore indicative of a loss of both RCS and Fuel Clad barriers in that it should not be exceeded without severe core degradation (metal-water reaction) or failure to trip in combination with RCS breach. This condition would be expected to require the declaration of a General Emergency. Containment Pressure is used as a Containment Barrier threshold in addition to the CFST thresholds to address events in which the CFSTs may not yet be in use. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 2.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.05 Containment Environment Status Tree
3. Salem EOP Setpoint Basis Document - Vendor Doc. #320832 Salem Page 1 of 2 Rev. 0 (draft E)

EAL#:CB(*p

SGS ECG - EAL Technical Bases EP-SC-1 11-223 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#,

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB7-P (2 points) EAL: Indications of > 4% H2 inside Containment Basis: Potential Less Threshold A Existence of an explosive mixture means a hydrogen and oxygen concentration of at least the lower deflagration limit curve exists. The indications of potential loss under this EAL corresponds to some of those leading to the RED path in potential loss thr shold 4-.AContainment barrier Potential Loss A-4CB1-Pabo.v and May be declared by those site. USRP§-GSFS-Ts. Explanation/Discussion/Definitions: When hydrogen concentration in the Containment atmosphere exceeds 4%, the possibility of an explosive mixture exists. Elevated hydrogen concentrations are likely to be present in the Containment only as a result of an inadequate core cooling, substantial metal-water reaction and a breach of the RCS barrier. A 4% mixture of H 2 with normal Containment atmosphere represents the deflagration lower limit. Any subsequent ignition and burn of this level mixture releases a substantial amount of energy that must be absorbed by the Containment structure, which is already under stress due to the Loss of the RCS Barrier. Elevated Containment atmosphere hydrogen, concentration is alarmed at > 2% by overhead annunciator C-23, CNTMT H 2 LVL HI. Salem Page 1 of 2 Rev. 0 (draft- E). EAL#:CB7=P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 2.B
2. 1(2)-EOP-FRCC-1 Response to Inadequate Core Cooling - Basis Document (pg 16)
3. Salem EOP Setpoint Basis Document - Vendor Doc. #320832
4. S1(S2).OP-AR.ZZ-0003(Q) OHA C-23, CNTMT H 2 LVL HI Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CB7oP

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB8-P (2 points) EAL: Containment pressure > 15 psig AND EITHER of the following: o NO Containment Spray Train in service AND 

     < 5 CFCUs running in low speed o One Containment Spray Train in service AND
     < 3 CFCUs running in low speed Basis:

Potential LOSS Thr..hold.. This threshold represents a Ppotential Lioss of _C,ontainment in that the Ceontainment heat removal/depressurization system is (e.g., contaiRnRment s.p., ice .. odenSerfaR,* et.., but not including 

           .containment     Venting Strategies) are either lost or performing in a degraded manner, as indicated by Ceontainment pressure greater than the setpoint at which the equipment was supposed to have actuated.

Explanation/Discussion/Definitions: A Containment pressure rise above 15 psig (the Containment Spray initiation setpoint) indicates a major release of energy to the Containment. No Containment Spray with fewer than five Containment Fan Coil Units (CFCUs) running in low speed or only one train of Containment Spray in service with fewer than 3 CFCUs running in low speed indicates a condition in which systems designed for Containment heat removal and depressurization do not have the capacity to maintain Containment pressure below the structural design limit. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: CBS°P

SGS ECG - EAL Technical Bases EP-SC-11 11-223 The Containment Fan Cooling System is designed to circulate and cool the Containment atmosphere in the event of a LOCA and thereby ensures that Containment pressure will not exceed its design value. Five fan-cooler units are capable of transferring heat from the Containment atmosphere at the post-accident design conditions. The UFSAR accident analyses determined a minimum of three fan-cooler units with at least one Containment Spray train is needed to maintain Containment integrity. Either of two Containment Spray trains containing a pump, associated valving and spray headers are independently capable of delivering 2,600 gpm. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 2.C
2. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
3. SGS Technical Specifications 3.6.2.1 Spray Additive System
4. SGS Technical Specifications 3.6.2.3 Containment Cooling System
5. UFSAR 6.2.2.1 Containment Spray System
6. UFSAR 6.2.2.2 Containment Fan Cooling System Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CBS-P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Judgment Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB9-P (2 points) EAL: ANY condition in the opinion of the Emergency Coordinator that indicates potential loss of the Containment barrier Basis: Thisese thresholds addresses any other factors that are to be used by the E-epgeRey Dir-eteG Emergency Coordinator in determining whether the Containment barrier is Iost-eG potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this threshold as a factor in Emergey 

                                 .Di.reGtC                              i       judgment that the barrier may be considered IGst or potentially lost.

The Containment barrier should not be declared Iest- -Gpotentially lost based on exceeding Technical Specification action statement criteria, unless there is an event in progress requiring mitigation by the Containment barrier. When no event is in progress (Loss or Potential Loss of either Fuel Clad and/or RCS) the Containment barrier status is addressed by Technical Specifications. Explanation/Discussion/Definitions: The Emergency Coordinator judgment threshold addresses any other factors relevant to determining if the Containment barrier is potentially lost. Such a determination should include IMMINENT barrier degradation, barrier monitoring capability and dominant accident sequences. o Barrier degradation exists if the degradation will likely occur within two hours based on a projection of current safety system performance. o Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration of offsite monitoring results. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:C[B-=

SGS ECG - EAL Technical Bases EP-SC-1 11-223 0 Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of AC power (Station Blackout) and ATWT EALs to assure timely emergency classification declarations. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 8.A Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: B9'p

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Loss of Containment Mode Applicability:. 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB1.L (3 points) EAL: Basis: I rýýn k c~cc A nnr M Rapid unexplained loss of pressure (i.e., not attributable to containment spray or condensation effects) following an initial pressure increase from a primary or secondary high energy line break indicates a Lioss of Ceontainment integrity. Contai*eM* t pressure and sum.p levels should increase as a rosult of mass and energy release it* o containment f-rm a LOCA. Thus, sup level or pressure no9t increas-ing indicateS containment bypass and a l9SS of containmen integrity. This indicator relies on operator recognition of an unexpected response for the condition and therefore does not have a specific value associated with it. The unexpected response is important because it is the indicator for a Ceontainment bypass condition. Explanation/Discussion/Definitions: The term "Unexplained" signifies the pressure drop is not a result of operator actions taken to reduce Containment pressure. The term "rapid" indicates the Containment breach is relatively large. For cases in which secondary coolant provides the source of energy that raised Containment pressure, a faulted Steam Generator is possible. This event would require actions in 1(2)- EOP-LOSC-1 to isolate the Main Steam lines, maintain intact Steam Generators for an RCS Heat Sink, minimize Containment pressure, and minimize RCS cooldown. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: C[ IL

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Barrier Loss 2.A
2. UFSAR Table 15.4-22 LOCA Containment Response Results (Loss of Offsite Power Assumed)
3. UFSAR Figures 15.4-43a, b and c Containment Pressure (varying initial conditions)
4. UFSAR Figure 15.4-44 Containment Pressure
5. 1(2)-EOP-LOSC-1 Loss of Secondary Coolant Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CBI L

SGS ECG - EAL.Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB2-L (3 points) EAL: Containment pressure or sump level response NOT consistent with LOCA conditions Basis: Loss Throesholds A a-nd Rapid unexplained loss of preGsure (i.e., not attributable to containment spray or condensation effects) following an initial pressure inrGease-from a primnary or secondary high energy line break indicates a loss of contai*nmn*t integrity. Containment pressure and sump levels should increase as a result of mass and energy release into _Ceontainment from a LOCA. Thus, sump level or pressure not increasing indicates _Ceontainment bypass and a Lioss of Ceontainment integrity. This indicator relies on operator recognition of an unexpected response for the condition and therefore does not have a specific value associated with it. The unexpected response is important because it is the indicator for a _Ceontainment bypass condition. Explanation/Discussion/Definitions: A LOCA is expected to result in a significant Containment pressure rise. This leak rate should result in the accumulation of RCS inventory in the Containment sump as the level rises. A lack of expected Containment sump level response or Containment pressure not rising indicates that the Containment barrier has been bypassed. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Barrier Loss 2.B
2. UFSAR Table 15.4-22 LOCA Containment Response Results (Loss of Offsite Power Assumed)
3. UFSAR Figures 15.4-43a, b and c Containment Pressure (varying initial conditions)
4. UFSAR Figure 15.4-44 Containment Pressure Salem- Page 1 of 2 Rev. 0 (draft E)

EAL#: 1E2-L

SGS ECG - EAL Technical Bases EP-SC-I 11-223 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#:CB2-L

SGS ECG - EAL Technical Bases EP-SC-111-223' EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB3-L (3 points) EAL: RUPTURED SG that is also FAULTED outside of Containment Basis: DI ,-, T.,rk,-,- ,-- A The Lloss threshold recognizes that SG tube leakage can represent a bypass of the Containment barrier as well as a Loss of the RCS barrier. UserS should realize that the t+,,, loss thresho. , This Loss threshold and Containment Loss CB4-L could be considered redundant. Thi warecOgnized durig the development p*ce.S.. The inclusion of an threshold that uses terms that are commonly used in Emergency Operating Procedure commonly used termss like "RUPTURED and FAULTED" adds to the ease of the classification process and has been included based on this human factor concern. This threshold results in a NQUE for smaller breaks that; (1) do not eXceed the normal ,"harging G-,opa"it,, tl-;rr,*h,-,I in RCS leak-l ra÷te baprier Pe-te ti,-l L ess thresho-ld,4 "r (2)' ,4,- net result in ECCS actuation in RCS SG tube rupture barrier Loss threshold. Fo~r larger breaks, RCS barrier threshold criteria would result in an Alert. For SG tube ruptures which may involve multiple steam generators or UNISOLABLE secondary line breaks, this threshold would exist in conjunction with RCS barrier thresholds and would result in a Site Area Emergency. Escalation to General Emergency would be based on "Potential Loss" of the Fuel Clad Barrier. Loss Thr~eshorld A This threshold addresses the condition in which a RUPTURED steam generator is also FAULTED. This condition represents a bypass of the RCS and containment barriers and is a subset of the seee-d threshold CB4-L. In conjunction with RCS leak rate barrier loss threshold, this would always result in the declaration of a Site Area Emergency. Explanation/Discussion/Definitions: Salem Page 1 of 3 Rev. 0 (draft E) EAL#:CB3oL

SGS ECG - EAL Technical Bases EP-SC-1 11-223 This threshold is intended to include all flow paths of Contaminated secondary coolant to the environment directly or through systems which exhaust to the Plant Vent (e.g.; leakage to the Auxiliary Building ventilation system). An exception would be if the EOPs require steaming the ruptured Steam Generator to the main condenser. The main condenser off-gas (R1 5) pathway is excluded from this EAL provided the release is both controlled and monitored. Salem Page 2 of 3 Rev. 0 (draft E) EAL#:CB3-L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 Definitions: RUPTURED: (PWRs) In a steam generator, existence of primary-to-secondary leakage of a magnitude sufficient to require or cause a reactor trip and safety injection. FAULTED: (PWRs) In a steam generator, the existence of secondary side leakage that results in an uncontrolled drop in steam generator pressure or the steam generator being completely depressurized. UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Barrier Loss 4.A
2. 1(2)-EOP-SGTR-1 Steam Generator Tube Rupture
3. 1(2)-EOP-SGTR-3 SGTR with LOCA - Subcooled Recovery Salem Page 3 of 3 Rev. 0 (draft E)

EAL#:C[3=L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB4-L (3 points) EAL: Primary-to-secondary leakrate > 25 gpm AND UNISOLABLE steam release from affected SG to the environment Basis: Dn+* i~lI ,.- Tkr~oc ,-r'4 A The Lioss threshold recognizes that SG tube leakage can represent a bypass of the Containment barrier as well as a Lloss of the RCS barrier. Users shoud roalizo that the two loss thresho-doThis Loss threshold and Containment Loss CB3-L could be considered redundant. This was recognized dUiRng the d.vel.pmcnt process. The inc,,usion. of. an thres*hol,,d that uses E P .gencyr.o..dU.e ... commo.,ly used toerroike 

':0  I07I 1D=M        ýnr     r-Af 11 Tr-:r"    ýrr    +^ fk      ,-vf+k-~,~           r~,i~'-    -'A k-, k--
--1, 14 k---14 -- +I,;_ k. --- ;__+_,

This threshold results in a NQUE for smaller breaks that; (1) do not exceed the normal charging capacity threshold in RCS leak rate barrier Potential Loss th-ie he RB3-P, or (2) do not result in ECCS (SL) actuation in RCS SG tube rupture barrier Loss threshelRRB3-L. For larger breaks, RCS barrier threshold criteria would result in an Alert. For SG tube ruptures which may involve multiple steam generators or UNISOLABLE secondary line breaks, this threshold would exist in conjunction with RCS barrier thresholds and would result in a Site Area Emergency. Escalation to General Emergency would be based on "Potential Loss" of the Fuel Clad Barrier. I me Thr~r~ehA , This threshold addresses SG tube leaks that exceed 25 4-1gpm in conjunction with an UNISOLABLE release path to the environment from the affected steam generator. The Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CB4-L

SGS ECG - EAL Technical Bases EP-S.G-1 11-223 threshold for establishing the UNISOLABLE secondary side release is intended to be a prolonged release of radioactivity from the RUPTURED steam generator directly to the environment. This could be expected to occur when the main condenser is unavailable to accept the contaminated steam (i.e., SG tube rupture with concurrent loss of off-site power and the RUPTURED steam generator is required for plant cooldown or a stuck open relief valve). If the main condenser is available, there may be releases via air ejectors, gland seal exhausters, and other similar controlled, and often monitored, pathways. These pathways do not meet the intent of an UNISOLABLE release path to the environment. These minor releases are assessed using EALs in Category R, Abnormal Rad Levels / Radiological Effluent aateshiodfo thisntheshld has boeon increased with Pvisio 3. n the aarrn c4sip, the threshold w/as.leakage greater~g-j hag TS ageowabie. Sipc'e the p~r4Fre man) p/aPts have impWemented reduced steam genera teor ToS limits (e.gr, 150 gpd) as a fofa ssuefiate with a/terate steam generater pluggindg srafton. Thne 150 gp ideptha UehliSOLA oA4I fbreachi leak thatan otbre, psrsomt isorraed boundar/ leakage of 10 gpm was used as the threshold3 !inme S5B, RCS Leakage, and isdeemed app4.Bprate for Explanation/Discussion/Definitions: Definitions: thEALses Ref erenew b seas):mreG, hehld 4p RUPTURED-: (PWRs) In a'steamn generator, exi~stence of primary-to-s~econdary leiakage of a magnitude sufficient to require or cause a reactor trip and safety injection. UNISOLABLE: A breach or leak that ca~nnot be promptly isolated from the- Control* Room.' EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Barrier Loss 4.B3 Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: CM-L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Other Initiating Condition: Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB5-L (3 points) EAL: Failure of ALL valves in ANY one line to close AND Direct downstream pathway to the environment exists after Containment isolation signal (Note 8) Note 8: A direct downstream release is a pathway from the Containment to any environment outside the Containment when Containment or system isolation is required due to: a safety injection signal, Containment pressure greater than 4 psig, or a VALID containment ventilation isolation signal and the pathway cannot be isolated from the Control Room. Basis: This threshold addresses incomplete containment isolation that allows direct release to the environment. The use of the modifier "direct" in defining the release path discriminates against release paths through interfacing liquid systems. The existence of an in-line charcoal filter does not make a release path indirect since the filter is not effective at removing fission product noble gases. Typical filters have an efficiency of 95-99% removal of iodine. Given the magnitude of the core inventory of iodine, significant releases could still occur. In addition, since the fission product release would be driven by boiling in the reactor vessel, the high humidity in the release stream can be expected to render the filters ineffective in a short period. There is no Potential Loss threshold associated with this item. Explanation/Discussion/Definitions: Indications of Containment failure may be evident without the exact pathway being understood at the time of the failure. If the Containment or part of the RCS is required to be isolated and Salem Page 1 of 4 Rev. 0 (draft E) EAL#:CB5=L

SGS. ECG - EAL Technical Bases EP-SC-1 11-223 there are VALID indications that the Containment is not isolated, the Containment barrier should be considered lost. Area Radiation monitor alarms that exceed normal monitor indications without a reason to expect another source such as a gas decay tank, spill, piping shine or fuel handling problem, indicate a loss of the Containment. Area temperature alarms, rising sump level indication's or unexpected system flow indications outside Containment may also indicate a loss of the Containment. If the Containment Barrier is lost without a loss of the Fuel Clad Barrier, effluent radiation readings may not increase significantly. Unexpected area temperature alarms, unexpected flow rates or sump level increases outside of Containment, however, may provide the indications that the Containment atmosphere is no longer isolated. In addition, the term "to the environment" is intended to include any leakage that cannot be isolated either directly or through systems that exhaust to the Plant Vent (e.g., leakage to the-Auxiliary Building Ventilation System) or directly to any other area outside the Containment. A safety injection, high Containment pressure or a Containment vent isolation signal represents a situation that requires the Containment to be isolated from the outside environment.. As indicated in Note 8, this EAL allows for valve closure from the Control Room, prior to event classification, to isolate any system not completely.isolated. Leakage cannot be isolated from the Control Room refers to valve(s) that did not completely close when demanded (either automatically or manually). This. includes Motor Operated Valves not controlled by isolation logic but are manually controlled from the Control Room. For example, if the isolation logic fails to cause valve closure but operator actions implemented. in the Control Room successfully isolates the Containment breach path, classification under this EAL is NOT WARRANTED. Although this EAL ALLOWS for valve closure from the Control Room, the time to attempt closure and make a decision if containment leak isolation was successful RUNS CONCURRENTLY with the EAL 15-minute assessment clock. o If, during the EAL 15-minute assessment period attempts from the Control Room to isolate the containment ARE SUCCESSFUL then, this EAL is.NOT exceeded and classification per this EAL should NOT be made. 

   "    If, during the EAL 15-minute assessment period attempts from the Control Room to isolate the containment ARE NOT SUCCESSFUL then, this EAL is exceeded and classification should be made at that time. There is no need to wait the full 15 minutes.

o If near the end of the 15 minute assessment period and the control room staff has not been able to attempt containment isolation or the EC is not convinced that an isolation attempt has been successful, then this EAL is exceeded and classification should be made at or before the 15-minute assessment time expires. Salem Page 2 of 4 Rev. 0 (draft E) EAL#:CBS=L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 Definitions: VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Barrier Loss 5.A
2. SGS Technical Specifications 3.6.3 Containment Isolation Valves
3. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
4. 1(2)-EOP-LOCA-6 LOCA Outside Containment Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: CB o5L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#:C[S-L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Judgment Initiating Condition: Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB6-L (3 points) EAL: ANY condition in the opinion of the Emergency Coordinator that indicates loss of the Containment barrier Basis: Thisese thresholds addresses any other factors that are to be used by the Eme~geRG" De-rEemergency Coordinator in determining whether the Containment barrier is lost-?F Ptentially-4e-st. In addition, the inability to monitor the barrier should also be incorporated in this threshold as a factor in Emergency Dire.to.Emerqency Coordinator judgment that the barrier may be considered lost or prtentilly ,oGt. The Containment barrier should not be declared lost or potentially los based on exceeding Technical Specification action statement criteria, unless there is an event in progress requiring mitigation by the Containment barrier. When no event is in progress (Loss or Potential Loss of either Fuel Clad and/or RCS) the Containment barrier status is addressed by Technical Specifications. Explanation/Discussion/Definitions: The Emergency Coordinator judgment threshold addresses any other factors relevant to determining if the Containment barrier is lost. Such a determination should include IMMINENT barrier degradation, barrier monitoring capability and dominant accident sequences. o Barrier degradation exists if the degradation will likely occur within two hours based on a projection of current safety system performance. o Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration of offsite monitoring results. o Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CB6-L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 AC power (Station Blackout) and ATWT EALs to assure timely emergency classification declarations. Definitions: IMMIINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Loss 8.A Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CB6oL

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SGS ECG - EAL Technical Bases EP-SC-1 11-224 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 1 - Loss of AC Power Initiating Condition: AC power capability to vital buses reduced to a single power source for 15 minutes or longer such that any additional single failure would result in complete loss of AC power to vital buses Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CUI.1 - UNUSUAL EVENT EAL: Loss of 4.16 KV Vital Bus Power Sources (Offsite and Onsite) which results in the availability of only one 4.16 KV Vital Bus Power Source (Offsite or Onsite) AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: The condition indicated by this 4G-EAL is the degradation of the off-site and on-site AC power systems such that any additional single failure would result in a station blackout. This condition could occur due to a loss of off-site power with a concurrent failure of all but one emergency diesel generator to supply power to its emeneF -vital busses. The subsequent loss of this single power source would escalate the event to an ALERT in accordance with GA-3EAL CA1.1. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power. Explanation/Discussion/Definitions: 

"Availability" means the power source can be aligned to provide power to a vital bus within 1 5 minutes or is currently supplying power to at least one vital bus.

Salem Page 1 of 2 Rev. 0 (draft E) EAL#: C UIAo

SGS ECG - EAL Technical Bases EP-SC-1 11-224 The availability of EDGs that have not been challenged to start during degradation of AC power sources to the 4KV vital buses should be based on meeting Technical Specification action requirements for loss of offsite AC power sources. The AC power distribution is summarized in Attachment 2, page 2. Emergency Classification escalates to an ALERT under EAL CA1.1 based on a loss of all offsite and all onsite AC power to all 4KV vital buses: This cold condition UNUSUAL EVENT EAL is equivalent to the hot condition ALERT EAL SA1.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05 - CU3 Example EAL #1
2. UFSAR Figure 8.2--2 500 kV Switchyard Diagram
3. UFSAR Figure 8.3-1 Auxiliary Power System Diagram
4. UFSAR 8.1.1 Utility Grid System and Interconnections
5. UFSAR 8.3.1 Power
6. SGS Technical Specifications 3.8.1.2 Electrical Power Systems - Shutdown
7. SGS Technical Specifications 3.8.2.2 AC Distribution - Shutdown
8. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
9. 1(2)-EOP-LOPA-1 Loss of All AC Power, 10.S1(S2).OP-AB.LOOP-0001(Q) Loss of Off-Site Power.,
11. S1 (S2).OP-AB.4KV-0.00 1(Q) Loss off lA 4_KVVit al Bus 12.S1(S2).OP-AB.4KV-0002(Q) Loss of 1B 4KV Vital Bus 13.S1(S2).OP-AB.4KV-0003(Q) Loss of 1C 4KV Vital Bus Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: CUM

SGS ECG - EAL Technical Bases EP-SC-1 11-224 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 1 - Loss of AC Power Initiating Condition: Loss of all offsite and all onsite AC power to vital buses for 15 minutes or longer Mode Applicability: 5 - Cold Shutdown, 6 - Refueling, D - Defueled EAL# & Classification Level: CAl.1 - ALERT EAL: Loss of all Power (Onsite and Offsite) to all 4KV Vital Buses AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal, Spent Fuel Heat Removal and the Ultimate Heat Sink (Service Water). The event can be classified as an ALERT when in cold shutdown, refueling, or defueled mode because of the significantly reduced decay heat and lower temperature and pressure, increasing the time to restore one of the e geRny-vital busses, relative to that specified for the SITE AREA EMERGENCY EAL. Escalating to SITE AREA EMERGENCY, if appropriate, is by EALs in Category R, Abnormal Rad Levels / Radielogical EffluentQGs. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Explanation/Discussion/Definitions: The intent of this EAL is to classify degraded AC power events that result in a loss of all offsite power sources (13.8 KV) to the 4KV vital buses along with a loss of all onsite power sources (EDGs). Salem Page 1 of 2 Rev. 0 (draft E) EAL#: CAI.

SGS ECG - EAL Technical Bases EP-SC-1 11-224 The AC power distribution is summarized in Attachment 2, page 2. This cold condition ALERT EAL is equivalent to the hot condition SITE AREA EMERGENCY EAL SS1.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05 - CA3 Example EAL #1
2. UFSAR Figure 8.2-2 500 kV Switchyard Diagram
3. UFSAR Figure 8.3-1 Auxiliary Power System Diagram
4. UFSAR 8.1.1 Utility Grid System and Interconnections
5. UFSAR 8.3.1 Power
6. S8S -Tech nical -Sp-ecifications 3.8.1.2 E-lectrical Power Systems- Shutcdown
7. SGS Technical Specifications 3.8:2.2 AC Distribution - Shutdown
8. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
9. 1(2)-EOP-LOPA-1 Loss of All AC Power
10. S (S2).OP-AB.LOOP-0001 (Q) Loss of Off-Site Power
11. S1(S2).OP-AB.4KV-0001(Q) Loss of 1A 4KV Vital Bus 12.S I(S2).OP-AB.4KV-0'002(Q) Loss of 1B 4KV Vital Bus
13. S1 (S2).OP-AB.4KV-0003(Q) Loss of' "1C .*

4KV Vital 

                                                     . T 7."

Bus Salem Page 2 of 2 Rev. 0 (draft E) EAL#:C , o

SGS ECG - EAL Technical Bases EP-SC-1 11-225 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 2 - Loss of DC Power Initiating Condition: Loss of required DC power for 15 minutes or longer Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CU2.1 - UNUSUAL EVENT EAL: < 114 VDC bus voltage indications on All 125 VDC vital buses for >_15 minutes (Note 3) OR < 25 VDC bus voltage indications on both 28 VDC vital buses for > 15 minutes (Note 3) AND loss of control of Safety Related Equipment from the Control Room has been confirmed Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: The purpose of this IC-EAL and its associated EALs is to recognize a loss of DC power compromising the ability to monitor and control the removal of decay heat during Cold Shutdown or Refueling operations. [This EAL is itededt* be agGipanG,,*,, .pefitingcre*. m*,,*,, the .m. . nt ho-e 

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                                                                                                                                                                                                                                  -rrr Th re.....d bu.es a... the n. mu m I..we. by Tec.hnic.al Spec.f.Got;on fGr*the Rm(o*de oG epe-a4tGn*jlt is intended that the loss of the operating (operable) train is to be considered. If this loss results in the inability to maintain cold shutdown, the escalation to an ALERT will be per CA4EAL CA4.1.

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P-n45' I5 n' rNJ C'+5'21142 /inff i C Ill/ffl t-r,;;rrn ,rvI inffor- 1, typically-1.8L1 Vol1ts per cell.] Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CU2oi

SGS ECG - EAL Technical Bases EP-SC-111-225 Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Explanation/Discussion/Definitions: The specified bus voltage indications (rounded for readability on Control Room instrumentation) are the minimum voltage requirements for operability of the 125 VDC buses and 28 VDC buses following battery discharge tests. Although continued operation may occur with degraded voltage, these values signify the minimum operable voltages allowed. This UNUSUAL EVENT EAL is the cold condition equivalent of the hot condition loss of DC power SITE AREA EMERGENCY EAL SS2.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SS3 Example EAL #1
2. SC.MD-ST.125-0004 (Q) 125 Volt Station Batteries 18 Month Service Test and Associated SurveillanceTesting Using BCT-2000
3. SC.MD-ST'28D-0004 (Q) 28 Volt Station Batteries 18 Month Service Test and Associated Surveillance Using BCT-2000
4. UFSAR 8.3.2 DC Power
5. SGS Technical Specifications 3.8.2.3.125 Volt DC Distribution.-Shutdown
6. SGS Technical Specifications 3.8.2.5 28 Volt DC Distribution- Shutdown
7. S1($-2);OP-SO.125-00051(2)A-125VDC Bus Ope-ration-.
8. S1($2).OP-SO.125-0006 1(2)B 125VDC Bus Operation
9. S1($2).OP-SO.125-0007 1(2)C 125VDC Bus Operation Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: C *2.i*

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory Mode Applicability: 5 - Cold Shutdown EAL# & Classification Level: CU3.1 - UNUSUAL EVENT EAL: RCS leakage results in the inability to maintain or restore RCS level to EITHER: o Pressurizer Level > 17% (cold calibration value) o Within the target band established by procedure (when the level band is established below the pressurizer) AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: This EAL is considered to be a potential degradation of the level of safety of the plant. The inability to maintain or restore level is indicative of loss of RCS inventory. Relief valve normal operation should be excluded from this 1-,EAL. However, a relief valve that operates and fails to close per design should be considered applicable to this 1-G.EAL if the relief valve cannot be isolated. Prolonged loss of RCS Inventory may result in escalation to the ALERT emergency classification level via either EAL CA3.1 or EAL CA4.1. Explanation/Discussion/Definitions: When Pressurizer (PZR) level drops to 17%, letdown isolates and pressurizer heaters are deenergized. The Pressurizer cold calibration level is monitored on LI-462. This condition is signaled by overhead annunciator E-36, PZR HTR OFF LVL LO. Cold calibrated Pressurizer level is indicated on computer points and SPDS. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: CU3.

SGS ECG - EAL Technical Bases EP-SC-1 11-226 In Cold Shutdown mode, PZR level may be intentionally lowered below the letdown isolation setpoint (e.g., in preparation to detension the reactor vessel head, etc.). For such evolutions, this EAL is applicable if RCS level cannot be restored and maintained within the prescribed target band specified in operating procedures. Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. EAL Basis Reference(s):

1. NEI 99--0, Rev. 05, CUI Example EAL #1
2. S1(S2).OP-AR.ZZ-0005(Q) OHA- E-36, PZR HTR OFF LVL LO
3. S1(S2).OP-IO.ZZ-0006(Q) Hot Standby to Cold Shutdown
4. S1(S2).OP-IO.ZZ-0007(Q) Cold Shutdown to Refueling
5. S1(S2).OP-SO.RC-0005 (Q) Draining the Reactor.Coolant System To >101 Foot Elevation
6. S1(S2).OP-SO.RC-0006 (Q) Draining the Reactor Coolant System < I01ft Elevation with Fuel in the Vessel Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CU3.1

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory Mode Applicability: 6 - Refueling EAL# & Classification Level: CU3.2 - UNUSUAL EVENT EAL: RCS level CANNOT be monitored with a loss of RCS inventory as indicated by ANY unexplained RCS leakage indication, Table C-I Table C-I RCS Leakage Indications o Rise in Containment sump pump run frequency o Aux Building sump level rise o PRT level rise o RWST level rise o RCDT level rise o Rise in RCS make-up rate o Observation of RCS leakage that is UNISOLABLE Salem Page 1 of 5 Rev. 0 (draft E) EAL#: CU3.2

SGS ECG - EAL Technical Bases EP-SC-111-226 Basis: This 4,-.EAL is a precursor of more serious conditions and considered to be a potential degradation of the level of safety of the plant. Refueling evo*lu.tionS that decrcase RCS water level belo. ' the RPV flange are carefully planned and procedurally controlled. An UNPLANNED event that results in water level decrcaSing below the RPV flange, or below the planned RCS w.4ater level for the giVen evolu ,,tion(if the planned RCS water level is already below the RPV flange), warrants deGo ,.oG,-,NQ deteth C ht s able to keep the coeC G9'Ve red. The allowance of 15 minuteS was chosen because iti reaSonable to -assume that leve can be restdred within this time frame using one rg moee of the redundant means of refill that sheuld be available. if level cannnt be restored in this time framle the it may indicate a more serious condition exists-. P-d-RConteveinudiaons S wl.v!ntorma ill rebuit (incluting the ALERT etmeorgencl classificati)o level via either CAl tor CAr, [The differ-ence betwe~en CLI and CU2 delels with the RCS conditions that ex-st between cold ShUtdowq and re fuefing m~odes. 1Pn cod shutdown the. RCS wil4 norma~ly be intac-t indication were to beltdrin RCS atd losde inventoryeare available. o n the refueling nee de the RmS is net intact and RPV level loss andr ntowas arre yobniterved by,different,.'4as]. This EAL addresses conditions in the R-refueling mode-_when normal means of core temperature indication and RCS level indication may'not be available. Redundant means of RPAVLRCS level indication will normally be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted. However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RPV- RCS inventory loss was occurring by observing sump and tanRk level eha~ge Table C-i indications. Sump and tank levelTable C-1i-h~reasesRCS leakage indications must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage. Escalation to the ALERT emergency classification level would be via eihep-EAL CGA-CA3.2 or EAL CA4.1. Explanation/Discussion/Definitions: During refueling, the reactor head and associated RVLIS piping are removed. Visual observation by personnel on the' refuel floor in communication with the Control Room may also provide indication of refueling cavity water level and RCS water level. Salem Page 2 of 5 Rev. 0 (draft E) EAL#:CU3,2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 In this EAL, all level indication is unavailable and the RCS inventory loss must be detected by the leakage indications listed in Table C-1. Level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the Containment to ensure they are indicative of RCS leakage. Visual observation of leakage from systems connected to the RCS in areas inside or outside the Containment that cannot be isolated could be indicative of a loss of RCS inventory. Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room. Salem Page 3 of 5 Rev. 0 (draft E) EAL#:CU3o2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, CU2 Example EAL #2
2. S1(S2).OP-SO.RVL-0001 Reactor Vessel Level Instrumentation System
3. UFSAR 5.6.5 Re'actor Vessel Water Le'vel
4. UFSAR 7.3.1.1.9 Instrumentation Used During a Loss of Coolant Accident
5. Sl(S2).OP-AB.RHR-0002(Q) Loss of RHR at Reduced Inventory
6. Sl(S2).OP-SO.RC-0005(Q) Draining the Reactor Coolant System To >101 Foot Elevation
7. UFSAR Figure 6..3-3 Containment Sump Pit
8. UFSAR 6.3.2.2 Equipment and Component Description (ECCS)
9. UFSAR Figure 6.2-17 ,Containment Isolation Pressurizer Relief Tank Connections
10. Si(S2).OP-AB.RC-0001(Q) ReactorCo0lant System Leak Salem Page 4 of 5 Rev. 0 (draft E)

EAL#:CU3o2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#:CU3o2

SGS ECG - EAL Technical Bases EP-SC'1 11 -226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory Mode Applicability: 6 - Refueling EAL# & Classification Level: CU3.3 - UNUSUAL EVENT EAL: UNPLANNED RCS level drop below EITHER of the following: o 104 ft (Reactor Vessel flange) o RCS level band (when the RCS level band is established below the Reactor Vessel flange) AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: This EAL is a precursor of more serious conditions and considered to be a potential degradation of the level of safety of the plant. Refueling evolutions that decrease RCS water level below the RPV-Reactor Vessel flange are carefully planned and procedurally controlled. An UNPLANNED event that results in water level decreasing below the RPV-Reactor Vessel flange, or below the planned RCS water level for the given evolution (if the planned RCS water level is already below the RPV-Reactor Vessel flange), warrants declaration of a NQUE due to the reduced RCS inventory that is available to keep the core covered. The allowance of 15 minutes was chosen because it is reasonable to assume that level can be restored within this time frame using one or more of the redundant means of refill that should be available. If level cannot be restored in this time frame then it may indicate a more serious condition exists. Salem Page 1 of 3 Rev. 0 (draft E3) EAL#:CU3o3

SGS ECG - EAL Technical Bases EP-SC-1 11-226 Continued loss of RCS Inventory will result in escalation to the ALERT emergency classification level via either EAL GA1-CA3.1 or EAL CA4.1. [Tho diffe r... bt... t,.. CI a..d C U2 doeals with the RCS c,-,diti.ns tht e,,i, between, cold shutdown3 and re.f.y.....g md k3 Gold shutdown the RCS wi4 normay be in.a 

                                                  .s.

an4d standeard P CS invo ntory and level mon414P Fneans ate av4ailable. !n the 1:c fueling- mode the RCS is not intact and RPV !eve& "'itory oreimoitor-ed by,diffei-et#n eane].- EAL-#-* This EAL involves a decrease in RCS level below the top of the RP*--Reactor Vessel flange that continues for 15 minutes due to an UNPLANNED event. This EAL is not applicable to decreases in flooded P--aeter--refueling cavity level, which is addressed by EAL A-92 EAL-IRU2.1, until such time as the level decreases to the level of the vessel flange. [For BWP~s] if RPV !EVel continueS to decrease and reaohcS the Low LoW ECOS Actuation Sctpoint thenR eScalation to CA! would be approGpriate. Explanation/Discussion/Definitions: 104 ft is the Reactor Vessel flange elevation. RCS water level is normally monitored using the instrument ranges illustrated in Attachment 2, page 10. During refueling, the reactor head and associated RVLIS piping are removed. Visual observation by personnel on the refuel floor in communication with the Control Room may also provide indication of refueling cavity water level and RCS water level. In cold conditions, RCS level may be intentionally lowered below the Reactor Vessel flange (e.g., detensioning the Reactor Vessel head, reduced inventory conditions, etc.). For such evolutions, this EAL is applicable if RCS level cannot be restored and maintained within the prescribed target band. This Cold Shutdown EAL represents the hot condition EAL SU7.1, in which RCS leakage is associated with Technical Specification limits. In cold conditions, these limits are not applicable; hence, the use of RCS level as the parameter of concern in this EAL. Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. EAL Basis Reference(s):

1. NEI 99-01, Rev. 05, CU2 Example EAL #1
2. S1(S2).OP-SO.RC-0005(Q) Draining the Reactor Coolant System to >101 Foot Elevation Salem Page 2 of 3 Rev. 0 (draft E3)

EAL#: CU3o3

SGS ECG - EAL Technical Bases EP-SC-1 11-226

3. S1(S2).OP-SO.RVL-0001 Reactor Vessel Level Instrumentation System
4. UFSAR 5.6.5 Reactor Vessel Water Level
5. UFSAR 7.3.1.1.9 Instrumentation Used During a Loss of Coolant Accident Salem Page 3 of 3 Rev. 0 (draft E3)

EAL#: CU3.3

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: Loss of RCS inventory Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CA3.1 - ALERT EAL: RCS level < 97.5 ft Basis: Thisese EALs serves as a precursors to a loss of ability to adequately cool the fuel. The magnitude of this loss of water indicates that makeup systems have not been effective and may not be capable of preventing further RP-V--RCS level decrease and potential core uncovery. This condition will result in a minimum emergency classification level of an ALERT. EAL ff1 [The BWVR Low-Low ECC S '~ul'tio Setpo intO :2 was- choS9n boc~ause it is 3 Standard 

                                                         %'Lvel Setpoin*t  at which S       aVailable
                             -me     injecti9n SyStems automatically stat. The PVR Bo..o.. Q         D.f the RCS Leep-SLevel setpoint was chosen because at this level remote RCS level indication may be lost and loss of suction to decay heat removal systems h@S EoeUFP may occur.-T-he Bottom ID of the R.S Loep Setpoint should be the level equal to the bott"m, of the RPV loo"p pcnetratioR     (not the Io Point Of 'the 'oop).,

The inability to restore and maintain level after reaching this setpoint would be indicative of a failure of the RCS barrier. EA L #2 [in the co~d Shutdown3 mode, POrM-a! RGS 19Ve! and RRV 'eVe!inerretto systems A44 usua!!, be available, !n te re 4 g mode.. 

                                                  ..       .orma! m..ean.s of RPV 'ee!     indic.at"on maynoa be available. Redundant mean~s of RP-V leve i;dication3 K411 uscually be insetalled (ýn cIU dingth abilty to monitor...           !nj÷*e    asure tat the ability tto to nj RPlrpte eeln                                 r          lo Oi,                d However, if a!! level indicatio,. were t         est du,4g a less of RCS i..       '.to. event., the0 opera tore, would n4eed to determ4ine that R.V                          was eocurring by obse-i4 sug4 less,~!o and tank level changes. Sump and tank level nrae must be ealuated againet other potential soureces of leakage such ae cooling water sources Th/doe Ithe containm;:ent to ensure they are indicative of RCS leakage.]

Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CA3o

SGS ECG - EAL Technical Bases EP-SC-1 11-226 [The 15 minute dur-atin forF the ioss of /ev! idi~at~en Wa GhonPbe~aU8. it iS half otf the GS! Site.A~rea Emer-gebcylydratioGP. 84- Sign~ifiant fuel dlamage iSnot eXPected tO OGE;U unti thE? Orbe GE? been UnGOeov~ed for-grep[e- th~an 1 h jr per the ap ap ,s din i-efprepeg4 t CG b*sis. T-hre-fre this.EL mee t" th7e definitin for aPn ALERT.] If RPV-RCS level continues to lower then escalation to SITE AREA EMERGENCY will be via EAL CS3.--2. Explanation/Discussion/Definitions: RCS water level is normally monitored using the instrument ranges illustrated in Attachment 2, page 10.. The centerline level of the RCS loop hot leg is at approximately 97 ft and the inside diameter of the hotleg-penetration is 29in. The bottom ID-would be 97 ft - 29/2 in. or 95 ft 9.5 in. Although NEI desires a level for this threshold that is equal to the bottom of the RCS loop hot leg penetration, the RCS level indication capability does not support detection of a threshold level that low. Mid Loop Level indication is capable of monitoring level to 97.3 ft;. so, a setpoint of 97.5 ft... has been sselected. Local, indication is also available to monitor this level. Continued inventory loss could result in a.loss of suction to the RHR System. The inability to restore and - maintain le.vel.after.reaching loop.centerline (approximately) would therefore be indicative of a failure of the RCS barrier. EAL Basis Reference(s):

1. NE! 99-01, Rev. 05, CA1 Example EAL #1
2. S1(S2).QP-SO.RC-0005(Q).Draining the Reactor Coolant System to >101 Foot Elevation.
3. UFSAR Fig-ure 5.1-1 Reactor Vessel Schematic
4. S1(S2).OP-AB.RHR-0002(Q) Loss of RHR at Reduced Inventory
5. UFSAR Figure 6.3-2 & 6.3-3 Containment Sump and Drain Trench & Containment Sump Pit
6. UFSAR 6.3.2.2 Equip'ment an"dd. Component Descriptii (ECCS)
7. UFSAR Figure 6.2-17 Containment Isolation Pressurizer Relief Tank Connections
8. SI(S2).OP-AB.RC-0001(Q) Reactor Coolant System Leak Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CA3o1

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: Loss of RCS inventory Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CA3.2 - ALERT EAL: RCS level CANNOT be monitored for ? 15 minutes with a loss of RCS inventory as indicated by ANY unexplained RCS leakage indication, Table C-1 (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Table C-I RCS Leakage Indications o Rise in Containment sump pump run frequency o Aux Building sump level rise o PRT level rise o RWST level rise o RCDT level rise o Rise in RCS make-up rate 

                     " Observation of RCS leakage that is UNISOLABLE Salem                                        Page 1 of 5                        Rev. 0 (draft E)

EAL#: CA3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 Basis: Thisese EALs serves as a precursors to a loss of ability to adequately cool the fuel. The magnitude of this loss of water indicates that makeup systems have not been effective and may not be capable of preventing further RP-V-RCS level decrease and potential core uncovery. This condition will result in a minimum emergency classification level of an ALERT. EAL #1 [The B*4'R Lw -Low ECCS Actuation Stp.int.Level 2 .. a. *ch..n be.au.. it is a standard at whi.h co 

               *etpoint ..avaablo hnjeEtion syctems autmatia.,y start. The PW. Bottom Q.;of the RCS Loop SetpOiht WaS chosen bocause, at tll:44 11nvnl0 ro~pete RCS lve!ze indication m~ay be lost and 1oS8 of suo-tion tbdo  el6a/heat renviaeyt                                            of the RC otm Q~ocf~.Th Loop Setpeintshehoued be the lo've! eqýai to the bottom of the RPV 1oop peRE4-tG (not the iv poit of (he~o~.

The ihability to restore aPd mA'r-intain level aftdr.Yoachiný this setpoint w,~,uld b indicative of a failure of the RCS barrier. -{ln the Ceold S-shutdown mode, normal RCS level and RPV level instrumentation systems will usually be available. In the RFefueling mode, normal means of RPV-RCS level indication may not be available. Redundant means of R.PV-RCS level indication will usually be installed (including the ability to mo~nitor level visually) to assure that the ability to monitor level will not be interrupted. However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RP-V-RCS inventory loss was occurring by observing Table C-i indicationsisump and tank level changeS. SUmhp and tank 16\'cl 0 eRGeasesTable C-1 RCS leakage indications must be evaluated against other potential sources of leaka.ge such as cooling water sources inside the Containment to ensure they are indicative of RCS leakage. Visual observation of leakage from systems connected to the ROS in areas inside or outside the Containment that cannot be isolated could be indicative of a loss of RPV-RCS inventoryl. fThe 15-minute duration for the loss of level indication was chosen because it is half of the EAL.GS-1-CS3.2 SITE AREA EMERGENCY EAL-duration. Significant fuel damage is not expected to occur until the core has been uncovered for greater than 1 hour per the analysis referenced in the EAL GG-1-CG3.2_basis. Therefore this EAL meets the definition for an ALERT.] If RPV-RCS level leakage indications continues and RCS level cannot be monitored for 30 minutes or more, EAL C53.2 will require to lower thn escalation to SITE AREA EMERGENCY v.ill be vi-a CS4. ExplanationlDiscussion/Definitions: Salem Page 2 of 5 Rev. 0 (draft E) EAL#:CA .

SGS ECG - EAL Technical Bases EP-SC-111-226 In this EAL, all RCS level indication is unavailable and the RCS inventory loss must be detected by the leakage indications listed in Table C-1. Level increases must be evaluated against other potential sources of leakage (SWS, Component Cooling Water, etc.) to ensure they are indicative of RCS leakage. In cold shutdown, the decay heat available to raise RCS temperature during a loss of inventory or heat removal event may be significantly greater than in the Refueling Mode. Entry into cold shutdown conditions may be attained within hours of operating at power or hours after refueling is completed. Entry into the Refueling Mode procedurally may not occur for typically a few days or longer after the reactor has been shutdown. Thus the heatup threat and therefore the threat to damaging the fuel clad may be lower for events that occur in the Refueling Mode with irradiated fuel in the Reactor Vessel (note that the heatup threat could be lower for cold shutdown conditions if the entry into cold shutdown was following a refueling). Salem Page 3 of 5 Rev. 0 (draft E) EAL#: CA3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 Definitions: UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room. EAL. Basis Reference(s):

1. NEI 99-01, Rev. 05, CA1 Example EAL #2
2. S1(S2).OP-SO.RVL-0001 Reactor Vessel Level Instrumentation System
3. UFSAR 5.6.5 Reactor Vessel Water Level
4. UFSAR 7.3.1.1.9 Instrumentation Used During a Loss of Coolant Accident
5. S1(S2).OP-AB.RHR-0002(Q) Loss of RHR at Reduced Inventory
6. S1(S2).OP-SO.RC-0005(Q) Draining the Reactor Coolant System To >101 Foot Elevation
7. Reference drawing 208915-A-8823 Sh 1
8. UFSAR Figure 6.3-3 Containment Sump Pit
9. UFSAR 6.3.2.2 Equipment and Component Description (ECCS)
10. UFSAR Figure 6.2-17 Containment Isolation Pressurizer Relief Tank Connections 11.1S(S2).OP-AB.RC-0001(Q) Reactor Coolant System Leak Salem Page 4 of 5 Rev. 0 (draft E)

EAL#:CA3o2

SGS ECG - EAL Technical Bases EP-SC-11 11 -226 This page intentionally blank Salem Page 5 of 5 Rev. 0 (draft E) EAL#: )

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CS3.2 - SITE AREA EMERGENCY EAL: RCS level CANNOT be monitored for > 30 minutes with a loss of RCS inventory as indicated by ANY of the following (Note 3): o R44A > 5 R/hr o R10B > 3500 mR/hr o R2 > 104 mR/hr o Erratic Source Range Monitor indication o ANY unexplained RCS leakage indication, Table C-1 Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Table C-1 RCS Leakage Indications o Rise in Containment sump pump run frequency o Aux Building sump level rise o PRT level rise o RWST level rise o RCDT level rise o Rise in RCS make-up rate 

                      " Observation of RCS leakage that is UNISOLABLE Salem                                           Page 1 of 4                        Rev. 0 (draft E)

EAL#:CS3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 Basis: Under the conditions specified by this 4-CEAL, continued decrease in RCS-RPV level is indicative of a loss of inventory control. Inventory loss may be due to an RCS breach, pressure boundary leakage, or continued boiling in the RP-VReactor Vessel. Thus, declaration of a SITE AREA EMERGENCY is warranted. Escalation to a GENERAL EMERGENCY is via EAL GG4CG3.2 or EAL RAG1.1. EAL -3 jln the cold shutdown mode, normal RCS level and RPV lve! instrumentation systems will usually be available. In the refueling mode, normal means of RPV-RCS level indication may not be available. Redundant means of RV-RCS level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted. However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RPV-RCS inventory loss was occurring by observing Table C-1 indications. Table C-1 RCS leakaqe indicationssump and tank level changes. SUMP and tank level i*.**. ses must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.1 The 30-minute duration allows sufficient time for actions to be performed to recover inventory control equipment. As-wateF eel in the RPVIoweFr, the dose rate above the corp 2iql inrae.... The dose rate due to this core shine shopuld result in Site specifiG monEitor indicat"ion and possible alaFrm. _[This EAL S13oUld G onScrt'atiVepl eat/mate a aite Sp ecif: c dose ýtq so tpont 4ndicatriv Of Gore unco"vey (i.e., level at TAF). R44S that do9 no÷tave *a 

                                   ,,r BWF                         insta..ed diaion.... nitors.apable Gf indicating co~re Lineovei), altern3ate 640e 6spoc/ic 19eý io'dioa tinS of GOPrs Uncovory should be

{Post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations.1 Explanation/Discussion/Definitions: This EAL applies to conditions in which the loss of decay heat removal capability has caused a significant drop in RCS water level below the bottom of the RCS hot leg penetration and core uncovery may be challenged. RCS level indication capability does not support detection of RCS levels that low and, consequently, alternate means of assessing RCS inventory loss must be used: Salem Page 2 of 4 Rev. 0 (draft E) EAL#: C332

SGS ECG - EAL Technical Bases EP-SC-1 11-226 o As water level in the Reactor Vessel lowers, the dose rate above the core will increase. The dose rate due to this core shine should result in up-scaled general area low range containment monitor (1/2R10B & 1/2R2) and high range containment monitor (1/2R44A) indication and possible alarm. A dose rate setpoint indicative of core uncovery (i.e., level at top of active fuel) is a means to detect the onset of IMMINENT core damage.. S-C-ZZ-MDC-2280 documents the basis for the threshold values for the R2, R1OB and R44A values that indicate RCS level at or approaching the top of active fuel. Data from both Unit 1 and Unit 2 was reviewed and values rounded off to provide conservative threshold values that cover both Salem units based on how many fuel assemblies are in the Reactor Vessel and includes an appropriate reduction for radioactive decay of short lived radionuclides. As Reactor Vessel level decreases life threatening levels could exist directly above the core; with water level at top of active fuel dose rates,20 feet above the dore will be in excess of 38,000 R/hr. Additionally, post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations. For EAL simplification, the thresholds are representative of a partially defueled core (80 fuel assemblies.in the Reactor Vessel). Erratic source range monitor indication may be identified by:

0. -Source rangecount rate indicators NI31B and N132B o NIS Recorder NR45 o Audio count rate
           ..o- SPDS.

o Process Computer RCS inventory loss may be detected by the leakage indications listed in Table C-1. Level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the Containment to ensure they are indicative of RCS leakage. Visual observation of leakage from systems connected to the RCS in areas irisid@ or outside the Containment that cannot be isolated could be indicative of a loss of REACTOR VESSEL inventory.- Definitions: UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room. IMMINENT: Mitigation actions have been ineffective, additional actions are not _expected to be successful, and. trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). Salem Page 3 of 4 Rev. 0 (draft E) EAL#: CS3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Basis Reference(s):

1. NEI 99-01, Rev. 05, CS1 Example EAL #3
2. S-C-ZZ-MDC-2280, EAL Dose Rates to Radiation Detectors Following Loss of RPV Level during Refueling Operation
3. Technical Specifications 3.3.1 .1 Reactor Trip System Instrumentation
4. UFSAR Table 7.5-2 Main Control Room Indicators and/or Recorders Available to the Operator to Monitor Significant Plant Parameters During Normal Operations
5. SC.IC-CC.NIS-0011(Q) N31 Source Range
6. SC.IC-CC.NIS-0012(Q) N32 Source Range
7. S1(S2).OP-SO.RC-0005(Q) Draining the Reactor Coolant System to >101 Foot Elevation
8. UFSAR Figure 6.3-2 & 6.3-3 Containment Sump and Drain Trench & Containment Sump Pit
9. UFSAR 6.3.2.2 Equipment and Component Description (ECCS)
10. UFSAR Figure 6.2-17 Containment Isolation Pressurizer Relief Tank Connections
11. Sl(S2).OP-AB.RC-0001 (Q) Reactor Coolant System Leak Salem Page 4 of 4 Rev. 0 (draft E)

EAL#:CS3o2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory; 3 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with Containment challenged Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CG3.2 - GENERAL EMERGENCY EALr. RCS level CANNOT be monitored for >_30 minutes with core uncovery indicated by ANY of the following (Note 3): o R44A > 5 R/hr o R1OB > 3500 mR/hr o R2 > 104mR/hr o Erratic Source Range Monitor indication o ANY unexplained RCS leakage indication, Table C-i AND ANY Containment Challenge indication, Table C-2 Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Salem Page 1 of 7 Rev. 0 (draft E) EAL#: C03.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 Table C-1 RCS Leakage Indications o Rise in Containment sump pump run frequency o Aux Building sump level rise o PRT level rise o RWST level rise o RCDT level rise o Rise in RCS make-up rate o Observation of RCS leakage that is UNISOLABLE Table C-2 Containment Challenge Indications o CONTAINMENT CLOSURE NOT established o Indications of > 4% H 2 inside Containment o UNPLANNED rise in Containment pressure Basis: This 4--EAL represents the inability to restore and maintain RPV-RCS level to above the top of active fuel with containment challenged. Fuel damage is probable if RRV-RCS level cannot be restored, as available decay heat will cause boiling, further reducing the RPV-RCS level. With the Ceontainment breached or challenged then the potential for unmonitored fission product release to the environment is high. This represents a direct path for radioactive inventory to be released to the environment. This is consistent with the definition of a GENERAL EMERGENCY. The GENERAL EMERGENCY is declared on the occurrence of the loss or IMMINENT loss of function of all three barriers. [These EALs are ba sed en3 concerns r~aiseed by,Generic Letter-88 17-, Less ef Dca Heat Remov/ai.L SECY 91 283, Evaluation of Shutd.w. and-Low Le P.....- Ri' k ...... NUREG- 1449, Shutdown3 and Lew Power-Operatin at Co rmer-Gial N.Ucaar-Power- Plan~ts in the united_ States, an*d, NUII4ARC 91 06., G4n*94,pe fGr Indutry A,,4-to to As*ess S-htdew* A number of variables can have a significant impact on heat removal capability challenging the fuel clad barrier. Examples include: Salem Page 2 of 7 Rev. 0 (draft E) EAL#:CG3.2

SGS ECG - EAL Technical Bases EP-SC-1 11 -226 BWPRs] n;itial vessel level, Sh.td.o.. heat removal SyStem deign* [PAR4s mid-loop, reduced level/flange level, head in place, cavity flooded, RCS venting strategy, decay heat removal system design, vortexing pre-disposition, steam generator U-tube draining. Analysis indicates that core damage may occur within aras soon as one hour following continued core uncovery, therefore, 30 minutes was conservatively chosen. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30 minute core uncovery time limit then escalation to GE would not occur. TQ~S -. ! .4I I tS .'.... do "Sit, ntigency

  • pro
                                                          .e-forre..                      e*tb,&hingCONTA!NMENT CLOSURE= fOllowg q losis of heat removal or RCS inventory, functions.]

[in the... rStag , ges f 6 6... every on6 e venP-t, it ,-, Un..ke.f th.a.t hydb*ge.* b.ui.dup due to a .or. uncover, coUld Fe-&4t ina xple s/ye mbxtufreP Of dissoKved gase nc CGntak:met~t. hoqwvAeIr. 

        ,,*-r*/m Containment            rg'.,",I 7 ,! , *ri m

monpitogp L,vl4,"I.;,O aFind cdm4qig 99-qr , should f lII;v,,r ,"I f*Ht o,,I, H be pef4FdRmcd'oL.4;tt.,4Ea~r . .. * ,//O to-verify this assumption anda GennnraIE4ýper-eq / 4 

                                , ra.                                 ,,f     Mai4i~'   oxýP84'G an*~r            F~nxt'ur'   N

[For- BW/Rs, the use of secondGary eon fa~iPibntra~diationJMoniorS.should pro vide indi'cation off P, _creased releaso that may be indicative of a challenge to9 Secondary containm~ent. The site &ep eific r-adiation monitor values should be baed6nthe _FR'§xiQP safe valus" be~ause thes values are easily r- 6nizable and havee an .epmc.rgenc-y basic.1 E-AL42-Table C-1 RCS leakaqe indicationsSump ad* tank level increases must be evaluated against other potential sources of. leakage such as cooling water-sources inside the Ceontainmennt to ensure they are indicative of RCS leakage.: {ln the Ceold Sshutdown mode,.normal RCS level and RPV level instrumentation systems will usually be. available. In the RPefueling mode, normal means.of RPV-RCS level indication may not be available. Redundant means .of RPV-RCS level indication will usually be installed (including the.-ability to monitor level visually).to assure that. the ability to monitor level will not-be interrupted. However, if all level indication were..to be lost during a loss of RCS inventory: event, the Operators would need to determine that RPV-RCS inventory loss was occurring by observing Table C-1 indications' Table C-1 RCS leakaqe indicationssump and tank le-'el changes. S-,mP 6, +,a.nk 16V.19 i.reases. . must be evaluated against other potential sources of leakage such as cooling water sources inside the Ce-ontainment to ensure they are indicative of RCS leakage.* As water level in the RPV lowers, the dose rate above the core WHlI increase. The dose rat due to this core shihe should result in site SPecific*R1Eoni6r ind~icationG and poss~i~ble alarmp. 

-[This       EAL 8sheould conPlservatively estim3ate a site specific doGse rate setpoint indicative of cnore uncoGverq,' 1( I. 1elV-1 at,.TQA F). For BWRs that do not have indage.d radiation monitetrs capal Salem                                                           Page 3 of 7                                             Rev. 0 (draft E)

EAL#:C33o2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 of indic-ating cer-e ui3Govery, aktor4ate. site &poolicGlevei 43dir-atiGot;9ofcorou-c9nI~ &44' ,be [Post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations.] Explanation/Discussion/Definitions: This EAL applies to conditions in which a significant drop in Reactor Vessel water level below the RCS hot leg penetration has occurred with prolonged core uncovery. RCS level indication capability does not support detection of RCS levels that low and, consequently, alternate means of assessing RCS inventory loss must be used: 0 As water level in the Reactor Vessel lowers, the dose rate above the core will increase. The dose rate due to this core shine should result in up-scaled general area low range containment monitor (1/2R1OB & 1/2R2) and high range containment monitor (1/2R44A) indication and possible alarm. A dose rate setpoint indicative of core uncovery (i.e., level at top of active fuel) is a means to detect the onset of IMMINENT core damage. S-C-ZZ-MDC-2280 documents the basis for the threshold values for the R2, R1i B and R44A values that indicate RCS level at or approaching the top of active fuel. Data from both Unit 1 and Unit 2 was reviewed and values rounded off to provide conservative threshold values that cover both Salem units based on how many fuel assemblies are in the Reactor Vessel and includes an appropriate reduction for radioactive decay of short lived radionuclides. As Reactor Vessel level decreases life threatening levels could exist directly above the core; with water level at top of active fuel dose rates 20 feet above the core will be in excess of 38,000 R/hr. Additionally, post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations. For EAL simplification, the thresholds are representative of a partially defueled core (80 fuel assemblies in the Reactor Vessel). o Erratic source range monitor indication may be identified by: o Source range count rate indicators NI31B and N132B o NIS Recorder NR45 o Audio count rate o SPDS o Process Computer RCS inventory loss may be detected by the leakage indications listed in Table C-1. Level increases must be evaluated against other potential sources of leakage such as Salem Page 4 of 7 Rev. 0 (draft E) EAL#:C(3,2

SGS ECG - EAL Technical Bases EP-SC-111-226 cooling water sources inside the Containment to ensure they are indicative of RCS leakage. Visual observation of leakage from systems connected to the RCS in areas inside or outside the Containment that cannot be isolated could be indicative of a loss of RCS inventory. Three conditions are associated with a challenge to Containment: o The status of CONTAINMENT CLOSURE indicates the ability to rely on the Containment as a barrier to fission product release. o When hydrogen concentration in the Containment atmosphere exceeds 4%, the possibility of an explosive mixture exists inside Containment. Elevated Containment atmosphere hydrogen concentration is alarmed at > 2% by overhead annunciator C-23, CNTMT H 2 LVL HI o An UNPLANNED rise in Containment pressure in the Cold Shutdown or Refueling Mode may signify an energy addition to the Containment such that the Containment cannot be relied upon as a barrier to fission product release.. Definitions: UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room... CONTAINMENT CLOSURE: Is the Salem procedurally defined action taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. CONTAINMENT CLOSURE status is checked'and verified using S1(S2-).OP-AB.CONT-0001 (Q). UNPLANNED: A parameter change or an event that is not the result of an intended evolution:and reqluiires corrective or mitigative actions. IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful,.and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Basis Reference(s):

1. NEI 99-01, Rev. 05, CG1 Example EAL #2
2. OU-AA-103 Shutdown Safety Management Program
3. S1 (S2).OP-AB.CONT-0001 (Q) Containment Closure
4. S-C-ZZ-MDC-2280, EAL Dose Rates to Radiation Detectors Following Loss of RPV Level during Refueling Operation
5. Technical Sp.ecifications 3.3.1.1 Reactor Trip System. Instrumentation
6. UFSAR Table 7.5-2 Main Control Room Indicators and/or Recorders'Available to the Operator to Monitor Significant Plant Parameters- During Normal Operations Salem Page 5 of 7 Rev. 0 (draft E)

EAL#:C(3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226

7. SC.IC-CC.NIS-0011(Q) N31 Source Range
8. SC.IC-CC.NIS-0012(Q) N32 Source Range
9. S1(S2).OP-SO.RC-0005(Q) Draining the Reactor Coolant System to >101 Foot Elevation
10. UFSAR Figure 6.3-2 & 6.3-3 Containment Sump and Drain Trench & Containment Sump Pit
11. UFSAR 6.3.2.2 Equipment and Component Description (ECCS)
12. UFSAR Figure 6.2-17 Containment Isolation Pressurizer Relief Tank Connections
13. S1 (S2).OP-AB.RC-0001 (Q) Reactor Coolant System Leak 14.1 (2)-EOP-FRCC-1 Response to Inadequate Core Cooling - Basis Document (pg 16)
15. Salem EOP Setpoint Basis Document - Vendor Doc. #320832 16.S1(S2).OP-AR.ZZ-0003(Q) OHA C-23, CNTMT H 2 LVL HI Salem Page 6 of 7 Rev. 0 (draft E)

EAL#:CG3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 This page intentionally blank Salem Page 7 of 7 Rev. 0 (draft E) EAL#: C83.2

SGS ECG - EAL Technical Bases EP-SC-1111-227 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 4- RCS Temperature Initiating Condition: UNPLANNED loss of decay heat removal capability with irradiated fuel in the Reactor Vessel Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CU4.1 - UNUSUAL EVENT EAL: An UNPLANNED Loss of Decay Heat Removal functions AND RCS Temperature has risen to > 200°F Basis: This -G-EAL is be-a precursor of more serious conditions and, as a result, is considered to be a potential degradation of the level of safety of the plant. In cold shutdown, the ability to remove decay heat relies primarily on forced cooling flow. Operation of the systems that provide this forced cooling may be jeopardized due to the unlikely loss of electrical power or RCS inventory. Since the RCS usually remains intact in the GCeold Sshutdown mode a large inventory of water is available to keep the core covered. LL~ ~~ y IL~L4'..' i *~A.I .J Lt LY & i if Alt'i f; F-i H f V H Hf 4 i i if ý f i ýifif ifif if 1 i i it if " ' ' " ' " ' " - 'r-:; 11 P I;q W n~it ~nr.'!r f~r fun/nc/K' 1fl0 bn~~~-c' l~fn n,,-Ior I ,-i *~ r fk-, rmýý'+r inn ' k oo, 1'-4,, r-,,-, 71'-siC 1 l1- -- , 1-1-,r- 4. fn-F-,-n 14 1-ýr-fln +Inno f ei-nn-',nn f/Sn 41- 4 rb,- 4 

                                                                                                     ~in o ,nsrf' 4L~/M4.1-- f ~ ,             ,    -,-  -f     I       ~-,-

r.l with ,-,adiato*d f;/ i41 the R /V(Pote that the atup th-,reat could , be loWr for oGIo ShUtdOW, conditionsif the entn' into cold sh,.tdo~wn w.e fo!lloino e rmfue.!/nn-) In .odd/]fi/ne ehnne.r.eter.e 

        ,            bea           to m49oitor RcSte..                               ratupesand RPV 'eve!                         9othat o*o÷4,              +     e4et4eo4-a",,

i-li 1 AA/In t' A I 1A1;11 n/r', Ir irf rnciitieorf 1 During refueling, the level in the RP-VReactor Vessel will normally be maintained above the Reactor Vessel RP--V-flange. Refueling evolutions that decrease water level below the Reactor Vessel RPV-flange are carefully planned and procedurally controlled. Loss of forced decay heat removal at reduced inventory may result in more rapid increases irfRCS/-RPV temperatures depending on the time since shutdown. r,;,lk, the oeldshutdewn mod-e noR-mal*men. .f core temperature indic.tion and RCS lee. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CU4.i

SGS ECG - EAL Technical Bases EP-SC-1 11-227 indicatioR apr therefore Procedurally installcd to assur- that the ability to monitor level will no be inter~rupted: Ho 'e.; if all level ad teRPerture indiGAtion to be loSt in 6ithcr the 

                                                                          .wec
.oid shutdoWn of refueling modes, EAL 2 Would     ,n result     declar.tion- of a NOUE if both temperature and level indication cAnnot be ,                 ithin 1 5 minuteS from the v.,re                                df bo h means of indication. Escalation to ALERT would be via EAL CA3.1 based on an inventory loss or EAL CA4.1 based on exceeding its temperature criteria.

Explanation/Discussion/Definitions: The Technical Specification cold shutdown temperature limit is 200 0 F. RCS coolant temperature may be indicated by the following instrumentation: o Core-e)xit TCs (compmuter points T003-iA, T-0022-A, T004-6A, T0014A) o Hot Leg temperatures (computerlpoints T0419A, T0439A, T0459A, T0479A) o RHR HX inlet temperatures (computer points T0630A and T0631A) temperatur o RHR HX outlet temperatures (T0627A, T2360A) o RCS cold leg temperatures (T0406A, T0426A, T0446A, T0466A) Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolutiorn and requires corrective or mitigative actions:. EAL Bases"Reference(s)- ."

1. NEI 99-01., Rev. 05,..CU4 Example EAL #1
2. SGS Technical Specifications Table 1.1, Operational Modes
3. 1(2)OP-AB.RHR-0001(Q) Loss of RHR
4. 1(2)OP-AB.RHR-0002(Q) Loss of RHR at Reduced Inventory
5. SC.OP-DL.ZZ-0011(Q) Reactor Coolant System Heatup/Cooldown Log Salem Page 2 of 2 Rev. 0 (draft-E)

EAL#: CU4o]

SGS ECG - EAL Technical Bases EP-SC-1 11-227 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 4 - RCS Temperature Initiating Condition: UNPLANNED loss of decay heat removal capability with irradiated fuel in the Reactor Vessel Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CU4.2 - UNUSUAL EVENT EAL: An UNPLANNED Loss of Decay Heat Removal functions AND Loss of BOTH of the following: o All RCS Temperature indication o All RCS level indication AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: This 9-GEAL is be a precursor of more serious conditions and, as a result, is considered to be a potential degradation of the level of safety of the plant. In cold shutdown, the ability to remove decay heat relies primarily on forced cooling flow. Operation of the systems that provide this forced cooling may be jeopardized due to the unlikely loss of electrical power or RCS inventory. Since the RCS usually remains intact in the Ceold Sshutdown mode a large inventory of water is available to keep the core covered. poe.Entry into the t-efu'e'"3g mode proce dur,,r4j, mayi not ene-uF~for typi'aIly !g00 houre (site sepoifie-) or !on3ger- a fteFthe lra-fl ~ 4 i;*ashtq~i, Thus the hea tup th~eat an~d theim-Aqr the threat to damaging the fuel Glad dmay be lowerý for events that occur-!n the re fu,914ng ,'node I-fi+I irrr4L+ f l ;nt Hn ý O 11 /rnrftý fin~ fl~i -,#, -- 1,4,n 1 fF- -- 1,I4 -14r - I-Salem Page 1 of 3 Rev. 0 (draft E) EAL#:CU4.2

SGS ECG - EAL Technical Bases EP-SC-1 11-227 

.... dt...q.. if the  try. 4.to 'oid s   [. was.'
                                            .gp .fueling).

f.4G.. a. 

                                                            *3             addition, the operate ohulid be ob, to mný91p;ito RCS temp e.. tur.. and RP-V level oqG that e.c. lation to the ale level via CA4 or- CA wil    M1 ocur if regu4ro d.

During refueling , the level in the RPV-RCS will normally be maintained above the RP-V Reactor Vessel flange. Refueling evolutions that decrease water level below the Reactor Vessel RPV-flange are carefully planned and procedurally controlled. Loss of forced decay heat removal at reduced inventory may result in more rapid increases in RCS/RP-V temperatures depending on the time since shutdown. [Unlik. the cold. .hutd.w. m-ode,] nNormal means of e-re-RCS temperature indication and RCS level indication may not be available in the refueling mode. Redundant means of RPV RCS level indication are therefore procedurally installed to assure that the ability to monitor level will not be interrupted. However, if all level and temperature indication were to be lost in either the _Ceold Sshutdown of R:efueling n~0d~s,this EAL 2-would result in declaration of a NQUE if both temperature and level indication cannot be restored within 15 minutes from the loss of both means of indication. Escalation to ALERT would be via EAL CA3.1 based on an inventory loss or EAL CA4.1 based on exceeding its temperature criteria. Explanation/Discussion/Definitions: RCS water level is normally monitored using the instrument ranges in Attachment 2, page 10. During refueling, the reactor head and associated RVLIS piping are removed. Visual observation. by personnel on the refuel floor in communication with the Control Room may also provide indication of refueling cavity water level and RCS water level. RCS coolant temperature may be indicated by the following instrumelntation: o Core exit TCs (computer points T0031A, T0022A, T0046A.T0014A) o Hot Leg temperatures (computer points T0419A, T0439A, T0459A, T0479A) o RHR HX inlet temperatures (computer points T0630A and T0631A) temperatue o RHR HX outlet temperatures (T0627A, T2360A) o RCS cold leg temperatures (T0406A., T0426A, T0446A, T0466A) Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. EAL Bases Reference(s);

1. NEI 99-01, Rev. 05, CU4 Example EAL #2
2. S1(S2).OP-S0.RC-0005(Q) Draining the Reactor Coolant System to> 100 Foot Elevation
3. S1(S2).OP-SO.RVL-0001 Reactor Vessel Level Instrumentation System
4. UFSAR 5.6.5 Reactor Vessel Water Level Salem. - Page 2 of 3 Rev. 0 (draft E)

EAL#: CU64D

SGS ECG - EAL Technical Bases EP-SC-1 11-227

5. UFSAR 7.3.1.1.9 Instrumentation Used During a Loss of Coolant Accident (LOCA)
6. 1(2)OP-AB.RHR-OOO1(Q) Loss of RHR
7. 1(2)OP-AB.RHR-0002(Q) Loss of RHR at Reduced Inventory
8. SC.OP-DL.ZZ-0011(Q) Reactor Coolant System Heatup/Cooldown Log Salem Page 3 of 3 Rev. 0 (draft E)

EAL#:CU4.2

SGS ECG - EAL-Technical Bases EP-SC-1 11-227 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 4 - RCS Temperature Initiating Condition: Inability to maintain plant in cold shutdown Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CA4.1 - ALERT EAL: An UNPLANNED event results in RCS temperature > 200'F for > Table C-3 duration OR An UNPLANNED event results in RCS pressure increase > 10 psig due to a loss of RCS cooling (this portion of the EAL does NOT apply in Solid Plant conditions) Table C-3 RCS Heatup Duration Thresholds RCS Integrity CONTAINMENT CLOSURE Duration Threshold Intact AND NOT in reduced NOT Applicable 60 minutes ** inventory status NOT Intact OR Established 20 minutes ** RCS is in a reduced inventory status NOT Established 0 minutes 

     ** IF a Decay Heat Removal System is placed in operation within the duration threshold and RCS Temperature is lowering, THEN this EAL is NOT Applicable Salem                                         Page 1 of 5                            Rev. 0 (draft E)

EAL#: CA4. ]

SGS ECG - EAL Technical Bases EP-SC-1 11-227 Basis: For EAL !, 1 st Condition Tthe RCS Rehea-t-Heatup Duration Threshold table addresses complete loss of functions required for core cooling for greater than 60 minutes during R-refueling and Ceold Sshutdown modes when RCS integrity is established. [RCS integrity should be considered to be in place when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams). The status of CONTAINMENT CLOSURE in this condition is immaterial given that the RCS is providing a high pressure barrier to fission product release to the environment.] The 60 minute time frame should allow sufficient time to restore cooling without thereebekng-a substantial degradation in plant safety. The RCS HeatupRehea Duration Threshold table also addresses the complete loss of functions required for core cooling for greater than 20 minutes during R4efueling and Ceold Sshutdown modes when CONTAINMENT CLOSURE is established but RCS integrity is not established or RCS inventory is reduced J(e.g., mid-loop operation in PWRs)]. b*"s d*,sGus". abeve, RCS into gr4qy-sh-uel b-e--assume toe ei ie hRteRS ~sueb6ýdr &4 its noermpal conditioný for-the colid s!ud~/ Re fGper-ation,(eog., noG fr'~eeze c ala or-noGzz daR4sX]-The allowed 20 minute time frame was included to allow operator action to restore the heat removal function, if possible. [The alo .... d ti÷;  ;ýr.... Io . ist, ,, the guidapn-c pr.ovided by Ge*n*e Letter 8. 17*, "L7=oss of QeGay,Heat Re*moya!'" (die cussed4 'ta o " h it baSiS) andI is belieeddto9 be con ee,'watiVe giVen that a 1low pressure Ceantinm ent baRe ri to fission product r-elease is established.] Finally, complete loss of functions required for core cooling during Rrefueling and Ceold Sshutdown modes when neither CONTAINMENT CLOSURE nor RCS integrity are established. [RCS integrity is in place when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams). No delay time is allowed because the evaporated reactor coolant that may be released into the Containment during this heatup condition could also be directly released to the environment.] The note (**) in Table C-3 indicates that this EAL is not applicable if actions are successful in restoring an RGS decayheat removal system to operation and RCS temperature is being reduced within the specified time frame. SREAL*2* t2nd Condition The 10 psig pressure increase addresses situations where, due to high decay heat loads, the time provided to restore temperature control, should be less than 60 minutes. The RCS pressure setpoint chosen should be 10 psig or the lowest pressure that the site can read on installed Control Board instrumentation that is equal to or greater than 10 psig. Escalation to SITE AREA EMERGENCY would be via EAL CS-1 EAL- CS3.2 should boiling result in significant R-PV-RCS level loss leading to core uncovery. Salem Page 2 of 5 Rev. 0 (draft E) EAL#:CA4ol]

SGS ECG - EAL-Technical Bases EP-SC-111-227 rFor PWRs, this iC and(its ao,,iatd EA4Ls are bosed Onc,*.... ra:oe d by ,cn.,r Lotter 88 Te, "Loss of Decay Heat Reomoeva. "A number of phendmenaouch a p n uZati., Tesatmxing, steam goarenatar U tube raiing, RecS level differtecehs wen operating at acmid loop condeition, decay heat rome vol system design, and 'j"'e' 1/2c'hl 'nmntation 75Pbb!6ý4q can3 lead to Gonditions where- do cay heat removal! is lost an d.eG~-E coGGoe5 can occur.NC ana4yses sheKw t,hatthqi~i am-- sqeG~e tha 

                                      '-~            aue1                           e 0m and Sevorei core d~amage with i'n anheour after deceay hea~t remGval iS lost.]

A loss of Technical Specification components alone is not intended to constitute an ALERT. The same is.true of a momentary unplanned excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available. The Emergency Direc*te,-.Emergency Coordinator must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is IMMINENT. If, in the judgment.of the 

  .egcn.... OirectorEmergqency Coordinator, an IMMINENT situation is at hand" the classification should be made as if the threshold has been exceeded.

Explanation/Discussion/Definitions: 200'F is the Technical Specification cold shutdown temperature limit.' 10 psig is one-half of the 20 psig minor division on 1(2)PI-403. This instrument has a range of 0 to 600 psig. This RCS pressure indication is also displayed on SPDS Point U1(2)PT0403S and P250 Computer Point P0499A. "Intact" is. defined as all RCS penetrations between the core-and Containment atmosphere are isolated, and a minimum of two RCS loops with U-tubes not drained and their associated Steam Generators are available as heat sinks for natural circulation. "Available as Heat Sinks!'- indicates each associated Steam Generator has a feed makeup source available, secondary water level is above the U:-tubes, and a Steam Generator vent path exists. A "Reduced Inventory" condition exists when Reactor Vessel level is less than 101 ft. RCS coolant temperature may be indicated by the following.instrumentation: o Core exit TCs (computer points T0031A, T0022A, T0046A, T0014A) o Hot Leg temperatures (computer points T0419A, T0439A, T0459A, T0479A) o RHR HX inlet temperatures (computer points T0630A and T0631A),teMPeratUreS o RHR HXoutlet temperatures (T0627A, T2360A) o RCS cold leg temperatures (T0406A; T0426A, T0446A, T0466A) Definitions: UNPLANNED: A parameter change or an event that is-not the result of an intended evolution and requires corrective or mitigative actions. Salem Page 3 of 5 Rev. 0 (draft E) EAL#:

SGS ECG - EAL Technical Bases EP-SC-1 11-227 CONTAINMENT CLOSURE: Is the Salem procedurally defined action taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. CONTAINMENT CLOSURE status is checked and verified using S1(S2).OP-AB.CONT-0001(Q). IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). Salem Page 4 of 5 Rev. 0 (draft E) EAL#: CA4.i

SGS ECG - EAL Technical Bases EP-SC-1 11-227 EAL Bases Reference(s):...

1. NEI 99-01, Rev. 05, CA4 Example EAL #1 & #2
2. OU-AA-103 Shutdown Safety Management Program
3. S1(S2).OP-AB.CONT-0001(Q) Containment Closure
4. S1(S2).OP-ST.CAN-0007(Q) Refueling Operations - Containment Closure
5. SGS Technical Specifications Table 1.1 Operational Modes
6. S1(S2).IC-CC.RCP-0070(Q) 1(2)PT-403 Reactor Coolant System Hot Leg Pressure Channel II
7. S1(S2).OP-SO.RC-0005(Q) Draining The Reactor Coolant System To >101 Foot Elevation
8. UFSAR 5.6.5 Reactor Vessel Water Level
9. S1(S2).OP-SO.RVL-0001 Reactor Vessel Level Instrumentation System, Note pg 16 10.1 (2)OP-AB.RHR-0001 (Q) Loss of RHR
11. 1(2)OP-AB.RHR-0002(Q) Loss of RHR at Reduced Inventory
12. SC.OP-DL.ZZ-001 1(Q) Reactor Coolant System Heatup/Cooldown Log Salem Page 5 of 5 Rev. 0 (draft E)

EAL#: CA4o ]

SGS ECG - EAL Technical Bases EP-SC-111-228 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 5 - Communications Initiating Condition: Loss of all onsite or offsite communications capabilities Mode Applicability: 5 - Cold Shutdown, 6 - Refueling, D - Defueled EAL# & Classification Level: CU5.1 - UNUSUAL EVENT EAL: Loss of all Table C-4 Onsite communication methods affecting the ability to perform routine operations OR Loss of all Table C-4 Offsite communication methods affecting the ability to perform offsite notifications Table C-4 Communications Systems System I Onsite Offsite Direct Inward Dial System (DID) X X Station Page System (Gaitronics) X Station Radio System X Nuclear Emergency Telephone X System (NETS) Centrex Phone System (ESSX) X NRC (ENS) X Salem Page 1 of 4 Rev. 0 (draft E) EAL#: CU5,

SGS ECG - EAL Technical Bases EP-SC-1 11-228 Basis: The purpose of this IG-EAL and its aSSociat"d EAL-- is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate issues with off-site authorities. The loss of off-site communications ability is expected to be significantly more comprehensive than the condition addressed by 10 CFR 50.72. The availability of one method of ordinary off-site.communications is su'ffic'ient to inform federal, state, and local authorities of plant issues. This EAL is intended to be used only when extraordinary means (e.g., relaying of information from radio transmissions, individuals being sent to off-site Iocations, etc.) are being utilized to make communications possible. Explanation/Discussion/Definitions: Onsite and Offsite global communications include one or more of the systems listed in Table C-4. Direct Inward Dial System (DID) Direct Inward Dial (DID) system is named for the dominant feature of the commercial telephone service provided by the local telephone company for the site. DID allows station telephones to be extensions or tied lines of the same systems. These exchanges can take advantage of backup power supplies provided to the stations, and may use either PSEG microwave, commercial telephone system microwave, or buried cable transmission systems to maintain external communications. This commercial telephone service is available as an additional backup for the NETS and Centrex/ESSX 1 system. Station Page System (Gaitronics) Gaitronics is a completely transistorized voice communication system with five voice channels: one page and five party. The system is designed for use in extreme environmental conditions such as dust, moisture, heat and noise. The system consists of handsets, speakers and their associated amplifiers. The power for this system is 120 volts AC from an.inverted DC source to provide reliable communications during an emergency. Station Radio System The Operations and Fire Protection Department UIHF radio system is a' multi-frequency system used routinely by both station Operations Departments and the Fire Protection Department. When an emergency event is declared, these radio frequencies serve both station Operations Support Centers (OSC). Salem Page 2 of 4 Rev. 0 (draft E) EAL#: C US. I

SGS ECG - EAL Technical Bases EP-SC-11 11 -228 Nuclear Emergency Telephone System (NETS) The Nuclear Emergency Telecommunications System (NETS) is a privately controlled, self-contained telephone exchange that operates as a closed system, not accessible from other phone exchanges. This feature allows the system to be dedicated to emergency response use. The system may use PSEG microwave, commercial telephone system microwave, fiber optics, or buried cable transmission as needed. The exchange switching equipment is maintained at the Environmental & Energy Resource Center (EERC). As an independent system with an uninterruptible power supply, it may operate with or without local phone service or external power. Centrex Phone System (ESSX) The Centrex/Electronic Switch System Exchange 1(Centrex/ESSX 1) is also a privately controlled exchange, which PSEG operates with its own microwave signal system. This system is also independent of local phone service, since each circuit is independently wired. The microwave signal is generated from corporate facilities in Newark, NJ, separated from any local effects of weather or telephone use. The exchange is accessible from other exchanges, but circuits are located only in PSEG facilities. It is considered the primary backup for the NETS system. NRC (ENS) The Emergency Notification System (ENS) is a dedicated communications system with the NRC, which is part of the Federal Telecommunications System (FTS) and consists of direct lines to the NRC. FTS lines are used to provide general accident information. These telephones are installed in the Control Room, TSC, and the EOF. This EAL is the cold condition equivalent of the hot condition EAL SU6.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, CU6 Example EAL #1 and 2
2. PSEG Nuclear Emergency Plan, Section 7 Communications
3. UFSAR 9.5.2 Communications System Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: C1LUM5

SGS ECG - EAL Technical Bases EP-SC-111-228 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: CU5A

SGS ECG - EAL Technical Bases EP-SC-1 11-229 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 6 - Inadvertent Criticality Initiating Condition: Inadvertent Criticality Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CU6.1 - UNUSUAL EVENT EAL: UNPLANNED sustained positive startup rate observed on nuclear instrumentation Basis: This -G-EAL addresses criticality events that occur in Cold Shutdown or Refueling modes [(NUREG 144. -0,Shutwdow.. an.d Lo, Row..er Ope.ration,at ,*..Mer-ciaol Nuclear Row.er R. nts in the *,it4d States)] such as fuel mis-loading events. and indvertent dilutin evnts. This -c EAL indicates a potential degradation of the level of safety of the plant, warranting a NQUE classification. [This c*opnditioGn**.be ideif*i*d ,,sing p. r4ed moniitor tatup ote montor. T-he ter, "sutaied"is usedl in order to allow axnlu sion of expected shot! term4 pes/i ye perioda/startup rates fei--PPaine4fuelbundle or control/rodý- moemnt - drog core alteraai~gfG ttS ý 1B14RS. The-Se short termp pos'tWve perend&s/staartyp ,rates are the result of th3e in crease in eutron po9pulation dUe to S"bG4t'-a'm M'tiplication.] Escalation would be by Emnergency'Dirceto! EmergencV Coordinator Judgment. Explanation/Discussion/Definitions: The term "sustained" is used in order to allow exclusion of expected short term positive startup rates from planned fuel bundle or control rod movements during core alteration. These short term positive startup rates are the result of the increase in neutron population due to subcritical multiplication. Positive reactor startup rate may be identified by: o Source range startup rate indicators N131 D and N132D o NIS Recorder NR45 o Audio count rate o SPOS o Process Computer Salem Page 1 of 3 Rev. 0 (draft E) EAL#:CU o

SGS ECG - EAL Technical Bases EP-SC-1 11-229 This EAL is the cold condition equivalent of the hot condition EAL SU3.1. Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. Salem Page 2 of 3 Rev. 0 (draft E) EAL#: C U (. 1

SGS ECG - EAL Technical Bases EP-SC-1 11-229 EAL Bases Reference(s): 1, NEI 99-01, Rev. 05, CU8 Example EAL #1 2, Technical Specifications 3.3.1.1 Reactor Trip System Instrumentation 3, UFSAR Table 7.5-2 Main Control Room Indicators 4, SC.IC-CC.NIS-0011(Q) N31 Source Range

5. SC.IC-CC.NIS-0012(Q) N32 Source Range Salem Page 3 of 3 Rev. 0 (draft E)

EAL#:CU6.1

EAL Attachmen ts (Support Materials)

SGS ECG - EAL Technical Bases EP-SC-1 11-230 Attacment i - Us f ison Prduct Barrer Tabk Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown A point system is used to determine the Emergency Classification Level based on the Fission Product Barrier Table. Each Fission Product Barrier Loss and Potential Loss threshold is assigned a point value as noted below. Perform the following:

1. Review all columns of the Fission Product Barrier Table and identify which need further review.
2. For each of the three barriers, determine the EAL with the highest point value. No more than one EAL should be selected for each barrier.
3. Add the point values for the three barriers.
4. Classify based on the point value sum as follows:

If the sum Classify as: EAL Att# 3 UNUSUAL ANY loss or ANY potential EVENT loss of Containment 1 ANY loss or ANY potential 4, 5 ALERT loss of either Fuel Clad or 2 RCS Loss or potential loss of ANY two barriers 3 SITE AREA OR 6-11 EMERGENCY Potential loss of 2 barriers with the loss of the 3rd barrier Loss of ANY two barriers 12,13 GENERAL AND 4 EMERGENCY Loss or potential loss of third barrier

5. Implement the appropriate ECG Attachment.
6. Continue to review the Fission Product Barrier Table for changes that could result in emergency escalation or de-escalation.

Salem Page 1 of 1 Rev. 0 (draft E) Attachment I- Use of FPLI Tab

SGS ECG - EAL Technical Bases EP-SC-1 11 -231 Attachment 2 - EAL Basis Figures Figures referenced in the basis discussions of the EALs are listed in this Attachment. Title Page No. AC Power Distribution 2 CFST - Core Cooling 4 CFST - Shutdown Margin 5 CFST - Heat Sink 6 CFST - Thermal Shock 7 Thermal Shock Limit A Curve 8 CFST - Containment Environment 9 RCS Level Instrument Ranges 10 Salem Page 1 of 10 Rev. 0 (draft E) Rg u ÷s

SGS ECG - EAL Technical Bases EP-SC-1 11-231 AC Power Distribution The 500-kV switching station is connected to three 500-kV transmission lines. Two transmission lines go north to two major switching stations: PSE&G New Freedom Switching Station and Atlantic City Electric's Orchard Switching Station. The New Freedom Switching Station is connected to the PSE&G 230-kV bulk power system via four 500/230-kV autotransformers. Orchard Switching Station is also connected to Atlantic City Electric's 230-kV bulk power system via a 500/230-kV autotransformer. In addition, it is connected to the Pennsylvania / New Jersey / Maryland 500-kV interconnected system. The third transmission line serves as a tie line to the adjacent Hope Creek 500-kV switchyard line which is also integrated into the Pennsylvania / New Jersey / Maryland 500-kV interconnected system. The 500-13 kV station power transformers are connected to different bus sections of the 500-kV switching station: o 13-kV north ring bus: Each 500-13 kV transformer T1 and T2 feeds two (one for each unit) 13-4 kV station power transformers T1 1, T21 and T1 2, T22 associated with group buses.

  • o 13kV south bus: Each 500-13kV transformer T3 and T4 respectively and feeds two (one for each unit) 13 4kV station power transformers T1 3, T24 and T1 4, T23 associated with vital buses and circulating water switchgear. The 13-4kV station power transformers T1 3 and T1 4 (Unit 1) share the loads of three vital buses and two CW bus sections while T21 and T22 (Unit 2) share the loads of three vital buses and two CW bus sections.

The onsite power sources for each unit consists of the main generator, the emergency diesel generators (one for each vital bus), and the Unit 3 40-MW gas turbine generator (one for both units). Any two EDGs and their associated vital buses can supply sufficient power for operation of the required safeguards equipment for a design basis LOCA coincident with a loss of offsite power. For the *purposes of the EAL, availability of EDGs that have not been challenged to start during degradation of AC power sources to the 4KV vital buses should be based on meeting Technical Specification action requirements for loss of offsite AC power sources. The gas turbine generator can be manually started and paralleled with normal sources of plant startup or standby power but is normally used for peaking purposes. Procedure AB.LOOP-0001 (Q) provides guidance to use the gas turbine to energize a 13KV ring bus during a blackout if necessary. The gas turbine generator is not controlled by technical specifications, however, and for classification purposes under this EAL cannot be credited as a power source for the 4KV vital buses. Salemn Page 2 of 10 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-231 AC Power Distribution (cont'd) 17W I- .E S% .00K K - 5-DOW. I*-+ING DEANS 1021 2~4' 50021 DISC 1.5 HOPECREEK4 '.7

'. +.., ,o i Salem Page 3 of 10 Rev. 0 (draft E)

Rg ures

SGS ECG - EAL Technical Bases EP-SC-1 11-231 CFST - Core Cooling Salem Page 4 of 10 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-231 CFST - Shutdown Margin 

        ~~~JYELLuriv 1,-REE                C.A.--E Salem                                 Page 5 of 10  Rev. 0 (draft E)

Rgure s

SGS ECG - EAL Technical Bases EP-SC-1 11-231 CFST - Heat Sink E CTO' ELLOw ,r . LLDYYELLN R HS FAHS-A 

                                -- l-     FRPHS-3       FRIHS-2 T.-        ...........

Salem Page 6 of 10' Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-I 11-231 CFST - Thermal Shock Salem Page 7 of 10 Rev. 0 (draft E) Mgures

SGS ECG - EAL Technical Bases EP-SC-1 11-231 Thermal Shock Limit A Curve IF'T'S PLANT OF-EFRUTIONAL L I I, TS (2tR VE 

     " Frt1001) i2j LU 300
                                                             .*                4 IN TE LP ERRA TU.RE "F Salem                             Page 8 of 10                       Rev. 0 (draft E) igures

SGS ECG - EAL Technical Bases EP-SC-1 11-231 CFST - Containment Environment T eNTWOEINT LESS7 THAN 7EX fi EL-L F p E-3 Salem Page 9 of 10 Rev. 0 (draft E) Mgujres

SGS ECG - EAL Technical Bases EP-SC-1 11-231 RCS Level Instrument Ranges CAVTY, c~__ L.EVEL PZR COLD CAL MIDLOOP SIGHT WIDE RANG GLASS LEVEL JNDICATI INDO:CATIO.P 1.Q., RVUS REDUCED INVENTORY I 

                                                 . .IDLOOP..

Si09.O" INDiCATION sti,,O Le-Salem Page 10 of 10 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-232 Attachment 3 - Definitions Selected words in the ECG Initialting Conditions (ICs) and Emergency Action Levels (EALs) have been set in all capital letters and bolded.These words are defined terms having specific meanings as they relate to this document and the definitions of these terms are provided below and in the basis for the EAL that the word is used in. AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. A large AIRCRAFT is referred to as an AIRLINER. AIRLINER/LARGE AIRCRAFT: Any size or type of AIRCRAFT with the potential for causing significant damage to the plant (refer to the Security Contingency Plan for a more detailed definition). BOMB: Refers to an explosive device suspected of having sufficient force to damage plant systems or structures. CIVIL DISTURBANCE: A group of persons violently protesting station operations or activities at the site. CONFINEMENT BOUNDARY: Is the barrier(s) between areas containing radioactive substances and the environment and includes the multi-purpose canister (MPC) and, for the purposes of this EAL, the associated cask shielding. CONTAINMENT CLOSURE: Is the Salem procedurally defined action taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. CONTAINMENT CLOSURE status is checked and verified using S1(S2).OP-AB.CONT-0001 (Q). CREDIBLE / ACTUAL THREAT: Is a threat which poses a likely and serious danger to the safe operation of the facility or to site personnel and public safety. DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies Salem Page 1 of 4 Rev. 0 (draft E) De~flnkria

SGS ECG - EAL Technical Bases EP-SC-1 11-232 o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit o Insufficient system pressure from keep-fill pumps o Elevated area temperatures or radiation levels o Increased sump pump operation in areas in' which the system is located EXPLOSION: A rapid, violent, unconfined combUstion, or catastrophic failure bf pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. FAULTED: (PWRs) In a steam generator, the existence of secondary side leakage that results in an uncontrolled drop in steam generator pressure or the steam generator being completely depressurized. FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is prefer'red but isNO'T required: if large quantities of smoke and heat are obser-ved. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the sta'tion. - HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy. equipment, take HOSTAGES, and/or intimidate PSEG to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILEýACTMON should not be const-rued to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may. include violent acts between individuals in the OCA). HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and dec*ption, equipped with suitable Weapons capable of killing, maiming, or causing destruction. IDENTIFIED LEAKAGE: As defined in T/S, shall be leakage (except Reactor Coolant Pump Seal Water i.njectibn)'into closed systems, such as pump seal or valve packing leaks that are captured and conducted to a s ump or collecting tank, or, shall be leakage Iinto the containment atmosphere from s6urces that are both slpecifically located and known eith~er not to' ihterfere with the operation of the leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE, or, shall be Reactor coolant system leakage through a steam generator to the secondary system (primary-to-secondary leakage). Salem Page 2 of 4 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-232 IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. MALICIOUS ACT: Purposeful malevolent actions directed at compromising reactor safety and thus could directly or indirectly endanger the public health and safety. MINIMUM EXCLUSION AREA (MEA): The closest location just beyond the OWNER CONTROLLED AREA where a member of the general public could gain access. For Salem the MEA is 0.79 miles. NORMAL PLANT OPERATIONS: Activities at the plant site associated with routine testing, maintenance, or equipment operations, in accordance with normal operating or administrative procedures. Entry into abnormal or emergency operating procedures, or deviation from normal security or radiological controls posture, is a departure from NORMAL PLANT OPERATIONS. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. PRESSURE BOUNDARY LEAKAGE: As defined in T/S, shall be leakage (except steam generator tube leakage) through a non-isolable fault in a Reactor Coolant System component body, pipe wall or vessel wall. PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability, or personnel safety. PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. RUPTURED: (PWRs) In a steam generator, existence of primary-to-secondary leakage of a magnitude sufficient to require or cause a reactor trip and safety injection. SABOTAGE: Deliberate damage, mis-alignment, or mis-operation of plant equipment with the intent to render the equipment inoperable. Equipment found tampered with or damaged due to malicious mischief may not meet the definition of SABOTAGE until this determination is made by security supervision. Salem Page 3 of 4 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-232 SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION. SIGNIFICANT TRANSIENT: An UNPLANNED event based on EC judgment, but includes as a minimum any one of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, or (4) Safety Injection Activation. TAMPERING: Means deliberately damaging, disabling, or altering equipment necessary for safe shutdown or security equipment necessary for the protection of the facility. Confirmed tampering implies that a criminal activity may have occurred which requires a threshold of proof for a reason to believe that no other possibility exists for the incident other than tampering. UNIDENTIFIED LEAKAGE: As defined in T/S, shall be all leakage which is not IDENTIFIED LEAKAGE. UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room. UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. VALIDATED: AIRCRAFT threat call from the NRC that is confirmed to be authentic. Calls from the NRC are VALIDATED by use of the NRC provided authentication code or by making a return call to the NRC Headquarter Operations Center and confirming threat information with the NRC Operation Officer. AIRCRAFT threat calls from other agencies, NORAD, FAA, or FBI should be VALIDATED by calling the NRC Operations Officer. VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, and paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included. VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. Salem Page 4 of 4 Rev. 0 (draft E) Definitions

SGS ECG - EAL Technical Bases EP-SC-111-233 Attachment 4 - Glossary of Abbreviations & Acronyms Acronyms and Abbreviations used in the ECG and ECG basis document are listed in this attachment. AAAG - Accident Assessment Advisory Group (Delaware) AB - Auxiliary Building AC - Alternating Current ADMSS - Administrative Support Supervisor - TSC AFST - Auxiliary Feedwater Storage Tank AFW - Auxiliary Feedwater ALARA - As Low As Reasonably Achievable ARM - Area Radiation Monitor ASAP - As Soon As Possible ASM - Administrative Support Manager ATWT - Anticipated Transient Without Trip Aux - Auxiliary BKGD - Background BKR - Breaker (electrical circuit) BLDG - Building BNE - Bureau of Nuclear Engineering (NJDEPE) CAS - Central Alarm Station CCPM - Corrected Counts per Minute CEDE - Committed Effective Dose Equivalent CDE - Committed Dose Equivalent CET - Core Exit Thermocouple CFCU - Containment Fan Coil Unit CFR - Code of Federal Regulations CFST - Critical Safety Function Status Tree CIS - Containment Isolation System CM1 - Primary Communicator (CR) CM2 - Secondary Communicator (CR) CNTMT - Containment (Barrier) CoC - Certificate of Compliance CO2 Carbon dioxide CP - Control Point CPM - Counts Per Minute CPS - Counts Per Second CR - Control Room CRS - Control Room Supervisor CREF - Control Room Emergency Filter System Salem Page 1 of 6 Rev. 0 (draft E) AbrevMton & Acronyms

SGS ECG - EAL Technical Bases EP-SC-111-233 CVCS Chemical and Volume Control System DC Direct Current DDE Deep Dose Equivalent DEI Dose Equivalent Iodine DEMA Delaware Emergency. Management Agency DEP Department of Environmental Protection (NJ) DHS Department of Homeland Security DID Direct Inward Dial (phone system) DOE Department of Energy DOT Department of Transportation DPCC/DCR Discharge Prevention, Containment, & Countermeasures/Discharge Cleanup & Removal Plan DPM Decades per Minute DPM Disintegrations per Minute DRCF Dose Rate Conversion Factor EACS - Emergency Air Conditioning, System (Control Room) EAL - Emergency Action Level EAS - Emergency Alert System (Broadcast) ECCS - Emergency Core Cooling Systems ECG Event Classification Guide EC Emergency Coordinator EDG Emergency Diesel Generator EDO - Emergency Duty Officer" EERC - Energy & Environmental Resource Center (Old NTC). EMRAD - Emergency Radio (NJ) ENC - Emergency News Center, ENS - Emergency Notification System (NRC) EOC - Emergency Operations Center (NJ & DE) EOF - Emergency Operations Facility EOP - Emergency Operating Procedures EPA - Emergency Preparedness Advisor EPA - Environmental Prote ction Agency'. EPIP - Emergency Plan Implementing Procedure EPM - Emergency Preparedness Manager EPZ - Emergency Planning Zone (Plume EPZ = 10 Miles, Ingestion EPZ 50 miles) ERDS - Emergency Response Data System ERF - Emergency Response Facility ERM - Emergency Response Manager ERO - Emergency Response Organization ESF - Engineered Safety Feature ESSX - Electronic Switch System Exchange (Centrex) (Newark 973 Exchange phone system) FAA - Federal Aviation AdmIinistration Salem Page 2 of 6 Rev. 0 (draft E) Abre~ai's&Acronym

SGS ECG - EAL Technical Bases EP-SC-1 11-233 FBI - Federal Bureau of Investigation FC - Fuel Clad (Barrier) FFD - Fitness For Duty FHB - Fuel Handling Building FPB - Fission Product Barrier FRCC - Functional Restoration Core Cooling FRCE - Functional Restoration Containment Environment FRCI - Functional Restoration Coolant Inventory FRERP - Federal Radiological Emergency Response Plan FRHS - Functional Restoration Heat Sink FRSM - Functional Restoration Shutdown Margin FRTS - Functional Restoration Thermal Shock FTS - Federal Telecommunications System (NRC) GE - General Emergency HCGS - Hope Creek Generating Station HEPA - High Efficiency Particulate Absorbers HP - Health Physics HVAC - Heating, Ventilation & Air Conditioning HX - Heat Exchanger lAW - In Accordance With IC - Initiating Condition ICMF - Initial Contact Message Form IDLH - Immediately Dangerous to Life and Health IPEEE - Individual Plant Examination of External Events IR - Intermediate Range ISFSI - Independent Spent Fuel Storage Installation I/S - In Service ISOL - Isolation Keff - Effective Neutron Multiplication Factor KI - Potassium Iodide KV - Kilovolt (1000 volts) LAC - Lower Alloways Creek LCO - Limiting Condition for Operation LDC - Learning Development Center (aka - NAB or TB2) LDE - Lens Dose Equivalent LEL - Lower Explosive Limit LFL - Lower Flammability Limit LLD - Lowest Level Detectable LOCA - Loss of Coolant Accident LOP/LOPA - Loss of Offsite Power/ Loss of Offsite Power Accident Salem Page 3 of 6 Rev. 0 (draft E) AbbevM~ns& Acroyms

SGS ECG - EAL Technical Bases EP-SC-1 11-233 LPZ Low Population Zone MBD - Mixed Bed Demineralizer MDA - Minimum Detectable Amount MEA - Minimum Exclusion Area (Salem = .79 miles, HC = .56 miles) MEES - Major Equipment &,Electrical Status (Form) MET - Meteorological t , . MIDAS - Meteorological Information Data Acquisition System MIMS - Metal Impact Monitoring System MOU - Memorandum of Understanding MRO - Medical Review Officer MSIV - Main Steam Isolation.Valve. MSLI - Main Steam Line Isolation NAB - Nuclear Administration Building (aka - LDC or TB2) NAWAS - National Attack Warning Alert System NCO - Nuclear Control Operator NEI - Nuclear Energy Institute NEO - Nuclear Equipment Operator NETS - Nuclear Emergency Telecommunications System NFE - Nuclear Fuels Engineer NFPB - Normal Full Power Background NG - Noble Gas NJSP - New Jersey State Police NOAA - National Oceanographic and Atmospheric Administration NOSF - Nuclear Operations Support Facility NR Narrow Range ' NRC Nuclear Regulatory Commission NSP - Nuclear Site Protection NUMARC - Nuclear Management and Resources Council NWS - National Weather Service OBE - Operating Basis Earthquake OCA - Owner Controlled Area ODCM - Offsite Dose Calculation Manual OEM - Office of Emergency Management OHA - Overhead Annunciators OSB - Operational Status Board (Form) OSC - Operations Support Center PAG - Protective Action Guideline PAR - Protective Action Recommendation PIM - Public Information Manager PMP - Pump PORV - Power Operated Relief Valve Salem Page 4 of 6 Rev. 0 (draft E) Abbrevg'aUons & Acronyms

SGS ECG - EAL Technical Bases EP-SC-111-233 PRT - Pressurizer Relief Tank PSEG - Public Service Enterprise Group PSIA - Pounds per Square Inch Absolute PSIG - Pounds Square Inch Gauge PWR - Pressurized Water Reactor PWST - Primary Water Storage Tank PZR - Pressurizer RAC - Radiological Assessment Coordinator RAD - Radiation RAL - Reportable Action Level RC - Reactor Coolant RCA - Radiologically Controlled Area RCAM - Repair and Corrective Action Mission RCDT - Reactor Coolant Drain Tank RCP - Reactor Coolant Pump RCS - Reactor Coolant System (Barrier) RHR - Residual Heat Removal RM - Recovery Manager RMO - Recovery Management Organization RMS - Radiation Monitoring System ROIC - Regional Operations & Intelligence Center (NJSP) RPS - Radiation Protection Supervisor RPS - Reactor Protection System RRC - Remote Response Center (in NOSF) RSM - Radiological Support Manager RVLIS - Reactor Vessel Level Instrumentation System RWST - Refueling Water Storage Tank SAE - Site Area Emergency SAM - Severe Accident Management SAS - Secondary Alarm Station (Security) SAT - Satisfactory SBO - Station Blackout SCBA - Self Contained Breathing Apparatus SCP - Security Contingency Procedure SDE - Shallow Dose Equivalent SDM - Shutdown Margin SFP - Spent Fuel Pool S/G - Steam Generator SGS - Salem Generating Station SGTR - Steam Generator Tube Rupture SI - Safety Injection SJAE - Steam Jet Air Ejector Salem Page 5 of 6 Rev. 0 (draft E) Abbreations & Acronyms

SGS ECG - EAL Technical Bases EP-SC-1 11-233 SM - Shift Manager SNM - Special Nuclear Material SOS - Systems Operations Supervisor (Security) SPDS - Safety Parameter Display System SRPT - Shift Radiation Protection Technician SSCL - Station Status Checklist (form) SSE - Safe Shutdown Earthquake SSM - Site Support Manager SSNM - Strategic Special Nuclear Material STA - Shift Technical Advisor SUR - Start-up Rate T-COLD - Temperature Cold (Leg) T-HOT - Temperature Hot (Leg) TAF - Top of Active Fuel - BWR TDR - Technical Document Room TEDE - Total Effective Dose Equivalent TOAF - Top of Active Fuel - PWR TPARD - Total Protective Action Recommendation Dose T/S - Technical Specifications TSC - Technical Support Center TSS - Technical Support Supervisor.. TSTL Technical Support.-Team Leader TSTM Technical Support Teami Member UE Unusual Event UFSAR Updated Final Safety Analysis Report' UHS Ultimate Heat Sink USCG United States Coast Guard VCT Volume Control Tank VDC Volts Direct Current VLV Valve WB Whole Body WR Wide Range Salem Page 6 of 6 Rev. 0 (draftlE) AbobravNatins &Acronyms

SGS ECG - EAL Technical Bases EP-SC-111-234 Attachment 5 - SGS-to-NEI 99-01 EAL Cross-Reference This cross-reference is provided to facilitate association and location of a Salem Generating Station EAL within the NEI 99-01 iC/EAL identification scheme. Further information regarding the development of the SGS EALs based on the NEI guidance can be found in the EAL Comparison Matrix. SGS NEI 99-01 EAL IC Example EAL RU1.1 AU1 1 RU1.2 AU [ 1 RU1.3 AUl 3 RU2.1 AU2 1 RU2.2 AU2 2 RA1.1 AA1 1 RA1.2 AA1 1 RA1.3 AA1 3 RA2.1 AA2 2 RA2.2 AA2 1 RA3.1 AA3 1 RS1.1 AS1 1 RS1.2 AS1 2 RS1.3 AS1 4 RG1.1 AG1 1 RG1.2 AGI 2 RG1.3 AG1 4 CU1.1 CU3 1 CU2.1 CU7 1 CU3.1 CUl 1 CU3.2 CU2 2 Salem Page 1 of 6 Rev. 0 (draft E) Cross-R~eference

SGS ECG - EAL Technical Bases EP-SC-1 11-234 SGS NEI 99-01 EAL IC Example A EAL CU31.3 CU2 1 CU4.1 CU4 1 CU4.2 CU4 2 CU5.1 CU6 1,2 CU6.1.. CU8 1. CA 1.1,': CA3 1 CA3.1 CA1 1 CA3.2 CA! 2. CA4.1 CA4. 1,2 CS3.2 CSl 3. CG3.2 CG1 2 HU1.1 HUl 1-HO1-.2 2 2Hu. HU1.3 HU1 4: Hu-.4 . HU 1 3-HU1.5 Hui. 5 HU*. .. Hu2 1 HU2.2 HU2 2 HU3.ý HU3 1 HU3.2 HU3. 2. HU4.1 HU4. 1,2,3 HU6.1 HU5 1 HA1.1 HA1 1 HA1.2 HAl 2 HA1.3 HAl 4 HA1.4 HAI 3 HA1.6 HAl 5 Salem Page 2 of 6 Rev. 0 (draft E) cross-Referace

SGS ECG - EAL Technical Bases EP-SC-l 11-234 SGS NEI 99-01 EAL IC Example EAL HA2.1 HA2 1 HA2.2 HA2 1 HA3.1 HA3 1 HA4.1 HA4 1,2 HA5.1 HA5 1 HA6.1 HA6 1 HS4.1 HS4 1 HS5.1 HS2 1 HS6.1 HS3 1 HG4.1 HG1 1,2 HG6.1 HG2 1 SU1.1 SUl 1 SU3.1 SU8 2 SU4.1 SU2 1 SU5.1 SU3 1 SU6.1 SU6 1,2 SU7.1 SU4 1 SU7.2 SU4 2 SU8.1 SU5 1,2 SA1.1 SA5 1 SA3.1 SA2 1 SA5.1 SA4 1 SS1.1 SS1 1 SS2.1 SS3 1 SS3.1 SS2 1 SS5.1 SS6 1 SG1.1 SG1 1 SG3.1 SG2 1 Salem Page 3 of 6 Rev. 0 (draft E) Cross-Reference

SGS ECG - EAL Technical Bases EP-SC- 111-234 Fission Product Barrier EALs SGS NED 99=01 EAL Barrier Threshold FB1-L FC Loss 1 FB4-L FC Loss 2 FB2-L FC Loss 3 FB3-L FC Loss 6 FB5-L FC Loss 8 FB1-P FC P-Loss 1 FB2-P FC P-Loss 1 FB3-P FC P-Loss 3 FB4-P FC P-Loss 4 FB5-P FC P-Loss 8 RB2-L RCS Loss 2 RB3ý-L RCS Loss 4 RB1-L RCS Loss 6 RB4-L RCS Loss 8 RB1-P RCS P-Loss 1 RB2-P RCS P-Loss 1 RB3-P RCS P-Loss 2. RB4-P RCS P-Loss 8 CB1-L CNTMT Loss 2 CB2-L CNTMT Loss 2 CB3-L CNTMT Loss 4 CB4-L CNTMT Loss 4, CB5-L CNTMT Loss 5 CB6-L CNTMT Loss 8 CB1-P CNTMT P-Loss 2 CB6-P CNTMT P-Loss 2 CB7-P CNTMT P-Loss 2 Salem Page 4 of 6 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-234 SGS NEI 99-01 EAL Barrier Threshold CB8-P CNTMT P-Loss 2 CB3-P CNTMT P-Loss 3 CB4-P CNTMT P-Loss 3 CB5-P CNTMT P-Loss 6 CB2-P CNTMT P-Loss 7 CB9-P CNTMT P-Loss 8 Salem Page 5 of 6 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-234 This page intentionally blank Salem Page 6 of 6 Rev. 0 (draft E) Cross-Refeersnas

SGS ECG - EAL Teclmical Bases EP-SC-1 11-2-35 Saleem RadioIogicaý EAL Setpoint Calculation Document NElI 99-01, Rev. 05 EALs

Purpose:

This is a reference document that contains the methodology and calculations used in developing the thresholds for radiological release based Emergency Action Levels (EALs). The radiological EALs covered under this document are based on EALs AU1, AA1, ASI and AGI in NEI-99-01, Rev. 05, "Methodology for Development of Emergency Action Levels". Reference Materials: o NEI 99-01, Rev. 05 - Methodology for Development of Emergency Action Levels, EALs AUl, AA1, AS1 and AGI o NEI 99-01, Rev. 05 - Appendix A: Basis for Radiological Effluent EALs o Salem ODCM Rev. 24 o EPA 400-R-92-00 1, Manual or Protective Action Guides and Protective Actions for Nuclear Incidents Terms & Calculation Constants and origin: o ODCM - Offsite Dose Calculation Manual o Hours in one year: 365.25 days X 24 h-rs/day = 8766 hours o EDE - Effective Dose Equivalent o CDE - Committed Dose Equivalent o CEDE - Committed Effective Dose Equivalent = CDE X Weighting Factor (thyroid per 10CFR20) o TEDE - Total Effective Dose Equivalent = EDE + CEDE o PAG - Protective Action Guideline: Per EPA = 1000omRem TEDE dose or 5000 mRem thyroid dose. Actual or projected values above these guidelines will require offsite protective actions to be implemented. o ODCM Rad Effluent Limit - 500 mRero/year is a total site Noble Gas limit that includes Salem 1, Salem 2 and Hope Creek. Therefore, Salem will have an administratively controlled limit of 1/2,' the total site limit or 250 rnRern/year for EAL calculation purposes. o Allocation Factor (AF) = .5 - As defined in the Salem ODCM, (page 83) this is an administrative control imposed to ensure that the combined releases from Salem Units 1 and 2 and Hope Creek will not exceed the regulatory limit from the site. The Site AF is only used in the UE and Alert EALs. Salem Page 1 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-l 11-235 Salem Rad o ogicaR EAL Setpoint CaIlcuilation Document NEI 99-01, Rev. 05 EALs " X/Q = Site Specific Atmospheric dispersion to the site boundary. UI and U2 Value = 2.2E-06 sec/m3 . Origin - Salem ODCM, Rev. 24,. Table 2-2.1 and 2-2.2, Parameters for Gaseous Alarm Setpoint Determinations.' o DRCF Site Specific Dose Rate Conversion Factor. U1 and U2 Value = 4.7E+02 troem/year per uCi/ i 3 . Origin - Salem ODCM, Rev. 24, Table C-i, Effective Dose Factors, Noble Gases -Total Body and Skin - Total Body Effective Dose Factor. Index: (Radiological Release EAL Calculations) Salem EALS: Pa~e#:- Unusual Event EAL AU 1L. 1 - (Default Release Rate EAL) 4 Unusual Event EAL AU 1.2 - (2 time alarm) No Calc needed Unusual. Event EAL AU 1.3 - (Sample Analysis. Concentration) 5 Unusual Event EAL AU 1.4 - (Perimeter Monitoring System - NA) Unusual Event EAL AU1.5 - (Dose Assessment - NA) Alert EAL AA 1.1 - (Default Release Rate EAL) 6 Alert EAL AA1.2 - (200 time alarm) No Calc needed Alert EAL AA1 .3 - (Sample Analysis Concentration) 7 Alert EAL AAl .4- (Perimeter Monitoring System - NA) Alert EAL AA1.5 - (Dose Assessment- NA) Site Area Emergency EAL AS 1.1 - (Default Release Rate EAL) 8 Site Area Emergency EAL AS 1.2 - (Dose Assessment) 9. Site Area Emergency EAL AS 1.3 - (Perimeter Monitoring Sys - NA) Site Area Emergency EAL ASI .4- (PA boundary dose rate) 10 Site Area Emergency EAL AS 1.4*- (1-13 1 Field Survey Sampie Analysis) 11 General Emergency EAL AGI.1 - (Default Release Rate EAL) 12 General Emergency EAL AG1.2 - (Dose Assessment) 13 General. Emergencyi EAL AGi.3- (Perimeter Monitoring Sys - NA) General Emergency EAL AG1.4 - (PA bouindary dose rate) 14 General Emergency EAL AG1.4 - (1-131 Field Survey Sample Analysis) 15 Salem Page 2 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-I 11-23)5 Salem Radiologicall EAL Setpoint Calculation Document NEEl 99o01, Rev. 05 EALs Submitted By: Craig Banner Date: 12-15-2009 EP Review By: Gary Young Date: 12-17-2009 Techn-ical Review: ____Jenny Shelton________________ Date: 06-04-2010 Salem SFAM Review: Phil Quick Date: 06-07-2010 HC SFAM Review: ____John Molner______________ Date: 06-04-2010 CFAM Approval: David Burgin Date: 06-09-2010 Salem Page 3 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-I 111-235 Salem Radiologicak EAL Setpoint Calculation Document NEEl 99-01, Rev. 05 EALs Calculation for: Unusual Event EAL AUI.1 - (Default Release Rate EAL) Objective of Calculation: Provide a Salem Radiological Release Rate value that equates to a Release that is > 2 times the ODCM limit of 500 mRem/year. Discussion: The ODCM limit of 500 rnRero/year is a total site limit that includes Salem 1, Salem 2 and Hope Creek. Therefore, Salem 1 &2 will have an administratively controlled limit of /Athe total site limit or 250 inReroyear for EAL calculation purposes. This EAL does not include Iodine Release Rates, since the Plant Vent does not have an Iodine detector. Release Rate = Total Noble Gas Release Rate from Salem (Unit 1 & Unit 2) which would result in a TEDE Dose Rate of 250 mRem/year, The EAL value will be 2 times this release rate. Derivation / Calculation: Radiological ODCM Limit Calculation for Noble Gas: Release Rate (uCi/Sec) = ODCAMLiinit(M Re 7i / year) * (SiteAllocationFactor) (ODCMX / 0) * (ODCMDRCF) ODCM Limit = 500 mRemlYear 3 Salem ODCM X/Q = 2.20E-06 sec/rn Salem ODCM DRCF = 4.70E+02 mRem/yr/uCi/m.3 Site Allocation Factor = 5.OOE-01 Release Rate (uCi/Sec) = (5007Rem/yr) * (5.OOE - 01) (2.20E - 06sec/ 773 ) * (4.70E + 02771 Re 7n / yr / pCi / 7 3) Release Rate = 2.42E+05 uCi/Sec (Also the ODCM Limit Release Rate Value) EAL Value = 2 times the Release Rate UE EAL Value: (EAL # RU11) Total (SI & 52) NoIble Gas Release Rate > 4.84E+05 jiCi/sec Salemn Page 4 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-235 Salem Radiological EAL Setpoint Calculation Document NEI 99-01, Rev. 05 EALs Calculation for: Unusual Event EAL AU1.3 - (Sample Analysis Concentration) Objective of Calculation: Provide a Radiological Release Noble Gas and Iodine Sample Concentration that equates to a Release that is > 2 times the ODCM limit of 500 mRen/year. Discussion: The ODCM limit of 500 mRern/year (Noble Gas/Total Body) and 1500mReim'year (1-13 1/Child Thyroid) is a total site limit that includes Salem 1, Salem 2 and Hope Creek. Therefore, Salem 1&2 will have an administratively controlled limit (allocation factor) of 1/2/2 the total site limit or 250 mReml-year (Noble Gas/Total Body) and 750 moRero/year (I-13 1/Child Thyroid) for EAL calculation purposes. This allocation factor is used in the calculation that derived the Noble Gas and Iodine release rates. Derivation / Calculation: Calculation of the threshold sample concentrations are as follows: Formula: Concentration (uCi/cc) = Sin7gleUnit ReleaseRate *2 Con'ersionFactor* TVentFlowRate I-)21E + 0-5p/Ci / sec* 2 Noble Gas Sample Concentration= .2- +- i c = 6.4E-03 tCi/cc 472xSOOOOcfin I]-)3] Sample ConcOentration =I ME+00,uisec*2 = 5.6E-07 tCi/cc 472x80000cfin Where: o Single Unit (UI or U2) Release Rate (Noble Gas) = Total Noble Gas Release Rate from Salem (Unit 1 & Unit 2) as derived for EAL AU 1.1 split between Unit 1 and 2 (divided by 2) = 2.42E+05 uCi/Sec/2 = 1.21E+05 uCi/Sec per Unit. o Single Unit (UI or U2) Release Rate (Thyroid/I-131) = 10.5 uCi/Sec per unit as per ODCM, Rev. 24, Section 2.3.2 o 2 = EAL criteria of 2X ODCM value o 472 = conversion factor (28,317 cc/ft3 x 1 mirI60 sec) o 80000 cfir- = Plant Vent Flow (normal) UE EAL Values: (EAL# RU1,3) Noble Gas Sample Concentration > 6o4E-03 piCi/ce 11-131 Sample Concentration > 5.6E-07 /aCi/cc Salem Page 5 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC- 111-235 Salem Radiollogical EAL Setpoint Calculation Document NEI 99-019 Rev. 05 EALs Calculation for: ALERT EAL AA1.1 - (Default Release Rate EAL) Objective of Calculation: Provide a Radiological Release Rate value that equates to a Release that is > 200 times the ODCM limit of 500 n-Rem/year. Discussion: The ODCM limit of 500 mRem/year is a total site limit that includes Salem 1, Salem 2 and Hope Creek. Therefore, Salem 1 &2 will have an administratively controlled limit of 1 the total site limit or 250 toReml/year for EAL calculation purposes. This EAL does not include Iodine Release Rates, since the Plant Vent does not have an Iodine detector. Release Rate = Total Noble Gas Release Rate from Salem (Unit 1 & Unit 2) which would result in a TEDE Dose Rate of 250 mRerm/year. The EAL Value will be > 200 times the release rate. Derivation / Calculation: ODCM Limit Calculation for Noble Gas: Release Rate (uCi/Sec) = (ODCMLiniit-nm Re 7m/ yea*)* (SiteAllocationFacior) (ODCMX / Q) * (ODCMDRCF) ODCM Limit = 500 mRem/Year 3 Salem ODCM XIQ = 2.20E-06 sec/mi 3 Salem ODCM DRCF = 4.70E+02 mRem/yr/uCi/m Site Allocation Factor = 5OOE-01 Release Rate (uCi/Sec) (500n Reini/ yr).* (5.00E - 01) (2.20E - O6sec/ 777) *(4.70E + 02M Re i/yr/ Ci / 77.3 ) Release Rate = 2.42E+05 uCi/Sec EAL Value = > 200 times the Release Rate Alert EAL Value: (EAL# RAIL 1) Total (51 & S2) Noble Gas Release Rate > 4084E+07 j.tCUsec Salem Page 6 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC- 111-23) 5 Salem Radiological EAL Setpoint Calculation Document NEI 99-01, Rev. 05 EALs Calculation for: ALERT EAL AA1.3 - (Sample Analysis Concentration) Objective of Calculation: Provide a Radiological Release Noble Gas and Iodine Sample Concentration that equates to a Release that is > 200 times the ODCM limit of 500 toRern/year. Discussion: The ODCM limit of 500 toRemolyear (,Noble Gas/Total Body) and 1500mRenlryear (1-13 I/Child Thyroid) is a total site limit that includes Salem 1, Salem 2 and Hope Creek. Therefore, Salem 1&2 will have an administratively controlled limit (allocation factor) of / the total site limit or 250 mRe!Olyear (Noble Gas/Total Body) and 750 mRenl/year (I-131/Child Thyroid) for EAL calculation purposes. This allocation factor is used in the calculation that derived the Noble Gas and Iodine release rates. Derivation / Calculation: Calculation of the threshold sample concentrations are as follows: Formula: Concentration (uCi/cc) = Sigle Unit Re leaseRate

  • 200 ConversionFactor* VentFlowvRate Noble Gas Sample Concentration =.21E+05pCi/sec*200 = 6.4E-01 jCi/cc 472xSOOOOqf*m 1-131 Sample Concentration = 10.5E + 00,Ci / sec* =200 5.6E-05 [tCi/cc 472xSOOOOcfin Where:

o Single Unit (Ul or U2) Release Rate (Noble Gas) = Total Noble Gas Release Rate fiom Salem (Unit 1 & Unit 2) as derived for EAL AU 1.1 split between Unit 1 and 2 (divided by 2) = 2.42E+05 uCi/Sec/2 = 1.21E+05 uCi/Sec per Unit. o Single Unit (UI and U2) Release Rate (Thyroid/I-13 1) = 10.5 uCi/Sec per unit as per ODCM, Rev. 24, Section 2.3 2 o 200 = EAL criteria of > 200X ODCM value o 472 = conversion factor (283 17 cc/ft-3 x I min/60 sec) o 80000 cfln = Plant Vent Flow (normal) Alert EAL Values: (EAL# RAI.3) Noble Gas Sample Concentration > 6.4E-01 jiCi/cc 11-131 Sample Concentration > 5.6E-05 itCl/cc Salem Page 7 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Teclmical Bases EP-SC-l 11-235 Salem Radiological EAL Setpoint. Calculation Document NEE 99-01, Rev. 05 EALs Calculation for: SITE AREA EMERGENCY - EAL AS1.1 - (Default Release Rate EAL) Objective of Calculation: Provide a Radiological Release Rate value that equates to a Release resulting in an offsite dose of > 100 mrem EDE at or beyond the site boundary. Discussion: This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. The monitor reading EALs should be determined using a dose assessment method that back calculates from the dose values specified in the IC. Since doses are generally not monitored in real-time, it is suggested that a release duration of one hour be assumed, and that the EALs be based on a site specific boundary (or beyond) dose of >100 mremr whole body. Iodine Release Rates for this EAL are excluded since the Plant Vent Radiation Monitoring System does not include an Iodine detector. The meteorology and source term used are the same as used for determining AU1 and AAl monitor reading EALs. Release Rate = Total Noble Gas Release Rate from Salem (Unit I & Unit 2) which would result in a EDE Dose Rate of > 1O0mRem/hr at the site boundary or beyond. Derivation / Calculation: Radiological Limit Calculation for Noble Gas: Release Rate (uCi/Sec)= (10%ofPAG)mn Re m(accumulatedi7lh1our) (ODCMX /Q) * (ODCMDRCF) 10% of PAG = 100 mRem dose accumulated 3 in 1 hour Salem ODCM X/Q = 2.20E-06 sec/m Salem ODCM DRCF = 5.3 6E-02 mRem/hr/uCi/m 3 (4.70E+02 mRem/yr/uCi/mn3 / 8766 hrs/yr) Site Allocation Factor = not used for SAE and GE EALs ' Release Rate (uCi/Sec) = 100777 Re 7n (doseaccum.ulatedilhr) (2.20E - 06sec/m 3) * (5.36E - 021n Re m/ hr ,/uCi /m 3 ) SAE EAL Value: (EAL# RSI/i) Total (SI & S2) Noble Gas Release Rate > 8.48E+08 uCi/See Salem Page 8 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Techmical Bases EP-SC-1 11-235 Salem Radiological EAL Setpoint Calculation Document NEI 99o019 Rev. 05 EALs Calculation for: SITE AREA EMERGENCY - EAL AS1.2 - (Dose Assessment) Objective of Calculation: Using actual meteorology, provide a dose assessment SSCL threshold TEDE 4-Day Dose value that is equivalent to a TEDE dose of >100 mRem and a Thyroid-CDE Dose of 500 mRero. Discussion: This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed 10% of the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and involve fuel damage. Derivation / Calculation: The dose assessment output on the SSCL is reported at varying distances from the plant as a TEDE 4-Day dose. This TEDE 4-day dose assumes a 4 lhr release duration. To obtain the approximate dose for a projected release condition of 1 hour, the TEDE 4-day dose value would need to be divided by 4. A TEDE 4-Day Dose > 4.OE+02 mRem correspond directly to an EDE dose rate value of 100 mRelhnfr and exceeds 10% of the EPA Protective Actions Guides (PAGs). The Thyroid-CDE Dose > 2.OE+03 mReln correspond directly to an CDE dose rate value of 500 mRemAlhr and exceeds 10% of the EPA Protective Actions Guides (PAGs) which was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.. Dose Assessment using actual meteorological data provides ai accurate indication of release magnitude. The use of dose assessment based EALs is therefore preferred over the use of Release Rate based EALs which utilize calculations which have built-in inaccuracies because ODCM default Meteorological data is used. SAE EALs Values: (EAL# RS1.2) Dose Assessment TEDE 4-Day Dose > 4.OE+02 mRem Dose Assessment CDE Dose > 2,0 E+03 mRem - based on Dose Assessment using Plant Vent effluent isotopic sample analysis as input to MIDAS and NOT based on a default Noble Gas to Iodine Ratio Salem Page 9 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC- 111-235 Salem Radiological EAL Setpoint Calculiation Document NEEI 99-01, Rev. 05 EALs Calculation for: SITE AREA EMERGENCY - EAL AS1.4 - (PA boundary dose rate) Obiective of Calculation: Provide a PROTECTED AREA Boundary dose rate that equates to an offsite dose of > 100 mRern EDE. Discussion: This IC addresses radioactivity releases that result in field survey results (closed window) dose rates greater than 100 mR/hr expected to continue for 60 minutes or longer at or beyond the site boundary. This value exceeds 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. Derivation Calculation: A Field Measured Dose Rate of > L.OE+02 mRem/hr corresponds directly to a dose values that exceed 10% of the EPA Protective Actions Guides (PAGs). SAE EAL Val>ue: (EAL# RS3)/ Dose Rate > 100 mRem/hr Salem Page 10 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Techmical Bases EP-SC-I 11-2315 Salem Radiological EAL Setpoint Calculation Document NEE 99-01, Rev. 05 EALs Calculation for: SITE AREA EMERGENCY - EAL AS1.4 - (1-131 Field Survey Sample Analysis) Objective of Calculation: Provide a Field Survey Sample Analysis value that equates to an offsite release that would result in a dose of > 500 mRem Thyroid CDE at or beyond the PROTECTED AREA Boundary. Discussion: This EAL addresses a radioactivity release field survey 1-13 1 sample concentration or count rate that would result in a Thyroid CDE dose of greater than 500 mRem for one hour of inhalation at or beyond the site boundary. This value exceeds 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. The Iodine-131 field survey sample concentration and count rate threshold is based on I-13 1 dose conversion factors (DCFs) from EPA-400. The thresholds are based on a Thyroid-CDE Dose Rate of > 500 mRem/hr for 1-13 1. Field Survey I-13 1 Sample Analysis results are provided as a sample concentration in units of uCi/cc for field samples counted in a Multi-Channel-Analyzer (MCA). Derivation / Calculation: The release sample concentration calculations are as follows. The sample concentration is calculated using the I-13 1 Dose Conversion Factor from EPA-400: Solving the following equation for aCi/cc: mRemlhr = (ýtCi/cc)(Dose Conversion Factor) Then; I-]31 Sample Concentration (1Ci/cc) ( 5 hrlcc ) = 3.85E-07e 1.30E + 097V Rem7 / uCi / cc / hr Where I.30E+09 mRemni/Ci/cc/hr is the Dose Conversion Factor from EPA-400, Table 5-4, Thyroid Dose, and includes the EPA breathing rate. SAE EAL Values: (EAL# RSI. 3) 1-131 Concentration > 3.85E-07 jLCilcc Salem Page 11 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-l 11-235 Salem Radio]iogicaRl EAL Setpotnt Calculiation Document NEI 99-01 9 Rev. 05 EALs Calculation for: GENERAL EMERGENCY - EAL AGI.1 - (Default Release Rate EAL) Objective of Calculation: Provide a Radiological Release Rate value that equates to a Release resulting in an offsite dose of > 1000 nrem EDE at or beyond the site boundary. Discussion: This IC addresses radioactivity releases that.result in doses at or beyond the site boundary that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and likely involve fuel damage. The monitor reading EALs should be determined using a dose assessment method that back calculates from the dose values specified in.the IC. Since doses are generally not monitored in real-time, it is suggested that a release duration of one hour be assumed, and that the EALs be based on a site specific boundary (or beyond) dose of> 1000 nrem whole body. Iodine Release Rates for this EAL are excluded since the Plant Vent Radiation Moniitoring System does not include an Iodine detector. The meteorology and source term used are the same as used for determining AU1 and AAI monitor reading EALs. Release Rate = Total Noble Gas Release Rate from Salem (Unit 1 & Unit 2) which would result in a TEDE Dose Rate of > 1000 mReminhr at the site boundary or beyond. Derivation / Calculation: Radiological Effluent Tecluical Specifications/ODCM Limit Calculation for Noble Gas: Release Rate (uCi/Sec) = 100%PA4 G(i Re m)Accumulatedinlhr (ODCAMX / 0) * (ODCMDRCF) 100% of PAG = 1000 nmRem accumulated 3 in 1 hour Salem ODCM X/Q = 2.20E-06 sec/mi Salem ODCM DRCF = 5.3 6E-02 mRem/lr/uCiim3 (4.70E+02 mnRen/rT/uCi/m 3 / 8766 hrs/yr) Site Allocation Factor not used for SAE and GE EALs 10007u71 Re 7n (doseaccuftiuiatedin~lh7-) Release Rate (uCi/Sec) = 1000m __Re doseaccumulatedinlhr) 3 (2.20E - 06sec/i 3 ) * (5.36E - 0277 Re n / hr /10Ci / n7) GE EAL Value: (EAL# RGL1) Total (SI & S2) Noble Gas Release Rate > 8.48E+09 uCi/Sec Salem Page 12 of 15 Rev: 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC- 111-2.3 5 Salem Radiological EAL Setpoint Calculation Document NEII 99-01, Rev. 05 EALs Calculation for: GENERAL EMERGENCY - EAL AG1.2 - (Dose Assessment) Objective of Calculation: Using actual meteorology, provide a dose assessment SSCL threshold TEDE 4-Day Dose value that is equivalent to a TEDE dose of > 1000 mRem and a Thyroid-CDE Dose of > 5000 mRem. Discussion: This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and involve fuel damage. Derivation / Calculation: The dose assessment output on the SSCL is reported at varying distances firom the plant as a TEDE 4-Day dose. This TEDE 4-day dose assumes a 4 hr release duration. To obtain the approximate dose for a projected release condition of 1 hour, the TEDE 4-day dose value would need to be divided by 4. A TEDE 4-Day Dose > 4.OE+03 mRem correspond directly to an EDE dose rate value of >1000 mRem/hr and exceeds the EPA Protective Actions Guides ( PAGs). The Thyroid-CDE Dose > 2.0E+04 mRem correspond directly to an CDE dose rate value of > 5000 mReln//hr and exceeds the EPA Protective Actions Guides (PAGs) which was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.. Dose Assessment using actual meteorological data provides an accurate indication of release magnitude. The use of dose assessment based EALs is therefore preferred over the use of Release Rate based EALs which utilize calculations which have built-in inaccuracies because ODCM default Meteorological data is used. GE EAL Values: (EAL# RG1.2) Dose Assessment TEDE 4-Day Dose > 4.0 E+03 mRem Dose Assessment CDE Dose > 2°0 E+04 mRem - based on Dose Assessment using Plant Vent effluent isotopic sample analysis as input to MIDAS and NOT based on a default Noble Gas to Iodine Ratio Salem Page 13 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Techmical Bases EP-SC-1 11-235 Saleem Radiokogicall EAL Setpoint Cal1ciulIation Document NEi 99-012 Rev. 05 EALs Calculation for: GENERAL EMERGENCY - EAL AG1.4 - (PA boundary dose rate) Objective of Calculation: Provide a PROTECTED AREA Boundary dose rate that equates to an offsite dose of> 1000 rnRem EDE. Discussion: This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed the EPA Protective Action Guides (PAGs). Public protective actionis will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and involves fuel damage. Derivation / Calculation: A Field Measured Dose Rate of> 1.OE+03 mriRem/hr corresponds directly to a dose values that exceed the EPA Protective Actions Guides (PAGs). GE EAL Vallue: (EAL# RG1.3) Dose Rate> 1000 mRem/hir. Salem Page 14 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-2315 Salem Radiologivl EAL Setpoint Calculation Document NEI 99-019 Rev. 05 EALs Calculation for: GENERAL EMERGENCY - EAL AG1.4 - (1-131 Field Survey Sample Analysis) Objective of Calculation: Provide a Field Survey Sample Analysis value that equates to an offsite release that would result in a dose of > 5000 mRern Thyroid CDE at or beyond the PROTECTED AREA Boundary. Discussion: This EAL addresses a radioactivity release field survey I-131 sample concentration or count rate that would result in a Thyroid CDE dose of greater than 5000 mRem for one hour of inhalation at or beyond the site boundary. This value exceeds the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. The Iodine-131 field survey sample concentration and count rate threshold is based on 1-13 1 dose conversion factors (DCFs) from EPA-400. The thresholds are based on a Thyroid-CDE Dose Rate of > 5000 mRem/hr for 1-131. Field Survey I-131 Sample Analysis results are provided as sample concentration in units of uCi/cc for field samples counted in a Multi-Channel-Analyzer (MCA). Derivation / Calculation: The release sample concentration calculations are as follows. The sample concentration is calculated using the 1-131 Dose Conversion Factor fiom EPA-400: Solving the following equation for j.Ci/cc: mRern/hr = (ptCi/cc)(Dose Conversion Factor) Then; 1-131 Sample Concentration (jCi/cc) =0( ReC/ce ) = 3.85E-06 1 .30E + 0977 Re7m / pCi / cc / h r Where 1.30E-+09 mRein/pCi/cc/lhr is the Dose Conversion Factor from EPA-400, Table 5-4, Thyroid Dose, and includes the EPA breathing rate. GE EAL Values: (EAL# RGI,3) 1-131 Concentration > 3.85E-06 ýiCi/cc Salem Page 15 of 15 Rev. 0 (Draft E)

4 y ATTACHMENT 6 Salem Generating Stations EAL Technical Bases Document (Clean Version)

SGS ECG - EAL Technical Bases EP-S C-1 11-200 0 Ps , EmerFgency Aclion Level TschiCcal Bases Draft E 7/30/2010

SGS ECG - EAL Technical Bases EP-SC-1 11-200 SALEM EVENT CLASSIFICATION GUIDE (EGG) EMERGENCY ACTION LEVEL (EAL) TECHNICAL BASES TABLE OF CONTENTS ECG - EAL Bases Front-Matter Materials: EP-SC-1 11-200 SGS ECG - EAL Technical Bases Table of Contents EP-SC-1 11-201 Emergency Action Level (EAL) Technical Basis Introduction EP-SC-111-202 ECG Usage ECG EAL Sections - Bases Information: EP-SC-1 11-203 EAL Bases for Category R1 - Offsite Rad Conditions EP-SC-1 11-204 EAL Bases for Category R2 - Onsite Rad Conditions I Fuel Pool Events EP-SC-1 11-205 EAL Bases for Category R3 - CR/CAS Rad. EP-SC-1 11-206 EAL Bases for Category E - ISFSI EP-SC-1 11-207 EAL Bases for Category H1 - Hazards - Natural & Destructive Phenomena (Quake, High Winds / Tornado, Turbine Rotating Component Failure, Internal Flooding, River Level, Vehicle Crash / Projectile Impact) EP-SC-1 11-208 EAL Bases for Category H2 - Hazards - Fire or Explosion EP-SC-1 11-209 EAL Bases for Category H3'- Hazards - Hazardous Gas EP-SC- 111-210 EAL Bases for Category H4 - Hazards - Security EP-SC-1 11-211 EAL Bases for Category H5 - Hazards - Control Room Evacuation EP-SC-1 11-212 EAL Bases for Category H6 - Hazards - EC Judgment EP-SC-1 11-213 EAL Bases for Category S1 - System Malfunction - Loss of AC Power Salem Page 1 of 3 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-200 SALEM EVENT CLASSIFICATION GUIDE (ECG) EMERGENCY ACTION LEVEL (EAL) TECHNICAL BASES TABLE OF CONTENTS EP-SC-1 11-214 EAL Bases for Category S2 - System Malfunction - Loss of DC Power EP-SC-1 11-215 EAL Bases for Category S3 - System Malfunction - ATWT/Criticality EP-SC-1 11-216 EAL Bases for Category S4 - System Malfunction - Inability to Reach or Maintain Shutdown Conditions EP-SC-1 11-217 EAL Bases for Category S5 - System Malfunction - Loss of Annunciators I Instrumentation EP-SC-1 11-218 EAL Bases for Category S6 - System Malfunction - Communication EP-SC-1 11-219 EAL Bases for Category S7 - System Malfunction - Fuel Clad Degradation EP-SC-1 11-220 EAL Bases for Category S8 - System Malfunction - RCS Leakage EP-SC-1 11-221 EAL Bases for Category F1 - Fission Product Barriers - Fuel EP-SC-111-222 EAL Bases for Category F2 - Fission Product Barriers - RCS EP-SC-1 11-223 EAL Bases for Category F3 - Fission Product Barriers - Containment EP-SC-1 11-224 EAL Bases for Category C1 - Cold Shutdown / Refuel System Malfunction 

                - Loss of AC Power EP-SC-1 11-225   EAL Bases for Category C2 - Cold Shutdown / Refuel System Malfunction
                - Loss of DC Power EP-SC-1 11-226   EAL Bases for Category C3 - Cold Shutdown / Refuel System Malfunction
                - RPV Level EP-SC-1 11-227   EAL Bases for Category C4 - Cold Shutdown / Refuel System Malfunction
                - RCS Temperature Salem                              Page 2 of 3                     Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-200 SALEM EVENT CLASSIFICATION GUIDE (ECG) EMERGENCY ACTION LEVEL (EAL) TECHNICAL BASES TABLE OF CONTENTS EP-S C-111-228 EAL Bases for Category C5 - Cold Shutdown / Refuel System Malfunction 

                  - Communication EP-S C-i 11-229    EAL Bases for Category C6 - Cold Shutdown / Refuel System Malfunction
                  - Inadvertent Criticality ECG - EAL Technicai Bases Supporting Documents:

EP-SC-1 11-230 - Use of Fission Product Barrier Table (Tab - Attachment 1) EP-SC-1 11-231 - EAL Bases Figures / Drawings (Tab - Attachment 2) EP-SC-1 11-232 - EAL Definitions (Tab - Attachment 3) EP-SC-1 11-233 - Glossary of Abbreviations & Acronyms (Tab - Attachment 4) EP-SC-1 11-234 - SGS-to-NEI 99-01 EAL Cross-reference (Tab - Attachment 5) EP-SC-1 11-235 - Salem EAL Rad Set-Point Calculation Document (Tab - Attachment 6) Salem Page 3 of 3 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-I 11-201 UPPnEG WSýG Nutclear LLC Salem Generating Station Event Ciassification Guide (ECG) Emergency Action Level TechnicaG Bases Draft E 7/30/10

SGS ECG - EAL Technical Bases EP-SC-1 11-201 TABLE OF CONTENTS Section Paqe 1 . P u rp o se ................................................................................................. .....2

2. Emergency Classification Descriptions .......................................................... 2
3. Fission Product Barriers ............................................................................... 3
4. EAL Relationship to EOPs ............................................................................. 5
5. Sym ptom-Based vs. Event-Based Approach ................................................. 5
6. EAL Organization .......................................................................................... 6
7. Operating Mode Applicability ......................................................................... 8
8. EAL Technical Bases Organization .................................... 9 9 . R e fe re n ce s ............................................................ .................................. . . 1 1 Salem Page I of 11 Rev. 0 (draft E)

Introductioo

SGS ECG - EAL Technical Bases EP-SC-1 11-201

1. PURPOSE This document provides an explanation and rationale for each Salem Generating Station (SGS) Emergency Action Level (EAL). It should be used to facilitate review of the SGS EALs, provide historical documentation for future reference and serve as a training aid. Decision-makers responsible for implementation of the Event Classification Guide (ECG) may use this document as a technical reference in support of EAL interpretation. This information may assist the Emergency Coordinator in making classifications, particularly those involving judgment or multiple events. The information may also be useful in training, for explaining event classifications to offsite officials, and facilitate regulatory review and approval of the classification scheme.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification. This document is controlled pursuant to 10 CFR 50.54(q).

2. Emergency Classification Descriptions The NRC and Federal Emergency Management Agency (FEMA) established four emergency classes for fixed nuclear facilities.

An emergency class is used for grouping off-normal nuclear power plant conditions according to their relative radiological seriousness and the time sensitive onsite and offsite actions needed to respond to such conditions. The four emergency classes are (in order of less severe to most severe): o Unusual Event (UE) o Alert (A) o Site Area Emergency (SAE) o General Emergency (GE) 2.1 Unusual Event Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicates a security threat to facility protection has been initiated. o The lowest level of emergency at the plant, which can usually be handled by the normal operating shift. Salem Page 2 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-2Q1 0 No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs. Dose consequences in Unrestricted Areas would not reach 20 mRem TEDE. 2.2 Alert Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. o Emergency Response personnel are required in addition to the normal operating shift. The entire emergency response organization is called in. The TSC is activated, and the EOF'and ENC are manned and may activate if needed for support. o Any release of radioactive material is expected to be limited to a small fraction of the EPA Protective Action Guideline exposure levels. Dose consequences in Unrestricted Areas would not reach 100 mRem TEDE. 2.3 Site Area Emergency Events are in progress or have occurred which involve an actual or likely failure of plant functions neededfor protection of the public or HOSTILE ACTION that result in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. o The entire emergency response organization is activated. o Any release of radioactive rmaterial is not expected to exceed EPA Protective Action Guideline exposure levels beyond the plant boundary. Dose consequences in Unrestricted Areas not to exceed 1000 mRem TEDE. 2.4 General Emergency Events are in process or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE. ACTIONS that result in an actual loss of physical control of the facility. o The entire emergency response organization is activated. o Release of radioactive material Can be expected to exceed EPA Protective Action Guideline exposure levels of 1000 mRem TEDE in Unrestricted Areas.

3. Fission Product Barriers-'

Many of the EALs derived from the NEI 99-01 methodology are fission product barrier based. That is, the conditions that define the EALs pertain to the loss .or potential loss of one or more Salem. Page 3 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201 of the three fission product barriers. "Loss" and "Potential Loss" signify the relative damage and threat of damage to the barrier. "Loss" means the barrier no longer assures containment of radioactive materials; "Potential Loss" infers an increased probability of barrier loss and decreased certainty of maintaining the barrier. 3.1 Barrier Descriptions The EAL fission product barriers are: Fuel Clad Barrier (FB): The Fuel Clad barrier consists of the zircalloy or stainless steel fuel bundle tubes that contain the fuel pellets. Reactor Coolant System Barrier (RB): The Reactor Coolant System barrier includes the Reactor Coolant System primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves. Containment (CB): The Containment barrier includes the containment building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve. 3.2 Emergency Classification Based on Fission Product Barrier Degradation The following criteria for event classification relate to fission product barrier loss or potential loss: UNUSUAL EVENT ANY loss or ANY potential loss of Containment ALERT ANY loss or ANY potential loss of either Fuel Clad or RCS SITE AREA EMERGENCY Loss or potential loss of ANY two barriersOR Potentialloss of 2 barrierswith the loss of the 3 rd barrier GENERAL EMERGENCY Loss of ANY two barriersand loss or potential loss of third barrier Salem Page 4 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201 Discrete threshold values associated with fission product barrier loss and potential loss are given in Attachment 1, Use of Fission Product Barrier Table. The bases for the thresholds are discussed in the following ECG sections: o EP-SC-1 11-221 EAL Bases for Fuel Clad Barrier o EP-SC-1 11-222 EAL Bases for RCS Barrier o EP-SC-1 11-223 EAL Bases for Containment Barrier A point system (described in Attachment 1) is used to determine fission product barrier emergency classification levels as well as Protective Action Recommendations (PARs) if a General Emergency is declared.

4. EAL Relationship to EOPs Where possible, the EALs have been made consistent with and utilize the conditions defined in the SGS Emergency Operating Procedures (EOPs). While the symptoms that-drive.operator actions ýpecified in the EOPs are not indicative of all possible conditions which warrant emergency claisification, they define the symptoms, independent- of initiating events, for which reactor plant safety and/or fission product barrier integrity are threatened. When these "

symptoms are clearly representative of one. of the NEI InitiatingConditions, they have been utilized as an EAL. This permits rapid classification of emergency situations based on plant conditions without the need for additional evaluation or event diagnosis. Although some of the EALs 'pres6ntedhere are based on conditions defihed in the EOPs, clasSification of emergencies using these EALs is not dependent upon EOP entry or execution. The EALs can be utilized independently or in conjunction with the EOPs.

5. Symptom-Based vs. Event-Based Approach To the extent possible, the EALs are symptom-based; that is, the action level threshold is defined by values of key plant operating parameters that identify emergency or potential emergency conditions. This approach is.appropriate because it allows the full scope of, variations in the types of events to be classified as emergencies. However, a purely symptom-based approach is not sufficient to address all events for which emergency classification is appropriate. Particular events to which no predetermined symptoms can be ascribed have also been utilized as EALs since they may be indicative of potentially.more serious conditions not yet fully realized.

Salem Page 5 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201

6. EAL Organization 6.1 EAL Groups The EAL scheme is divided into three broad groups:

o EALs applicable under all plant operating modes - This group would be reviewed by the EAL-user any time emergency classification is considered. o EALs applicable only under hot operating modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup or Power Operations operating modes. o EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown or Refueling operating modes or when the Reactor Vessel is defueled. The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency. 6.2 EAL Categories and Subcategories Within each EAL group, EALs are assigned to categories/subcategories. Category titles generally align with the EAL Recognition Categories of NEI 99-01. Subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. Subcategories are used as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. Salem Page 6 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201 The SGS EAL categories/subcategories and their relationship to NEI Recognition Categories are listed below. SGS EALs Category Subcategory Group: Any Operating Mode: R - Abnormal Rad Release / Rad Effluent 1 - Offsite Rad Conditions 2 - Onsite Rad Conditions/Fuel Pool Events 3 - CR/CAS Rad E - ISFSI Spent Fuel Transit H - Hazards & Other Conditions Affecting 1- Natural & Destructive Phenomena Plant Safety 2- Fire or Explosion 3- Hazardous Gas 4- Security 5- Control Room Evacuation 6 - EC Judgment Group: Hot Conditions: S - System Malfunction 1- Loss of AC Power 2- Loss of DC Power 3- ATWT / Criticality 4- Inability to Reach or Maintain Shutdown Conditions 5- Instrumentation 6- Communications 7- Fuel Clad Degradation 8 - RCS Leakage F - Fission Product.Barrier Degradation None Group: Cold Conditions: C - Cold Shutdown / Refuel System 1- Loss of AC Power Malfunction 2 - Loss of DC Power 3- RCS Level 4 - RCS Temperature 5- Communications 6- Inadvertent Criticality Salem Page 7 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201

7. Operating Mode Applicability With the exception of ISFSI (which is not assigned an operating mode), NEI 99-01 assigns one or more operating modes to each EAL. The ISFSI EAL will be applicable in all operating modes at Salem Generating Station; as such, operating mode applicability is N/A for the ISFSI EAL.

7.1 Operating Mode Definitions THERMAL MODE Keff POWER* TAVG

1. Power Operation > 0.99 > 5% > 350'F
2. Startup > 0.99 < 5% > 350'F
3. Hot Standby < 0.99 0 > 350'F
4. Hot Shutdown < 0.99 0 > 200'F & < 350'F
5. Cold Shutdown < 0.99 0 < 200'F
6. Refueling ** < 0.95 0 < 140'F Defueled NA NA NA - no fuel in Reactor Vessel
  • Excluding Decay Heat
             **   Fuel in the Reactor Vessel with the head closure bolts less than fully tensioned or with the head removed 7.3    Applicability The plant operating mode that exists at the time that the event occurs (prior to any protective system or operator action is initiated in response to the condition) should be compared to the operating mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the operating mode that existed at the time the event occurred.

For events that occur in Cold Shutdown or Refueling, escalation is via EALs that have Cold Shutdown or Refueling for mode applicability, even if Hot Shutdown (or a higher mode) is entered during any subsequent heat-up. In particular, the fission product barrier EALs are applicable only to events that initiate in Hot Shutdown or higher. Salem Page 8 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201

8. EAL Technical Bases Organization EAL technical bases are provided for each EAL according to:

o EAL category (R, E, H, S, F and C) o EAL subcategory Figures cited in EAL basis discussions are provided in Attachment 2. EAL defined terms and abbreviations and acronyms are listed in Attachments 3 and 4, respectively. For each EAL, the following information is provided: o EAL Category Letter & Title o EAL Subcategory Number & Title o Initiating Condition Site-specific description of the generic IC given in NEI 99-01. o Operating Mode Applicability One or more of the following Operating modes comprise the conditions to which each EAL is applicable:,1-. Power Operations, 2 - Startup, 3 - Hot Standby, 4.- Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling, D - Defueled, N/A - Not Applicable or All. For Fission Product Barrier Table bases, Operating Mode Applicability. is always Operating Modes 1, 2, 3 and 4. For these EALs, the barrier threat (Loss or Potential Loss) is listed. o EAL# and Classification Level (EAL# & Point Value for Fission Product Barrier Table EAL bases): The EAL number is a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel.. Four characters define.each EAL identifier: Category R, E, H, C and S EALs: (Example: SU7.1)

1. First character (letter) - Corresponds to the EAL category (R, E, H, C or S)
2. Second character (letter) - Emergency classification level: U for Unusual Event, A for Alert, S for Site Area Emergency, or G for General Emergency.
3. Third character (number): Subcategory number within the given category.

Subcategories are sequentially numbered beginning with the number one (1). Salem Page 9 of 11 Rev. 0 (draft E) SMtroductior

SGS ECG - EAL Technical Bases EP-SC-1 11-201 If a category does not have a subcategory, this character is assigned the number one (1).

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

Selected EALs in Category H have been designated as "Common Site" events. These events are annotated with the phrase "(Common Site)" immediately following the classification level. Category F Fission Product Barrier EALs: (Example CB4-P)

1. First and second characters (letters) identify the barrier to which the EAL applies.

FB: Fuel Clad Barrier RB: Reactor Coolant Barrier CB: Containment Barrier

2. Third character (number) - Sequential number beginning with the number one (1) for the first threshold in the barrier loss or potential loss of the Fission Product Barrier Table (Attachment 1)
3. Last character (letter) preceded by a dash (-) designates if EAL is for a potential loss or loss of the barrier in question.

P: Potential Loss L: Loss o EAL (enclosed in rectangle) Exact wording of the EAL as it appears in the EAL wallcharts. o Basis The basis discussion applicable to the EAL taken from NEI 99-01. Salem Page 10 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-201 

   " Explanation/Discussion/Definitions Description of the site-specific rationale for the EAL.

o EAL Basis Reference(s) Source documentation from which the EAL is derived. The first reference in each list gives the NEI 99-01 IC and example EAL number. A cross-reference of SGS EALs and NEI 99 ICs/EALs is given in Attachment 5.

9. REFERENCES 9.1 NEI 99-01 Revision 5, Methodology for Development of Emergency Action Levels, Final, February 2008 (ADAMS Accession Number of ML080450149) 9.2 NRC Regulatory Issue Summary (RIS) 2003-18, Supplement 2, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels Revision 4, Dated January 2003 (December 12, 2005) (ADAMS Accession Number of ML051450482) 9.3 NRC Regulatory Issue Summary (RIS) 2007-02 Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, Dated February 2007 (ADAMS Accession Number of ML062370311) 9.4 Salem EAL Comparison Matrix - NRC submittal document that defines differences between NEI 99-01, Rev. 05 and PSEG submitted Salem EALs Salem Page 11 of 11 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-202 

                         . EVENT CLASSIFICATION GUIDE (ECG) USE NOTE It is expected the Shift Manager (SM) always serves at the Emergency Coordinator (EC) during the initiating event even if the SM is out of the control room. The Control Room Supervisor (CRS) assumes operational command and control responsibility for the shift crew but not as the EC. The CRS should ensure that the SM is immediately called back to the control room on any conditions that require ECG assessment. Only if the SM is not able (sick or hurt) may the CRS serve as the EC.
1. EC Judgment The EALs described in the ECG are not all inclusive and will not identify each and every condition, parameter or event which could lead to an event classification. The following guidance should be used by the EC:

IF an EAL has been exceeded, but satisfaction of the Initiating Condition (IC) is in question, THEN CLASSIFY the event lAW the EAL. IF however, it is clear that the EAL has NOT been exceeded (and will not), THEN DO NOT classify the event. IF an IC has been satisfied, but exceeding the specific EAL is in question, THEN CLASSIFY the event lAW the IC. In any case, IF the plant conditions are equivalent to one of the four emergency classes as described in Section 2 of EP-SC-1 11-201, THEN CLASSIFY the event based on EC discretion lAW EALs in Category H.

2. Assessment Time 2.1 Timeliness Assessment of an Emergency Condition should be completed in a timely manner, which is considered to be within 15 minutes of when events are known or should have been known.

If an EAL specifies a duration time (e.g., loss of annunciators for 15 minutes or longer), the assessment time runs concurrently with the EAL duration time and is the same length. Salem Page 1 of 8 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-202 2.2 Duration Time Exceeded If an event is recognized or reported and the required duration time is known to have already been exceeded, the duration portion of the EAL should be considered as being satisfied and the assessment time for the remaining portions of the EAL should be within 15 minutes from the time of recognition.

3. Implementing Actions The ECG is not a stand-alone document. At times, the ECG will refer the user to other attachments or procedures for accomplishment of specific evolutions such as: Accountability, Recovery, development of PARs, etc.

The ECG should be considered an "Implementing Procedure" and used in accordance with the requirements of a Level 2 - Reference Use procedure as defined in HU-AA-1 04-101, Procedure Use and Adherence. The ECG classification sections allow for judgment and decision making as to whether or not an EAL is exceeded. NOTE Comparison of redundant instrumentation, indications, and/or alarms should be used to confirm actual plant conditions.

4. Classification The primary tools for determining the emergency classification level are the EAL wallcharts.

The user of the EAL wallcharts may (but is not required to) consult the EAL Technical Bases in order to obtain additional information concerning the EALs under classification consideration. To use the EAL wallcharts, follow this sequence:

1. Assess the event and/or plant conditions and determine which EAL Group is most appropriate.
2. Review EAL categories and subcategories on the appropriate wallcharts.
3. For each applicable subcategory, review EALs in the subcategory beginning with the highest emergency classification level to. the lowest classification level (left to right).
4. If the HOT conditions wallchart is employed, also review the Fission Product Barrier (FPB) Table (Wallchart sheet 3) as follows:
a. Examine the FPB categories in the left column of the table.
b. Select the category that most likely coincides with event conditions.
c. Review all thresholds in this category for each fission product barrier.
d. For each threshold that is exceeded, identify its point value and determine the classification level in accordance with the instructions on the Fission Product Barrier Table (or in EAL Technical Basis, Attachment 1).

Salem Page 2 of 8 Rev. 0 (draft E) Usage

SGS ECG - EAL Technical Bases EP-SC-1 11 -202 NOTE The Emergency Coordinator should classify and declare an emergency before an Emergency Action Level (EAL) is exceeded if, in the EC's judgment, it is determined that the EAL will be exceeded within 2 hours

5. REVIEW the associated EALs as compared to the event and SELECT the highest appropriate emergency. If identification of an EAL is questionable refer to paragraph 1 above.

If there is any doubt with regard to assessment of a particular EAL, the ECG EAL Technical Basis Document should be reviewed. Words contained in an EAL that appear in uppercase and bold print (e.g., VALID) are defined at the end of the basis for the EAL. Words or numbers contained in an EAL that are in bold print but not uppercase are EAL threshold values (e.g., > 15 minutes).

6. If an EAL has been exceeded, equal level EALs or lower level EALs are not required to be seperately reported as long as the applicable information is communicated to the NRC using ECG Attachment 5, EP-SC-111-F5, NRC Data Sheet Completion Reference.
7. When the Shift Manager (SM) is the Emergency Coordinator, the Shift Technical Advisor (STA) is responsible to perform an independent verification of the EAL classification. The STA verification does not alleviate the requirement of the SM to make a timely classification. Should the SM fill the STA role, independent verification of the EAL classification will be delegated to another on-shift SRO, the Independent Assessor.
8. Identify and implement the referenced ECG form based on the Emergency Classification Level.

o Unusual Event Implement EC-SC-111-F1 o Alert Implement EC-SC-1 11-F2 o Site Area Emergency Implement EC-SC-1 1 1-F3 o General Emergency Implement EC-SC-1 1 1-F4 o Unusual Event (Common Site) Implement EC-SC-1 11-F8

9. Continue assessment after classification and attachment initiation, by returning to the EAL wallcharts to review EALs that may result in escalation/de-escalation of the emergency level.

Salem Page 3 of 8 Rev. 0 (draft E) Usagie

SGS ECG - EAL Technical Bases EP-SC-1 11-202

5. Emergency Short Duration Events
1. A Short Duration emergency event is a transitory event that meets or exceeds one or more EALs for less than 15 minutes (i.e., action is taken and the plant returned to a condition in which no EAL applies). For a Short Duration event the Control Room Staff is aware of the event and realizes that an EAL had been exceeded. -
2. Short Duration events thatoccur will be assessed and emergency classification made, if appropriate, within 15 minutes of control room indications or the receipt of the information, indicating that an EAL has or had been exceeded. This classification is to be made even if no EALs are currently being exceeded (i.e., actions have been taken to stabilize the Plant such that no EALs currently apply).
3. For some events, the condition may be corrected before a declaration has been made.

The key consideration in this situation is to determine whether or not further, plant damage occurred while the corrective actions were being taken. In some situations, this can be readily determined,, in other situations, further analyses (e.g., coolant radiochemistry sampling,. may be necessary). Classify the event as indicated and terminate the emergency. once assessment shows that there were no consequences from the event and other terminationcriteria are met.

4. Guidance.for classifying, transient events. addresses the period of time of event recognition and classification (15 minutes)'. However, in cases when EAL declaration criteria may.be met momentarily during the normal expected response of the plant, declaration requirements should. not be considered to be met when the conditions are a part of the designed plant respo~nse, or result from appropriate Operator actions.
6. Conditions Discovered After-the-Fact There may be cases in which a plant condition that exceeded an EAL was not. recognized at the time of occurrence but is identified well after the condition has occurred (e.g., as a result of routine log or record review), and the condition. no longer exists. In these cases, an emergency should not be declared. Reportihg requirements of 10 CFR 50.72 are applicable and the guidance of NUREG-1022, Rev...2, Section 3, should be applied.
1. An After-the-Fact event is defined as an event that exceeded an EAL threshold and was not recognized at the time of occurrence but is identified greater than 1 hour after the condition has occurred (e.g., as a result of a routine log review, record review, post trip review, engineering evaluation) and the condition no longer exists.
2. For an After-the-Fact event the Control Room Staff was either not aware of the event or did not realize that an EAL was exceeded at the time of the occurrence.
3. Plant emergency events that are in progress or have occurred with ongoing adverse consequences/effects should not be considered After-the-Fact events and should therefore be classified and declared as an ongoing emergency event.

Salem Page 4 of 8 Rev. 0 (draft E) 

                            ~Usage

SGS ECG - EAL Technical Bases EP-SC-1 11-202

4. EMERGENCY CONDITIONS - After-the-Fact events that occur will be assessed and evaluated to ensure that no EAL currently applies. An emergency declaration is NOT required and a non-emergency, One-Hour Report should be initiated in accordance with non-emergency RALs in the ECG.
7. NRC Communications During An Emergency Guidance
1. Complete and accurate communications with the NRC Operations Center during emergencies is required and expected. The purpose of notifying the NRC within one-hour of an emergency, is to provide event information when immediate NRC action may be required to protect the public health and safety OR when the NRC needs accurate and timely information to respond to heightened public concern. If the information we provide is not accurate or does not contain sufficient detail, then we hamper the NRC from doing their job.
2. The NRC Data Sheet, along with the Initial Contact Message Form, is the primary vehicle to ensure the NRC is kept informed. General Guidance on completing the event description portion of the NRC Data Sheet is provided in the NRC Data Sheet (ECG Attachment 5).
8. Event Retraction Guidance IF an ENS notification to the NRC was made as directed by the applicable ECG Attachment AND it is later determined that the event or condition is not reportable, THEN the notification may be retracted as follows:
1. OBTAIN both the Operations Shift Manager's and Shift Manager's approval of any proposed retractions. Ensure Reg Assurance is consulted prior to approval to retract an Event.
2. COMPLETE "page 1" of ECG Attachment, EP-SC-111-F5, NRC Datasheet Completion Reference, providing a retraction of the original notification. Event Description Section of NRC Data Sheet should explain the rationale for the retraction.
3. NOTIFY the NRC Operations Center and NRC Resident Inspector.
4. RECORD on the "NRC Data Sheet" the name of the NRC contact that received the retraction information.
5. FORWARD the retraction "NRC Data Sheet" with the rest of the original attachment of the ECG that was implemented when the original notification was made to the Operations Shift Manager.

Salem Page 5 of 8 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-202

9. Common Site Events Guidance
1. Selected EALs in Category H (Unusual Event level only) have been designated as "Common Site" events. These events will be annotated with the words "Common Site" just below the mode applicability line in the wallcharts and next to the classification level in the EAL Bases document.

2, The Common Site UE ECG Attachment 8, EP-SC-1 11 -F8, Declaration of "Common Site" UE, will direct the SM to establish agreement on which SM will declare and report the event. Therefore, either Salem or Hope Creek will report Common Site Unusual Events, but not both. 31 Events classified at an Alert or higher level require plant specific information to be provided to the states of New Jersey and Delaware, the NRC, and to PSEG Emergency Response Facilities and therefore will not be classified as common site events.

10. EAL Classification Considerations
1. Planned evolutions involve preplanning to address the limitations imposed by the condition, the performance of required surveillance testing, and the implementation of specific controls prior to knowingly entering the condition in accordance with the specific requirements of the SGS Technical Specifications. Activities which cause the site to operate beyond that-allowed by the SGS Technical Specifications, planned or unplanned, may result in an EAL threshold being met or exceeded. Planned evolutions to test, manipulate, repair, perform maintenance or modifications to systems and equipment that result in an EAL value being met or exceeded are not subject to classification and activation requirements as long as the evolution proceeds as planned and is within the operational limitations imposed by the specific operating license. However, these conditions may be subject to the reporting requirements of 10 CFR 50.72.
2. All classifications are to be based upon VALID indications, reports or conditions.

Indications, reports or-conditions areconsidered VALID when they are verifi6d by (1) an instrument channel check, or (2) indications on related or redundant indications, or (3) by-direct obsernation by plant personnel, such that doubt related tothe indication's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment.

3. Although the majority of the EALs provide very specific thresholds, the Emergency Coordinator must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is IMMINENT. If, in the judgment of the Emergency Coordinator, an IMMINENT situation is at hland, the classification should be made as if the threshold has been exceeded. While this is particularly prudent at the higher emergency-classification levels (as the early classification may provide for mfore effective implementation of protective measures), it is nonetheless applicable to all emergency classification levels.

Salem- Page 6 of 8 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11 -202

4. When multiple simultaneous events occur, the emergency classification level is based on the highest EAL reached. For example, two Alerts remain in the Alert category. Or, an Alert and a Site Area Emergency is a Site Area Emergency. Further guidance is provided in RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events.
5. Another important aspect of usable EAL guidance is the consideration of what to do when the risk posed by an emergency is clearly decreasing. A combination approach involving recovery from General Emergencies and some Site Area Emergencies and termination from Unusual Events, Alerts, and certain Site Area Emergencies causing no long term plant damage appears to be the best choice. Downgrading to lower emergency classification levels adds notifications but may have merit under certain circumstances. Refer to procedure NC.EP-EP.ZZ-0405, Emergency Termination -

Reduction - Recovery, for detailed directions.

6. The logic used for the Fission Product Barrier EALs reflects the following considerations:
           "   The Fuel Clad Barrier and the RCS Barrier are weighted more heavily than the Primary Containment Barrier. Unusual Events associated with RCS and Fuel Clad Barriers are addressed under EALs in Category S, System Malfunctions.

o The ability to escalate to higher emergency classification levels as an event deteriorates must be maintained. For example, RCS leakage steadily increasing would represent an increasing risk to public health and safety. o The Primary Containment Barrier should not be declared lost or potentially lost based on exceeding Technical Specification action statement criteria, unless there is an event in progress requiring mitigation by the Primary Containment barrier. When no event is in progress (Loss or Potential Loss of either Fuel Clad and/or RCS barrier) the Primary Containment Barrier status is addressed by Technical Specifications.

7. Since Salem is a multi-unit station with shared safety-related system and functions, emergency classification level upgrading must also consider the effects of a loss of a common system on more than one unit (e.g., potential for radioactive release from more than one core). For example, the control panels for both units in close proximity within the same room. Thus, Control Room evacuation most likely would affect both units. There are a number of other systems and functions which may be shared. This must be considered in the emergency classification level declaration.
8. SGS and HCGS share a common ISFSI. Classification of events related to spent fuel stored at the ISFSI appear only in the HCGS EAL scheme. Classification of events related to the transfer of spent fuel from SGS to the ISFSI are addressed in the SGS EAL scheme (EAL EUI.).

Salem Page 7 of 8 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-202 This page intentionally blank Salem Page 8 of 8 Rev. 0 (draft E)

EALs for: Abnormal 0 0 Radiol.ogical Levels ISFSI

SGS ECG - EAL Technical Bases EP-SC-111-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 2 times the ODCM for 60 minutes or longer Mode Applicability: All EAL# & Classification Level: RUI.1 - UNUSUAL EVENT EAL: VALID gaseous monitor reading > Table R-1 column "UE" AND 

> 60 minutes have elapsed (Note 2)

Note 2: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: RUI. il

SGS ECG - EAL Technical Bases EP-SC-1 11-203 S: ." Table R-I Effluent Monitor Classification Thresholds*. Release Point Monitor GE SAE ALERT UE u) Plant Vent 1R41D + 2R41D o Effluent Noble OR 8.48E+09 pCi/sec 8.48E+08 pCi/sec 4.84E+07 pCi/sec 4.84E+05 pCi/sec GasSPDS combined C U unit 1 + Unit 2 release rate Containment Fan Coil 1(2)R13A/B ---- ---- 1.64E+05 cpm 1.64E+03 cpm Process Liquid 1RIS U1= 5.50E+05 cpm Radwaste. . . .... N/A Disposal See EAL RA1.3 

  . Process'              2R18                                                                             U2= 9.90E+05 cpm

.' Steam 1R19A-D U1= 6.40E+05 cpm U1= 6.40E+03 cpm Generator Blowdown Process 2R19A-D U2= 8.30E+05 cpm U2= 8.30E+03 cpm Non-Rad Liquid cm 36E0 cp 

                                                                                                                    *R736E0 Waste2R7....3.                                                                         E+5cm.6E0                     cp
  • For high radiation conditions on Letdown L'ine Monitor 1 R31A (2R31), refer to EAL SU7.1 Basis:

This EAL addresses a potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate features intended to controI the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls. The threshold value that equates to a multiple of two times the ODCM limits is specified in EAL RU1.1 only to distinguish between non-emergency conditions. While this multiple obviously corresponds to an off-site dose or dose rate, the emphasis in classifying this event is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate. This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in the EAL. This EAL is intended for sites that have established effluent monitoring on non-routine release pathways for which a discharge permit would not normally be prepared. Salem Page 2 of 4 Rev. 0 (draft E) E AL#: FIIU I, . ]

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Explanation/Discussion/Definitions: The column "UE" gaseous release value in Table R-1 (Unit 1 + Unit 2) represents two times the associated effluent monitor alarm setpoint. This setpoint is set to preclude exceeding the ODCM release rate limits associated with the specified monitor. The plant vent monitors (R41) sample and detect noble gases and collect samples of particulates and iodine discharge through the plant vent. Channel D (R41 D) provides the gaseous effluent release rate (pCi/sec) by combining (product of) the on-range R41A through R41 C with plant vent flow (cc/sec). Definitions: VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AG1 Example EAL #1
2. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)
3. FSAR Section 11.4 Radiological Monitoring
4. PSBP 315733(4) Radiation Monitoring System Control Manual Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: RU*

SGS ECG - EAL Technical Bases EP-SC-1 11 -203 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: R u 1.o 1

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 2 times the 0DCM for 60 minutes or longer EAL# & Classification Level: RU1.2 - UNUSUAL EVENT Mode Applicability: All EAL: ANY VALID liquid monitor reading > Table R-1 column "UE" AND _ 60 minutes have elapsed (Note 2) Note 2: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: RUI. o2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 .. ............... " Table R-1 Effluent Monitor Classification Thresholds*. Release Point Monitor GE SAE ALERT UE Plant Vent 1R41D +2R41D 0 S-E Effluent Noble OR 8.48E+09 pCi/sec 8.48E+08 pCi/sec 4.84E+07 pCi/sec 4.84E+05 pCi/sec 0 Gas SPDS combined Unit 1 + Unit 2 release rate Containment Fan Coil 1(2)R13A/B ........ 1.64E+05 cpm 1.64E+03 cpm Process Liquid 1R18 Ui= 5.50E+05 cpm Radwaste N/A .... -* Disposal See EAL RA1.3 

"    Process                  2R18                                                                          U2= 9.90E+05 cpm SJ steam                   1R19A-D                                                   U1= 6.40E+05 cpm      UI= 6.40E+03 cpm Generator Blowdown Process                2R19A-D                                                   U2= 8.30E+05 cpm      U2= 8.30E+Ci3 cpm Non-Rad Liquid           2R37                                                       3.60E+05 cpm          3.60E+03 cpm Waste For high radiation conditions on Letdown Line Monitor 1 R31A (2R31), refer to EAL SU7.1 Basis:

This EAL addresses a potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended, period of time. Nuclear power plants incorporate features intended to control therelease of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintehti6hal -eleases, or co-ntrol and m6r'-iior intentional release'.The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls. The threshold values that equate to a multiple of two times the ODCM limits are specified in EAL RU1.2 only to distinguish between non-emergency conditions. While this multiple obviously corresponds to an off-site dose or dose rate, the emphasis in classifying this event is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate. This EAL addresses radioactivity releases, that for whatever reason, cause effluent radiation monitor readings to exceed the threshold identified in the EAL. This EAL is intended for sites that have established effluent monitoring on non-routine liquid release pathways for which a discharge permit would not normally be prepared (Containment Fan Coil, SG Blowdown & Chemical Waste Basin) as well as planned batch releases for which a radioactivity discharge permit is prepared (Liquid Radwaste Disposal). Salem Page 2 of 4 Rev. 0 (draft E) EAL#: rU 1. 2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Explanation/Discussion/Definitions: The column "UE" liquid release values in Table R-1 represent two (2) times the High Alarm setpoints ( except 2R18 which is 1.5 times) associated with the specified monitors. The High Alarm setpoints are obtained from channel calibrations procedures as listed in the reference section of this bases. Instrumentation that may be used to assess this EAL is listed below: o Containment Fan Coil Process 1(2)R13A/B (Upper Range is 1.OOE+06 cpm) Service water is used as the cooling medium for the containment fan coil units (CFCUs) and could be contaminated if the cooling coil leaks with containment pressure above Service Water pressure. Since the Service Water System discharges into Circ Water and then back to the river, the fan cooler units will be indirectly monitored for radioactivity. This is done through the use of two monitors for the five fan coolers. The two monitors sample two of the three Circ Water headers that contain Service Water used to cool the CFCUs just before it discharges back to the river. Alarms on these monitors would be indicative of a CFCU leak but could also be associated with other systems including from the pathways monitored by the R1 8s, R1 9s and the R37, which also discharge into Circ Water and are monitored by the 1(2)R13A/B. If simultaneous Rad Alarms are received on an R13 monitor along with any R18s, Rl9s or R37 monitor, then the source of the Rad effluent may not be a CFCU leak and further investigation would be warranted. However, exceeding the EAL threshold value for > 60 minutes should result in Unusual Event classification even if the exact source remains questionable. o Liquid Radwaste Disposal Process 1(2)R1 8 (Upper Range is 1.OOE+06 cpm) This channel continuously monitors all Waste Disposal System liquid releases from the plant. Automatic valve closure action is initiated by this monitor when a high radiation level is indicated and alarmed in the Control Room. Liquid Radwaste discharges to Circ Water which then discharges to the Delaware River. This Unit 1 EAL threshold is based on 2 times the High Alarm Set Point as defined in the Channel Calibration procedure. This Unit 2 EAL threshold is based on a value that is approximately 1.5 times the High Alarm Set Point as defined in the Channel Calibration procedure which ensures that the threshold value is within the upper range of the monitor. Since the ranges of the 1(2) R18s monitors do not support EAL threshold values of 200 times the high alarm value, no Alert threshold is provided on Table R-1. If the release pathway could not be isolated as expected, the EC should refer to EAL RA1.3 for Alert threshold values based on sample analysis. Salem Page 3 of 4 Rev. 0 (draft E) EAL#: RU1I .2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 o Steam Generator Blowdown Process 1(2)R19A-D (Upper Range is 1.OOE+06 cpm) Each of these channels (four channels per unit) monitors the liquid phase of the steam generators for radioactivity, which would indicate a primary-to-secondary system leak. The four steam generator blowdown sample lines each have a radiation monitor. A high radiation alarm signal will close the No. 12 (22) steam generator blowdown tank inlet valves and the steam generator blowdown isolation valves on the affected steam generator. o Non-Rad Liquid Waste 2R37 (Upper Range is 1.OOE+06 cpm) The non-radwaste basin provides a potential release path due to the fact that steam generator blowdown is directed to the basin during plant startup. This monitor provides for continuous monitoring of the discharge from the non-radwaste basin. Non-Rad Liquid Waste discharges to Circ Water which then discharges to the Delaware River. Definitions: VALID:. An. indication, report, or condition, is considered to be VALID when it is verified by (1) :an instrument channel check,.or (2) indications on related or redundant. indicators, or (3) by direct observation by plant personnel, such that doubt r~elated to the indicator's'operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):.

1. NEI 99-01 Rev. 5, AU1 Example EAL #2
2. Salem ODCM Section 3.3.8 -. Radioactive Liquid EffluentMonitoring Instrumentation
3. Salem ODCM Figures 1-1 and 1-2, Liquid Release Flow paths for Unit 1 and Unit 2
4. UFSAR Section 11.4 Radiation Monitoring
5. PSBP 31.5733(4) Radiation Monitoring System Control Manual
6. S1(S2).IC-CC.RM-0097/98,. Channel'Cal for 1/2R13A/B
7. S1(S2).IC-CC.RM-0028, Channel Cal for 1/2R18
8. S1 (S2).IC-CC.RM-0029/30/31/32, Channel Cal for 1/2R1 9A/B/C/D
9. S2.IC-CC.RM-0060, Channel Cal for 2R37 Salem Page 4 of 4 Rev. 0 (draft E)

EAL#: R U 1. 2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 2 times the ODCM for 60 minutes or longer EAL# & Classification Level: RU1.3 - UNUSUAL EVENT Mode Applicability: All EAL: Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > Table R-2 column "UE" AND >_60 minutes have elapsed (Note 2) Note 2: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown. ___ .Table R-2 Effluent Sample Classification Thresholds Release Point Sample ALERT UE NG 6.40E-01 pCi/cc 6.40E-03 pCi/cc Plant Vent 0 1-131 5.60E-05 pCi/cc 5.60E-07 pCi/cc V) Unmonitored Isotopic 200 x ODCM 3/4.11.2 2 x ODCM 3/4.11.2 Containment Fan Coil Isotopic 200 x ODCM 3/4.11.1 2 x ODCM 3/4.11.1 

           .2   Liquid Radwaste Disposal        Isotopic   200 x ODCM 3/4.11.1      2 x ODCM 3/4.11.1
           .2   Steam Generator Blowdown        Isotopic   200 x ODCM 3/4.11.1      2 x ODCM 3/4.11.1 Chemical Waste Basin           Isotopic    200 x ODCM 3/4.11.1      2 x ODCM 3/4.11.1 Unmonitored                     Isotopic   200 x ODCM 3/4.11.1      2 x ODCM 3/4.11.1 Salem                                                Page 1 of 4                                 Rev. 0 (draft E)

EAL#: RU .3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Basis: This EAL addresses a potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls. The multiple of two times the ODCM limits is specified in EAL RU1.3 only to distinguish between non-emergency conditions. While this multiple obviously corresponds to an off-site dose or dose rate, the emphasis in classifying this event is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate. This EAL includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit for > 60 minutes. This EAL addresses uncontrolled releases that are detected by sample analyses, particularly on unmonitoredr pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc. Explanation/Discussion/Definitions: Releases in excess of two times the site Offsite Dose Calculation Manual (ODCM) Section 3/4.11.1 or 3/4.11.2 limits that continue for 60 minutes or longer represent an uncontrolled situation and. hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the UNUSUAL EVENT emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes. Table R-2 provides calculated radiological release noble gas and iodine sample concentrations that equate to a release that is 2 times the ODCM limit(Section 3/4.11.2).of 500 mRem/year as well as specifying liquid release effluent sample streams 2 times the ODCM limits (Section 3/4.11.1). Each Salem unit has a single gaseous release point (Plant Vent) for which a sample concentration threshold has been calculated. Salem Page 2 of 4 Rev. 0 (draft E) EAL#:RUI]3

SGS ECG - EAL Technical Bases EP-SC-111-203 EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AUL1 Example EAL #3
2. Off-Site Dose Calculation Manual, Section 3/4.11.1 - Liquid Effluents
3. Off-Site Dose Calculation Manual, Section 3/4.11.2 - Gaseous Effluents
4. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)

Salem Page 3 of 4 Rev. 0 (draft E) EAL#:RUi.3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: R[ I.3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 200 times the ODCM for 15 minutes or longer Mode Applicability: All EAL# & Classification Level: RAI.1 -ALERT EAL: VALID gaseous monitor reading > Table R-1 column "ALERT" AND > 15 minutes have elapsed (Note 2) Note 2: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: RA i]

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Table R-1 Effluent.Monitor Classification Thresholds*. Release Point Monitor GE SAE ALERT UE Plant Vent 1 R41D + 2R41D o Effluent Noble OR Ga 8.48E+09 pCi/sec 8.48E+08 pCi/sec 4.84E+07 pCi/sec 4.84E+05 pCi/sec V) Gas SPDS combined (D Unit 1 + Unit 2 release rate Containment Fan Coil 1(2)R13A!B ---- 1.64E+05 cpm 1.64E+03 cpm Process Liquid 1R18 U1= 5.50E+05 cpm Radwaste N/A . Disposal See EAL RA1.3 

    . Process                2R18                                                                          U2= 9.90E+05 cpm

.' Steam 1R19A-D UI= 6.40E+05 cpm U1= 6.40E+03 cpm Generator Blowdown Process 2R19A-D U2= 8.30E+05 cpm U2= 8.30E+03 cpm Non-Rad Liquid 2R37 ---- 3.60E+05 cpm 3.60E+03 cpm Waste

  • For high radiation conditions on Letdown Line Monitor 1R31A (2R31), refer to EAL SU7.1 Basis:

This EAL addresses an actual or substantial potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time . Nuclear power plants incorporate features intended to control the release. of radioactive. effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls. The threshold value that equates to a multiple of two hundred times the ODCM limits is specified in EAL RA1.1 only to distinguish between non-emergency conditions. While this multiple obviously corresponds to an off-site dose or dose rate, the emphasis in classifying this event is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate. This EAL is intended for sites that have established effluent monitoring on non-routine release pathways for which a discharge permit would not normally be prepared. Explanation/Discussion/Definitions: The column "ALERT" gaseous release value in Table R-1 (Unit 1 + Unit 2) represents two hundred times the associated effluent monitor alarm setpoint. This setpoint is set to preclude exceeding the ODCM release rate limits associated with the specified monitor. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: rPIA,1 1]

SGS ECG - EAL Technical Bases EP-SC-1 11-203 The plant vent monitors (R41) sample and detect noble gases and collect samples of particulates and iodine discharge through the plant vent. Channel D (R41 D) provides the gaseous effluent release rate (pCi/sec) by combining (product of) the on-range R41A through R41 C with plant vent flow (cc/sec). Definitions: VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AA1 Example EAL #1
2. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)
3. UFSAR Section 11.4 Radiological Monitoring
4. PSBP 315733(4) Radiation Monitoring System Control Manual Salem Page 3 of 4 Rev. 0 (draft E)

EAL#:RAI]i

SGS ECG - EAL Technical Bases EP-SC-1 11-203 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#:

  • 1.]1

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 200 times the ODCM for 15 minutes or longer EAL# & Classification Level: RA1.2 - ALERT Mode Applicability: All EAL: ANY VALID liquid monitor reading > Table R-1 column "ALERT" AND > 15 minutes have elapsed (Note 2) Note 2: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: RAI 2

SGS ECG - EAL Technical Bases EP-SC-111-203 Table R-1 Effluent Monitor Classification Thresholds* . Release Point Monitor GE SAE ALERT UE f Plant Vent 1R41D + 2R41D o Effluent Noble OR 8.48E+09 pCi/sec 8.48E+08 ICi/sec 4.84E+07 pCi/sec 4.84E+05 pCi/sec Gas SPDS combined oD Unit 1 + Unit 2 release rate Containment Fan Coil 1(2)R13A/B ---- 1.64E+05, cpm 1.64E+03 cpm Process Liquid 1R18 N U1= 5.50E+05 cpm Radwaste N/A -o Disposal See EAL RA1.3 

  - Process             2R18                                                                           U2= 9.90E+05 cpm Sstea..               1R19A-D                                                    U1= 6.40E+05 cpm     U1 = 6.40E+03 -cpm Generator Blowdown Process            2R19A-D                                                    U2= 8.30E+05 cpm     U2= 8.30E+03 cpm Non-Rad Liquid      2R37                                                        3.60E+05 cpm          3.60E-+03 cpm Waste
  • For high radiation conditions on Letdown Line Monitor 1R31A (2R31), refer to EAL SU7.1 Basis:

This EAL addresses an actual or substantial potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments-for an extended period of time - . Nuclear power plants incorporate features intended to control the release of radioactive effluents to the environment. Further, there are administrative con-tr-olsestablished to prevent unintentional releases, or control and monitor intentional releases. The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls. The threshold values that equate to a multiple of two hundred times the ODCM limits are specified in EAL RA1.2 only to distinguish between non-emergency conditions. While this multiple obviously corresponds to an off-site dose or dose rate, the emphasis in classifying this event is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate. This EAL includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit. This EAL is intended for sites that have established effluent monitoring on non-routine release pathways for which a discharge permit would not normally be prepared (Containment Fan Coil, SG Blowdown & Chemical Waste Basin) as well as planned batch releases for which a radioactivity discharge permit is prepared (Liquid Radwaste Disposal). Salem Page 2 of 4 Rev. 0 (draft E) EAL#: RAI 2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Explanation/Discussion/Definitions: With the exception of the R18 monitors, the "ALERT" column liquid release values in Table R-1 represent two hundred (200) times the High Alarm setpoints associated with the specified monitors. The High Alarm setpoints are obtained from channel calibrations procedures as listed in the reference section of this bases. Instrumentation that may be used to assess this EAL is listed below: o Containment Fan Coil Process 1(2)R13A/B (Upper Range is 1.00E+06 cpm) Service water is used as the cooling medium for the containment fan coil units (CFCUs) and could be contaminated if the cooling coil leaks with containment pressure above Service Water pressure. Since the Service Water System discharges into Circ Water and then back to the river, the fan cooler units will be indirectly monitored for radioactivity. This is done through the use of two monitors for the five fan coolers. The two monitors sample two of the three Circ Water headers that contain Service Water used to cool the CFCUs just before it discharges back to the river. Alarms on these monitors would be indicative of a CFCU leak but could also be associated with other systems including from the pathways monitored by the R1 8s, R19s and the R37, which also discharge into Circ Water and are monitored by the 1(2)R1 3A/B. If simultaneous Rad Alarms are received on an R1 3 monitor along with any R1 8s, R19s or R37 monitor, then the source of the Rad effluent may not be a CFCU leak and further investigation would be warranted. However, exceeding the EAL threshold value for > 15 minutes should result in an Alert classification even if the exact source remains questionable. o Liquid Radwaste Disposal Process 1(2)R1 8 (Upper Range is 1.OOE+06 cpm) Since the ranges of the 1(2) R1 8s monitors do not support EAL threshold values of 200 times the high alarm value, no Alert threshold is provided on Table R-i. If the release pathway could not be isolated as expected, the EC should refer to EAL RA1.3 for Alert threshold values based on sample analysis. This channel continuously monitors all Waste Disposal System liquid releases from the plant. Automatic valve closure action is initiated by this monitor when a high radiation level is indicated and alarmed in the Control Room. Liquid Radwaste discharges to Circ Water which then discharges to the Delaware River. o Steam Generator Blowdown Process 1(2)R1 9A-D (Upper Range is 1.OOE+06 cpm) Each of these channels (four channels per unit) monitors the liquid phase of the steam generators for radioactivity, which would indicate a primary-to-secondary system leak. The four steam generator blowdown sample lines each have a radiation monitor. A high radiation alarm signal will close the No. 12 (22) steam generator blowdown tank inlet Salem Page 3 of 4 Rev. 0 (draft E) EAL#:RAI.2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 valves and the steam generator blowdown isolation valves on the affected steam generator. o Non-Rad Liquid Waste 2R37 (Upper Range is 1.OOE+06 cpm) The non-radwaste basin provides a potential release path due to the fact that steam generator blowdown is directed to the basin during plant startup. This monitor provides for continuous monitoring of the discharge from the non-radwaste basin. Non-Rad Liquid Waste discharges to Circ Water which then discharges to the Delaware River. Definitions: VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1)an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AA1 Example EAL #2
2. Salem ODCM Section 3.3.8 - Radioactive Liquid Effluent Monitoring Instrumentation
3. Salem ODCM Figures 1-1 and 1-2, Liquid Release Flow paths for Unit 1 and Unit 2
4. UFSAR Section 11.4 Radiation Monitoring
5. PSBP 315733(4) Radiation Monitoring System Control Manual
6. S1($2).IC-CC.RM-0097/98, Channel Cal for 1/2R13A/B
7. S1(S2).IC-CC.RM-0028, Channel Cal for 1/2R18
8. S1 ($2).IC-CC.RM-0029/30/31/32, Channel Cal for 1/2R1 9A/B/C/D
9. S2.IC-CC.RM-0060, Channel Cal for 2R37 Salem Page 4 of 4 Rev. 0 (draft E)

EAL#: R] .2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Any release of gaseous or liquid radioactivity to the environment greater than 200 times the ODCM for 15 minutes or longer EAL# & Classification Level: RA1.3 - ALERT Mode Applicability: All EAL: Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > Table R-2 column "ALERT" AND > 15 minutes have elapsed (Note 2) Note 2: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time. In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown. Table R-2 Effluent Sample Classification Thresholds Release Point Sample ALERT UE NG 6.40E-01 pCi/cc 6.40E-03 pCi/cc Plant Vent 0 1-131 5.60E-05 I.Ci/cc 5.60E-07 pCi/cc Unmonitored Isotopic 200 x ODCM 3/4.11.2 2 x ODCM 3/4.11.2 Containment Fan Coil Isotopic 200 x ODCM 3/4.11.1 2 x ODCM 3/4.11.1 

          ,'  Liquid Radwaste Disposal        Isotopic   200 x ODCM 3/4.11.1      2 x ODCM 3/4.11.1
          .V
          '-J Steam Generator Blowdown        Isotopic   200 x ODCM 3/4.11.1      2 x ODCM 3/4.11.1 Chemical Waste Basin            Isotopic   200 x ODCM 3/4.11.1      2 x ODCM 3/4.11.1 Unmonitored                     Isotopic   200 x ODCM 3/4.11.1      2 x ODCM 3/4.11.1 Salem                                              Page 1 of 4                                 Rev. 0 (draft E)

EAL#: RAA1 o3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Basis: This EAL addresses an actual or substantial potential decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. Nuclear power plants incorporate features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established.to prevent unintentional releases, or control and monitor intentional releases. The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of a degradation in these features and/or controls. The multiple of two hundred times the ODCM limits is specified in EAL RU1.3 only to distinguish between non-emergency conditions. While this multiple obviously corresponds to an off-site dose or dose rate, the emphasis in classifying this event is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate. This EAL addresses uncontrolled releases that are detected by sample analyses, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc. ExplanationiDiscussionlDefinitions: Confirmed sample analyses in excess of two hundred times the'site Offsite Dose Calculation Manual Section 3/4.11.1- or 3/4.11.2 limits that continue for 15rminutes or longer represent an uncontrolled situation and hence, a potential degradation in the level'of safety. This event escalates from the UNUSUAL EVENT by raising the magnitude of the release by a factor of 100 over the UNUSUAL EVENT level (i.e., 200 times ODCM). Table R-2 provides calculated radiological release noble gas and iodine sample concentratinh-s that 6quate to a -relea-se that is200 times the ODCM limit (Section 3/4.11.2) of 500 mRem/year as well as specifying liquid release effluent sample streams 200 times the ODCM limits (Section 3.11.1). Each Salem unit has-a single gaseous release point (Plant Vent) for which a sample concentration threshold has been calculated. The required release duration was reduced to 15 minutes in recognition of the raised severity. Salem Page 2 of 4 Rev. 0 (draft E) EAL#:RAi.3

SGS ECG - EAL Technical Bases EP-SC-111-203 EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AA1 Example EAL #3
2. Off-Site Dose Calculation Manual, Section 3/4.11.1 - Liquid Effluents
3. Off-Site Dose Calculation Manual, Section 3/4.11.2 - Gaseous Effluents
4. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)

Salem Page 3 of 4 Rev. 0 (draft E) EAL#: RA 3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 This page intentionally blank Salenm Page 4 of 4 Rev. 0 (draft E) EAL#:RA] 3

SGS ECG - EAL Technical Bases EP-SC-111-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 100 mRem TEDE or 500 mRem Thyroid CDE for the actual or projected duration of the release Mode Applicability: All EAL# & Classification Level: RSI.1 - SITE AREA EMERGENCY EAL: VALID gaseous monitor reading > Table R-1 column "SAE" AND Dose assessment results are NOT available AND _ 15 minutes have elapsed (Note 1) Note 1: If dose assessment results are available, declaration should be based on dose assessment (EAL RS1.2) instead of gaseous monitor values. Do NOT delay declaration awaiting dose assessment results. The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: RSIAl

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Table R-1 Effluent Monitor classification. Thresholds* . Release Point Monitor GE SAE ALERT UE Plant Vent 1 R41 D + 2R41 D o Effluent EfetoeoR Ga Noble O.RR. 8.48E+09 pCi/sec 8.48E+08 pCi/sec 4.84E+07 pCi/sec 4.84E+05 pCi/sec Gas SPIDS combined 0 Unit 1 + Unit 2 release rate Containment Fan Coil 1(2)R1 3A/B 1.64E+05 cpm 1.64E+03 cpm Process Liquid 1R18 U1= 5.50E+05 cpm Radwaste N/A -o*. Disposal Process 2R18 .R1" See EAL RA1.3 U U2= 9.90E4-05 cpm "J Steam 1R19A-D U1= 6.40E+05 cpm U1= 6.40E+03 cpm Generator Blowdown Process 2R19A-D U2= 8.30E+05 cpm U2= 8.30E+03 cpm Non-Rad Liquid 2R37 - 3.60E+05 cpm 3.60E+03 cpm W aste I...

  • For high radiation conditions on Letdown Line Monitor 1R31A (2R31), refer to EAL SU7.1 Basis:

This EAL addresses radioactivity releases that result in doses at or beyond the site boundary that exceed 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. While these failures.are addressed by other EALs, this EAL provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertaintiesassociated with the source term and/or meteorology. The TEDE dose which forms the bases for the specified effluent monitor threshold is set at 10% of the EPA PAG. The Table R-1 monitor list includes effluent monitors on all potential release pathways. Since dose assessment is based on actual meteorology, whereas the monitor reading EAL is not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted. For this reason, emergency implementing procedures call for the timely performance of dose assessments using actual meteorology and release information. If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor reading EAL. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: IRS 1]°I]

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Explanation/Discussion/Definitions: This EAL address gaseous radioactivity releases, that for whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed 100 mRem TEDE. The column "SAE" gaseous effluent release values in Table R-1 (Unit 1 + Unit 2) correspond to calculated doses of 10% of the EPA Protective Action Guidelines (TEDE). The plant vent monitors (R41) sample and detect noble gases and collect samples of particulates and iodine discharge through the plant vent. Channel D (R41 D) provides the gaseous effluent release rate (pCi/sec) by combining (product of) the on-range R41A through R41 C with plant vent flow (cc/sec). If dose assessment results are available, EAL RS1.2 would dictate the need for a Site Area Emergency classification due to abnormal radiation effluents. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AS1 Example EAL #1
2. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)
3. UFSAR Section 11.4 Radiological Monitoring
4. PSBP 315733(4) Radiation Monitoring System Control Manual Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: R31.1

SGS ECG - EAL Technical Bases EP-SC-111-203 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: RS 1. 1

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 100 mRem TEDE or 500 mRem Thyroid CDE for the actual or projected duration of the release EAL# & Classification Level: RS1.2 - SITE AREA EMERGENCY Mode Applicability: All EAL: Dose assessment using actual meteorology indicates TEDE 4-day dose > 4.OE+02 mRem or Thyroid CDE dose > 2.OE+03 mRem at or beyond the MINIMUM EXCLUSION AREA (MEA) Basis: This EAL addresses radioactivity releases that result in doses at or beyond the MINIMUM EXCLUSION AREA (MEA) that exceed 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. While these failures are addressed by other EALs, this EAL provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertainties associated with the source term and/or meteorology. The TEDE dose is set at 10% of the EPA PAG, while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE. Since dose assessment is based on actual meteorology, whereas the monitor reading EAL is not, the results from these assessments may indicate that the classification is not warranted, or may indicate that a higher classification is warranted. For this reason, emergency implementing procedures call for the timely performance of dose assessments using actual meteorology and release information. If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor reading EAL. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: RSI*] ,2

SGS ECG - EAL Technical Bases EP-SC-1 11 -203 Explanation/DiscussionlDefinitions: The dose assessment output on the Station Status Checklist (SSCL) is reported at varying distances from the plant as a TEDE 4-Day dose. This TEDE 4-day dose assumes a 4 hr release duration. .To obtain the approximate dose for a projected release condition of 1 hour, the TEDE 4-day.dose value would.need to be divided by. 4. A TEDE 4-Day Dose > 4.OE+02 mRem correspond directly to a TEDE dose rate value of 100 mRem/hr and exceeds 10% of the EPA Protective Actions Guides (PAGs). The Thyroid-CDE Dose > 2.OE+03 mRem correspond directly.to an.OCDE dose, rate value of 500 mRem/hr and exceeds 10% of the EPA Protective Actions Guides (PAGs) which was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE. For the purposes of this EAL, the Site Boundary for SGS is the MINIMUM EXCLUSION AREA. Definitions:" IMMIONENT: Mitigation actions have been ineffective, additional actions are not 

     'expected to-b-estccessful, and-trerided information- indicates that the eent or'condition will occur within approximately 2 hours (unless a different time is specified).

MINOMUM EXCLUSIION AREA (MEA).: The closest location ju.st beyond the OWNER CONTROLLED AREA where a member of the general public could gain access. For. Salem the MEA is 0.79 miles.' .  : . - -. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG 

       .purposeNuclear  as part of the Salem & Hope.Creek Generating Station complex. For the of emergency classificati6n, area from the PSEG' Nuclear access road oheckpoint and inward towards the stations is considered the OCA.

EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AS1 Example EAL #2
2. Salem Radiological EAL Setpoint- alc'ulation Document NEI 99-01 Rev. 5 EA "Ls (Attachment 6)
3. U.FSAR 2.1.2.2, Boundaries for Establishing Effluent Release Limits:.

Salem Page 2 of 2 Rev. 0 (draft E) 

                           '-                                                   ~EAL#:R[SI. 2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 100 mRem TEDE or 500 mRem Thyroid CDE for the actual or projected duration of the release EAL# & Classification Level: RS1.3 - SITE AREA EMERGENCY Mode Applicability: All EAL: Field survey results indicate closed window dose rates > 100 mRem/hr expected to continue for > 1 hr at or beyond the PROTECTED AREA BOUNDARY OR Analyses of field survey samples indicate 1-131 concentration > 3.85E-07 ýiCi/cc at or beyond the PROTECTED AREA BOUNDARY Basis: This EAL addresses radioactivity releases that result in doses at or beyond the PROTECTED AREA BOUNDARY that exceed 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. While these failures are addressed by other EALs, this EAL provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertainties associated with the source term and/or meteorology. The TEDE dose is set at 10% of the EPA PAG, while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE. Explanation/Discussion/Definitions: This EAL addresses a radioactivity release field survey 1-131 sample concentration or count rate that would result in a Thyroid CDE dose of greater than 500 mRem for one hour of inhalation at or beyond the PROTECTED AREA BOUNDARY. This value exceeds 10% of the Salem Page 1 of 2 Rev. 0 (draft E) EAL#:RSI.3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. The lodine-131 field survey sample concentration and count rate threshold is based on 1-131 dose conversion factors (DCFs) from EPA-400. The.thresholds are based on a Thyroid-CDE Dose Rate of 500 mRem/hr for 1-131. For the purposes of this EAL, the PROTECTED AREA BOUNDARY is used as it is an easily determined location to obtain a field survey dose rate reading or to obtain a field sample. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AS1 Example EAL #4
2. Off-Site Dose Calculation Manual, Figure 5.1-3, Area Plot Plan of Site
3. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)

Salem Page 2 of 2 Rev. 0 (draft E) EAL#:RSI.3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 1000 mRem TEDE or 5000 mRem Thyroid CDE for the actual or projected duration of the release Mode Applicability: All EAL# & Classification Level: RGI.1 - GENERAL EMERGENCY EAL: VALID gaseous monitor reading > Table R-1 column "GE" AND Dose assessment results are NOT available AND > 15 minutes have elapsed (Note 1) Note 1: If dose assessment results are available, declaration should be based on dose assessment (EAL RG1.2) instead of gaseous monitor values. Do NOT delay declaration awaiting dose assessment results. The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: Al

SGS ECG - EAL Technical Bases EP-SC-1 11-203 K  ::. Table R-1 Effluent Monitor Classification Thresholds* Release Point Monitor GE SAE ALERT UE Plant Vent 1R41D + 2R41D o Effluent Noble OR Gas Gas b "S. . 8.48E+09 pCi/sec 8.48E+08 pCi/sec 4.84E+07 pCi/sec 4.84E+05 pCi/sec SPIDS combined 0 Unit 1 + Unit 2 release rate Containment Fan Coil 1(2)R1 3A/B ---- ---- 1.64E+05 cpm 1.64E+03 cpm Process Liquid 1R18 U1= 5.50E+05 cpm Radwaste N/A . Disposal See EAL RA1.3 

 . Process               2R18                                                                           U2= 9.90E+05 cpm

"* Steam 1R19A-D U1= 6.40E+05 cpm U1= 6.40E+03 cpm Generator Blowdown Process 2R19A-D U2= 8.30E+05 cpm U2= 8.30E+03 cpm Non-Rad Liquid 2R37 ---- 3.60E+05 cpm 3.60E+03 cpm Waste

  • For high radiation conditions on Letdown Line Monitor 1R31A (2R31), refer to EAL SU7.1 Basis:

This EAL addresses radioactivity releases that result in doses at or beyond the site boundary that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection" of the public and likely involve fueldafnage: While these failures are addressed by other EALs, this EAL provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large unce-rtainties'associated with the sourCe term and/or meteorology. The TEDE dose which forms the. bases for the specified effluent monitor threshold is set at the EPA PAG. The Table R-1 monitor list includes effluent monitors on all potential release pathways. Since dose assessment is based on actual meteorology, whereas the monitor reading EAL is not, the results from these assessments may indicate that the classification is not warranted. For this reason, emergency implementing procedures call for the timely performance of dose assessments using actual meteorology and release information. Ifthe results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor reading EAL. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: I. jrfG I

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Explanation/Discussion/Definitions: This EAL address gaseous radioactivity releases, that for whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed 1000 mRem TEDE. The column GE gaseous effluent release values in Table R-1 (Unit 1 + Unit 2) correspond to calculated doses of 100% of the EPA Protective Action Guidelines (TEDE). The plant vent monitors (R41) sample and detect noble gases and collect samples of particulates and iodine discharge through the plant vent. Channel D (R41 D) provides the gaseous effluent release rate (pCi/sec) by combining (product of) the on-range R41A through R41 C with plant vent flow (cc/sec). If dose assessment results are available, EAL RG1.2 would dictate the need for a General Emergency classification due to abnormal radiation effluents. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AG1 Example EAL #1
2. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)
3. UFSAR Section 11.4 Radiological Monitoring
4. PSBP 315733(4) Radiation Monitoring System Control Manual Salem Page 3 of 4 Rev. 0 (draft E)

EAL#:RGI.1

SGS ECG - EAL Technical Bases EP-SC-1 11-203 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: RGI.

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 1000 mRem TEDE or 5000 mRem Thyroid CDE for the actual or projected duration of the release EAL# & Classification Level: RG1.2 - GENERAL EMERGENCY Mode Applicability: All EAL: Dose assessment using actual meteorology indicates TEDE 4-day dose > 4.OE+03 mRem or Thyroid CDE dose > 2.OE+04 mRem at or beyond the MINIMUM EXCLUSION AREA (MEA) Basis: This EAL addresses radioactivity releases that result in doses at or beyond the MINIMUM EXCLUSION AREA (MEA) that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and likely involve fuel damage. While these failures are addressed by other EALs, this EAL provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertainties associated with the source term and/or meteorology. The TEDE dose is set at the EPA PAG, while the 5000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE. Since dose assessment is based on actual meteorology, whereas the monitor reading EAL is not, the results from these assessments may indicate that the classification is not warranted. For this reason, emergency implementing procedures call for the timely performance of dose assessments using actual meteorology and release information. If the results of these dose assessments are available when the classification is made (e.g., initiated at a lower classification level), the dose assessment results override the monitor reading EAL. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:RGI.2

SGS ECG - EAL Technical Bases EP-SC-111-203 Explanation/Discussion/Definitions: The dose assessment output on the Station Status Checklist (SSCL) is reported at varying distances from the plant as a TEDE 4-Day dose. This TEDE 4-day dose assumes a 4 hr release duration. To obtain the approximate dose for a projected release condition of 1 hour, the TEDE 4-day dose value would need to be divided by 4. A TEDE 4-Day Dose > 4.OE+03 mRem correspond directly to a TEDE dose rate value of 1000 mRem/hr and exceeds the EPA Protective Actions Guides (PAGs). The Thyroid-CDE Dose > 2.OE+04 mRem correspond directly to an CDE dose rate value of 5000 mRem/hr and exceeds the EPA Protective Actions Guides (PAGs) which was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE. For the purposes of this EAL, the Site Boundary for SGS is the MINIMUM EXCLUSION AREA (MEA) dista-nce. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful,- and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). MWINMUM EXCLUSION AREA (MEA): The closest location just beyond the OWNER CONTROLLED AREA where a member of the general public could gain access. For Salem the MEA is 0.79 miles. OWNER CONTROLLED AREA (OCA): Property owned* maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AG1 Example EAL #2"..
2. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6).
3. UFSAR 2.1.2.2, Boundaries for Establishing Effluent Release Limits Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: R31 .2

SGS ECG - EAL Technical Bases EP-SC-1 11-203 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 1 - Offsite Rad Conditions Initiating Condition: Off-site dose resulting from an actual or IMMINENT release of gaseous radioactivity greater than 1000 mRem TEDE or 5000 mRem Thyroid CDE for the actual or projected duration of the release EAL# & Classification Level: RG1.3 - GENERAL AREA EMERGENCY Mode Applicability: All EAL: Field survey results indicate closed window dose rates > 1000 mRem/hr expected to continue for > 1 hr at or beyond the PROTECTED AREA BOUNDARY OR Analyses of field survey samples indicate 1-131 concentration > 3.85E-06 jiCi/cc at or beyond the PROTECTED AREA BOUNDARY Basis: This EAL addresses radioactivity releases that result in doses at or beyond the PROTECTED AREA BOUNDARY that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and likely involve fuel damage. While these failures are addressed by other EALs, this EAL provides appropriate diversity and addresses events which may not be able to be classified on the basis of plant status alone. It is important to note that for the more severe accidents the release may be unmonitored or there may be large uncertainties associated with the source term and/or meteorology. The TEDE dose is set at the EPA PAG, while the 5000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE. Explanation/Discussion/Definitions: This EAL addresses a radioactivity release field survey I-131 sample concentration or count rate that would result in a Thyroid CDE dose of greater than 5000 mRem for one hour of inhalation at or beyond the PROTECTED AREA BOUNDARY. This value exceeds the EPA Salem Page 1 of 2 Rev. 0 (draft E) EAL#: RGi].3

SGS ECG - EAL Technical Bases EP-SC-1 11-203 Protective Action Guides (PAGs). Releases of this magnitude. are associated with the failure of plant systems needed for the protection of the public. The Iodine-131 field survey sample concentration and count rate threshold is based on 1-131 dose conversion factors (DCFs) from EPA-400. The thresholds are based on a Thyroid-CDE Dose Rate of 5000 mRem/hr for 1-131. For the purp-6ses of this EAL, the PROTECTED AREA BOUNDARY is used as it is an easily determined location to obtain a field survey dose rate reading or to obtain a field sample. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road*- checkpoint and inward towards the stations is considered the OCA. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AG1 Example EAL #4
2. Off-Site Dose Calculation Manual, Figure 5.173, Area Plot Plan of Site
3. Salem Radiological EAL Setpoint Calculation Document NEI 99-01 Rev. 5 EALs (Attachment 6)

Salem Page 2 of 2 Rev. 0 (draft E) EAL#: RI.3

SGS ECG - EAL Technical Bases EP-SC-1 11-204 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 2 - Onsite Rad Conditions/Fuel Pool Events Initiating Condition: UNPLANNED rise in plant radiation levels Mode Applicability: All EAL# & Classification Level: RU2.1 - UNUSUAL EVENT EAL: UNPLANNED water level drop in the refueling cavity, refueling canal or spent fuel pool (SFP) as indicated by ANY of the following: o Confirmed SFP low level alarm (OHA-C35 SFP LVL LO) o RVLIS - Refueling Mode o Visual observation (local or remote) AND VALID area radiation monitor reading rise on ANY of the following: o 1(2)R5 Fuel Handling Bldg o 1(2)R9 Fuel Storage Area o 1(2)R32A Fuel Handling Crane Fuel Handling Bldg (local monitor) o 1(2)R2 Containment General Area 130ft elevation o Temporary ARM Basis: This EAL addresses increased radiation levels as a result of water level decreases above irradiated fuel or events that have resulted, or may result, in unplanned increases in radiation dose rates within plant buildings. These radiation increases represent a loss of control over radioactive material and represent a potential degradation in the level of safety of the plant. The refueling pathway is the combination of cavities and pools in which spent fuel may be located. While a radiation monitor could detect an increase in dose rate due to a drop in the water level, it might not be a reliable indication of whether or not the fuel is covered. For example, an ARM reading may increase due to planned evolutions such as head lift, or even a fuel assembly being raised in the manipulator mast. Also, a monitor could in fact be Salem Page 1 of 4 Rev.0 (draft E) EAL#: RU2.>I

SGS ECG - EALTechnical Bases EP-SC-1 11-204 properly responding to a known event involving transfer or relocation of a source, stored in or near the fuel pool or responding to a planned evolution such as removal of the reactor head. Generally, increased radiation monitor indications will need to combined with another indicator (or personnel report) of water loss. For refueling events where the water level drops below the Reactor Vessel flange, classification would be via EAL CU3.1. This event escalates to an ALERT per EAL RA2.1 if irradiated fuel outside the reactor vessel is uncovered. For events involving irradiated fuel in the reactor vessel, escalation would be via the Fission Product Barrier Table for events in operating modes 1-4. Expiaiantion/Discussion/Defiriti6n S: The Spent Fuel Pool (SFP) low level alarm actuates at 128' 2" from 1(2)LC650. During refueling operations the reactor vessel and refueling cavity are flooded. During fuel handling operations, the fuel transfer tube (canal) will connect the refueling cavity and the Spent Fuel Pool (SFP). An unexplained lowering of refueling cavity level'or SFP level can be an indication that these volumes are draining. A drop in refueling cavity and SFP level may result in a SFP low-level alarm. This alarm would be validated by visual observation of lowering level (local or remote) in the refueling cavity or SFP. When the spent fuel pool and refueling cavity are connected, there could exist the possibility of uncovering irradiated fuel. Therefore, this EAL is applicable for conditions in which irradiated fuel is being transferred to and from the Reactor Vessel and SFP as well as for SFP drain down events. For a loss of shielding, the source of,the radiation is within the refueling cavity or SFP. Without the shielding provided by normal water inventory in the SFP, equipment pool, and/or refueling cavity, radiation levels from irradiated fuel and activation products will rise substantially. Area radiation monitors.that-may respond. to-a loss of spent fuel shielding are those located on the 130' elevation (Containment or Fuel Handling Building): o 1(2)R5 Fuel Handling Bldg o 1(2)R9 Fuel Storage Area, o 1(2)R32A Fuel Handling Crane Fuel Handling Bldg (local monitor) o 1(2)R2 Containment General Area 130ft elevation o Temporary Area Radiation Monitors Definitions: . UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. Salem Page 2 of 4 Rev.0 (draft E) EAL#: RU2.1

SGS ECG - EAL Technical Bases EP-SC-1 11-204 VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AU2 Example EAL #1
2. SI(S2).OP-AR.ZZ-0003(Q) OHA-C35 SFP LVL LO
3. S1(S2).OP-AB.FUEL-0002(Q) Loss of Refueling Cavity or Spent Fuel Pool Level
4. SI (S2).OP-AB.RAD-0001 (Q) Abnormal Radiation
5. S1(S2).OP-AB.FUEL-0001(Q) Fuel Handling Incident Salem Page 3 of 4 Rev.0 (draft E)

EAL#:RU2.i

SGS ECG - EAL Technical Bases EP-SC-I 1 lw--204 This page intentionally blank Salem Page 4 of 4 Rev.O (draft E) EAL#: RUM2oI

SGS ECG - EAL Technical Bases EP-SC-1 11-204 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 2 - Onsite Rad Conditions/Fuel Pool Events Initiating Condition: UNPLANNED rise in plant radiation levels Mode Applicability: All EAL# & Classification Level: RU2.2 - UNUSUAL EVENT EAL: UNPLANNED VALID area radiation monitor readings or survey results rise by a factor of 1,000 over normal levels (Note 7) Note 7: Normal levels can be considered as the highest reading in the past 24 hours excluding the current peak value Basis: This EAL addresses UNPLANNED increases in radiation dose rates within plant buildings. These radiation increases represent a loss of control over radioactive material and represent a potential degradation in the level of safety of the plant. This EAL excludes radiation level increases that result from planned activities such as use of radiographic sources and movement of radioactive waste materials. A specific list of ARMs is not required as it would restrict the applicability of the threshold. The intent is to identify loss of control of radioactive material in any monitored area. Explanation/Discussion/Definitions: Definitions: UNPLANNED - A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. VALID - An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. I EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AU2 Example EAL #2 Salem Page 1 of 2 Rev. 0 (draft E)

EAL#:RU2o2

SGS ECG - EAL Technical Bases EP-SC-1 11-204 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: RU2O2

SGS ECG - EAL Technical Bases EP-SC-1 11-204 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 2 - Onsite Rad Conditions/Fuel Pool Events Initiating Condition: Damage to irradiated fuel or loss of water level that has resulted or will result in the uncovering of irradiated fuel outside the Reactor Vessel Mode Applicability: All EAL# & Classification Level: RA2.1 - ALERT EAL: Damage to irradiated fuel or loss of water level (uncovering irradiated fuel outside the Reactor Vessel) that causes a VALID high alarm on ANY of the following radiation monitors: Fuel Handling Bldg o 1(2)R5 Fuel Handling Bldg 1(2)R9 Fuel Storage Area o 1(2)R32A Fuel Handling Crane Fuel Handling Bldg (local monitor) o 1(2)R41A Plant Vent Containment o 1(2)R2 Containment General Area 130ft elevation o 1(2)R11A Containment Air- Particulate o 1(2)R12A Containment Vent - Noble Gas o 1(2)R12B Containment Vent- Iodine Basis: This EAL addresses increases in radiation dose rates within plant buildings, and may be a precursor to a radioactivity release to the environment. These events represent a loss of control over radioactive material and represent an actual or substantial potential degradation in the level of safety of the plant. Salem Page 1 of 4 Rev. 0 (draft E) EAL#:RA2oi

SGS ECG - EAL Technical Bases EP-SC-1 11-204 These events escalate from EAL RU2.1 in that fuel activity has been released, or is anticipated due to fuel heatup. This EAL applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage. This EAL addresses radiation monitor indications of fuel uncovery and/or fuel damage. Increased ventilation monitor readings may be indicatiorn of a radioactivity release from the fuel, confirming that damage has occurred. Increased background at the ventilation monitor due to water level decrease may mask increased ventilation exhaust airborne activity and needs to be considered. While a radiation monitor could detect an increase in dose rate due to a drop in the water level, it might not be a reliable indication of whether or not the fuel is covered. For example, a refueling bridge ARM reading may increase due to planned evolutions such as head lift, or even a fuel assembly being raised in the manipulator mast. Also, anmonitorcould in fact be properly responding to a known event involving transfer or relocation of a source, stored in or near the fuel pool or responding to a planned evolution such as removal of the reactor head. Generally, increased radiation monitor indications will need to combined with another indicator (or personnel report) of water loss. Escalation of this emergency classification level, if appropriate, would be based on EAL RS1.1 or EAL RG1.1. Explanation/Discussion/Definitions: Indications of spent fuel damage may include: o Actual visual observation of a fuel handling incident o Gas bubbles in the vicinity of a fuel bundle o Discoloration of the water in the vicinity of a fuel bundle o Increasing radiation and alarm on area and ventilation..radiation monitors When the Spent Fuel Pool (SFP) and refueling cavity are connected, there could exist the possibility of uncovering irradiated fuel. Therefore, this EAL is applicable for conditions in which irradiated fuel is being transferfed to andfrorni the Reactor Vesserland SFP. For a loss of shielding, the source of the radiation is within the refueling cavity, refueling canal or SFP. Without the shielding provided by normal, water inventory in the SFP, refueling canal and/or refueling cavity, radiation levels from irradiated fuel-and activation products will rise substantially in either the Cdntainmenthor Fuel Handling, Building. Radiation levels - 2 R/hr in the Containment or FHB are indicative of imminent uncovering of spent fuel or reactor internals. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: l 2.o

SGS ECG - EAL Technical Bases EP-SC-1 11-204 Fuel Handling Building (FHB) Area Radiation Monitors (ARMs) 1(2)R5 Spent Fuel, 1(2)R9 New Fuel Storage and 1(2)R32A Fuel Handling Crane are located on the 130' elevation of the FHB. o 1(2)R5 Fuel Handling Bldg - This channel continuously monitors the fuel storage areas. A high radiation alarm will initiate charcoal filtration of the FHB atmosphere. o 1(2)R9 Fuel Storage Area - This channel also continuously monitors the fuel storage areas. A high radiation alarm will also initiate charcoal filtration of the FHB atmosphere. o 1(2)R32A Fuel Handling Crane Fuel Handling Bldg (local monitor) - This channel is not connected to the central Radiation Monitoring System and is provided with a flashing beacon and stops upward hoist movement. 1(2)R41 A Plant Vent is the low range noble gas Plant Vent monitor. Releases of fission product gases to the FHB atmosphere would be transported via the FHB ventilation and detected in the plant vent radiation monitor. Containment Area Radiation Monitor (ARM) 1(2)R2 Containment is located on the 130' elevation of the Containment. Releases of fission product particulates, iodines or gases to the Containment atmosphere would be transported via Containment ventilation and detected in the Containment Vent Radiation Monitors 1(2)R11A (part.), 1(2)R12A (gas) or 1(2)R12B (iodine). Definitions: VALID - An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AA2 Example EAL #2
2. S1(S2).OP-AB.FUEL-0002(Q) Loss of Refueling Cavity or Spent Fuel Pool Level
3. S1(S2).OP-AB.RAD-0001(Q) Abnormal Radiation
4. S1(S2).OP-AB.FUEL-0001(Q) Fuel Handling Incident
5. UFSAR Section 11.4 Radiation Monitoring Systems Salem Page 3 of 4 Rev. 0 (draft E)

EAL#:RA2.i

SGS ECG - EAL Technical Bases EP-SC-1 11-204 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#:RA

SGS ECG - EAL Technical Bases EP-SC-1 11-204 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 2 - Onsite Rad Conditions/Fuel Pool Events Initiating Condition: Damage to irradiated fuel or loss of water level that has resulted or will result in the uncovering of irradiated fuel outside the Reactor Vessel Mode Applicability: All EAL# & Classification Level: RA2.2 - ALERT EAL: A water level drop in the refueling cavity, spent fuel pool or refueling canal that will result in irradiated fuel becoming uncovered Basis: This event represents a loss of control over radioactive material and represents an actual or substantial potential degradation in the level of safety of the plant. This event escalates from EAL RU2.1 in that fuel activity release is anticipated due to fuel heatup. This EAL applies to spent fuel requiring water coverage and is not intended to address spent fuel which is licensed for dry storage. Indications may include instrumentation such as water level and local area radiation monitors, and personnel (e.g., refueling crew) reports. If available, video cameras may allow remote observation. Depending on available level instrumentation, the declaration threshold may need to be based on indications of water makeup rate or decrease in water storage tank level. Escalation of this emergency classification level, if appropriate, would be based on EAL RS1.1 or EAL RGI.1. Explanation/Discussion/Definitions: None EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AA2 Example EAL #1 Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: RA2o2

SGS ECG - EAL Technical Bases EP-SC-1 11-204 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: RA2o2

SGS ECG - EAL Technical Bases EP-SC-1 11 -205 EAL Category: R - Abnormal Rad Levels / Rad Effluent EAL Subcategory: 3 - CR/CAS Rad Initiating Condition: Rise in radiation levels within the facility that impedes operation of systems required to maintain plant safety functions Mode Applicability: All EAL# & Classification Level: RA3.1 - ALERT EAL: Basis: This EAL addresses increased radiation levels that impact continued operation in areas requiring continuous occupancy to maintain safe operation or to perform a safe shutdown. The cause and/or magnitude of the increase in radiation levels is not a concern of this EAL. The Emergency Coordinator must consider the source or cause of the increased radiation levels and determine if any other EAL may be involved. The value of 15mR/hr is derived from the GDC 19 value of 5 rem in 30 days with adjustment for expected occupancy times. Although Section ll.D.3 of NUREG-0737, "Clarification of TMI Action Plan Requirements", provides that the 15 mR/hr value can be averaged over the 30 days, the value is used here without averaging, as a 30 day duration implies an event potentially more significant than an Alert. Areas requiring continuous occupancy include the Control Room and the Central Alarm Station (CAS). Salem Page 1 of 2 Rev. 0 (draft E) EAL#: 1RA31

SGS ECG - EAL Technical Bases EP-SC-1 11-205 Explanation/Discussion/Definitions: Control Room ARM 1(2)R1A measures area radiatiQn in a range of 0.1 - 10 3 mR/hr..Should increase Control Room radiation be detected, operators are directed to align Control Room Ventilation in the Accident Pressurized mode. There is no permanently installed CAS area radiation monitor that may be used to assess this EAL threshold. Therefore, this threshold must be assessed via local radiation survey for the CAS. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, AA3 Example EAL #1
2. UFSAR Section 11.4 Radiation Monitoring Systems
3. Si (S2).OP-AB.RAD-0001(Q) Abnormal Radiation Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: RAM

SGS ECG - EAL Technical Bases EP-SC-1 11-206 EAL Category: E - ISFSI EAL Sub-category: Spent Fuel Transit Initiating Condition: Damage to a loaded cask CONFINEMENT BOUNDARY Mode Applicability: Mode NOT applicable EAL# & Classification Level: EUI.1 - UNUSUAL EVENT EAL: Damage to a Multi Purpose Canister (MPC) CONFINEMENT BOUNDARY as indicated by on-contact radiation readings . 600 mnRhr (gamma + neutron) on the surface of the spent fuel cask, excluding the air vents, OR > 60 mR/hr_(gamma + neutron) on the top of the spent fuel cask while in transit to the ISFSI. Basis: An UNUSUAL EVENT in this EAL is categorized on the basis of the occurrence df an event of sufficient, magnitude that a loaded in-transit MPC CONFINEMENT BOUNDARY is damaged or violated. This includes classification based on a loaded fuel storage-cask CONFINEMENT BOUNDARY loss posing an operational safety problem with 'respect to its removal from storage. Explanation/Discussion/Definitions: This EAL applies to emergency conditions affecting a spent fuel cask caused by an accident or natural phenomena. This EAL would be applicable at all times in all modes for a loaded spent fuel storage cask from the time the lid is installed, as the cask leaves the Salem Fuel Handling Building and during transport to the INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI). This EAL provides for an Unusual Event classification, which may be entered if conditions occur that have the potential for damaging or degrading the CONFINEMENT BOUNDARY of a spent fuel cask. Damage to the storage cask could result in an increase in direct radiation readings from the cask. This Salem EAL is only applicable for a Salem spent fuel cask that is in transit to the ISFSI. After the spent fuel cask is in place at the ISFSI, any further conditions that could adversely impact the ISFSI or an individual cask from either Salem or Hope Creek would be assessed and classified as needed by the Hope Creek Shift Manager (SM) per Hope Creek EAL EUI.1. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: IEUJ1. 1

SGS ECG - EAL Technical Bases EP-SC- 111 -206 As provided in the Holtec HI-STORM 100 System Certificate of Compliance (CoC), Appendix A (Technical Specifications), Section 5.7.4 contains radiation values for the cask that should not be exceeded. Under Amendment #5, the highest allowable radiation level on contact with the HI-STORM 100 cask body is 300 mR/hr on the side of the cask and 30 mR/hr on the top of the cask. Keeping in line with NEI guidance that a UE is warranted for radiation conditions at a level of twice the Technical Specification value, 600 mRlhr and 60 mR/hr are being used as the EAL threshold radiation levels. Continued use of this lower value is conservative for casks loaded under later CoC amendments where the radiation limit values may increase. The threshold values are: sufficiently above nominal radiation levels of the CONFINEMENT BOUNDARY that radiation levels above this EAL threshold would indicate significant damage to-the CONFINEMENT BOUNDARY. No relea:ses of radioactiVe material requiring offsite response or monitoring are expected - beca~use the seal-welded spe'nt fue'l canisteýK(part of the CONFINEMENT BOUNDARY)]is designed to remain intact under all normal, off-'normal, and credible accident conditi6ns of onsite transport and storage at the ISFSI, a'ccording to Holtec licensing documents'. Prior-to the installation of the spent fuel cask lid on the HI-STORM 100 cask, emergency classifications would be based on other Category R EALs. Definitions: 

       ;INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSl): A complex'.

that:is designed and constructed for the. interim storage of spent nuclear fuel'and-oth:e: r radioactive materials- a'ssociated: with spent fuel storage. CONFINEMENT BOUNDARY: Is the barrier(s) between areas containing radioactive substances and the environment and includes the multi-purpose canister (MPC) and, for the purposes of this EAL, the associated cask shielding. EAL Basis Reference(s):

1. NEI 99-01 Rev. 5, E-HU1 Example EAL#1
2. HOLTEC HI-STORM 100 UFSAR, Chapter 5 and Chapter 11
3. Certificate of Compliance,.Docket #72-1014
4. Holtec International Final Safety Analysis Report for the HI-STORM 100 Cask System Holtec Report No.: HI-2002444
5. Certificate of Compliance No. 72-1014 Appendix A Technical Specifications for the HI-STORM 100 Cask System Section 1.1 Definitions Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: EU1.1

EALs foix HAZARD S

SGS ECG - EAL Technical Bases EP-SC-1 11 -207 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the. PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HUI.1 - UNUSUAL EVENT (Common Site) EAL: Seismic event identified by ANY two of the following: o Earthquake felt in plant by Control Room Operators o SMA-3 Event Indicator (flag) white o National Earthquake Information Center (NEIC) (Note 4) Note 4: The NEIC can be contacted by calling (303) 273-8500. Select option #1 and inform the analyst you wish to confirm recent seismic activity in the vicinity of Salem/Hope Creek Generating Station. Provide the analyst with the following coordinates: 390 27' 46" (39.4650) north latitude, 750 32' 08" (75.5370) west longitude. Basis: This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators. Damage may be caused to some portions of the site, but should not affect ability of safety functions to operate. As defined in the EPRI-sponsored Guidelines for Nuclear Plant Response to an Earthquake, dated October 1989, a "felt earthquake" is: An earthquake of sufficient intensity such that: (a) the vibratory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated. The National Earthquake Information Center can confirm if an earthquake has occurred in the area of the plant. Salem Page 1 of 4 Rev. 0 (draft E) EAL#:HUI.i

SGS ECG - EAL Technical Bases EP-SC-1 11-207 Explanation/Discussion/Definitions: SGS seismic instrumentation consists of a Kinemetrics SMA-3 Strong Motion Accelerograph and associated sensors that are equipped with seismic triggers set to alarm (Unit 1 OHA A-37 SEIS RCDR SYS ACT) and initiate recording at an acceleration equal to or exceeding 0.01 g. When the seismic trigger activates-the SMA-3 Event Indicator (flag) will change from black to white and the amber event alarm will illuminate. The amber event alarm will extinguish when ground acceleration reduces below the 0.01 g setpoint but the Event Indicator (flag) will remain white until manually reset. Three time-history triaxial acceleration sensors are provided (2 in Reactor Building, 1 in Auxiliary Building). These sensors transmit electrical signals to be recorded on magnetic tape. The NEIC can confirm seismic activity in the vicinity of the SGS/HCGS site. Refer to Note 4 to contact the NEIC. Alternatively go to the USGS NEIC website: http ://earthquake.usgs.gov/eqcenter/ On the US map, click on 'New Jersey' and then click on earthquake indicator for information. The maps are updated within 5 min. of a measured earthquake. Additional Earthqu'ake informatiobncan be found on the internet at: o http://www.earthquake.usgs.gov o http://www.mgs.md.gov (click on "Live Earthquake Data online") o http://earthquake.usgs.gov/regional/neic This event escalates to an ALERT under EAL HA1.1 if the earthquake exceeds Operating Basis Earthquake (OBE) levels (0.1g). An approximate relationship between acceleration units in gravity and magnitude reported per the Richter scale is as follows:. An Acceleration of: is approx. equal to a Richter Scale Magnitude of: 0.01g 4.0. 0.02g 4.5 0.1 g 5.5 0.2g 6.5' Salem Page 2 of 4 Rev. 0 (draft E) EAL#: H 1.o it

SGS ECG - EAL Technical Bases EP-SC-1 11-207 Definitions: PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU1 Example EAL #1
2. UFSAR Table 7.7-3 Seismic Monitoring Instrumentation
3. SC.OP-AB.ZZ-0004(Q) Earthquake
4. S1 .OP-AR.ZZ-0001 (Q) OHA A-37 SEIS RCDR SYS ACT
5. UFSAR 2.1.1 Site Location
6. UFSAR 1.2.4 Seismology Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: HUIi

SGS ECG - EAL Technical Bases EP-SC-1 11 -207 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: HU1,

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HU1.2 - UNUSUAL EVENT (Common Site) EAL: Tornado TOUCHING DOWN within the PROTECTED AREA OR Average Wind Speeds > 95 MPH from ANY elevation of the Met Tower Basis: This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators. This EAL is based on a tornado touching down within the PROTECTED AREA or high winds onsite Escalation of this emergency classification level, if appropriate, would be based on DEGRADED PERFORMANCE, or by other in-plant conditions, via EAL HA1.2. Explanation/Discussion/Definitions: Average, as used in the EAL threshold, is intended to be the 15 minute rolling average as provided by SPDS and not the instantaneous wind speed. The design wind velocities are 108 mph (including a gust factor of approximately 1.3) at 30 feet above ground. However, the Control Room wind speed only provides indication up to 100 mph so the classification threshold has been capped at 95 mph to allow for onscale indication of wind speed. The manner in which the HCGS SPDS processes data from the meteorological instrumentation differs from the SGS SPDS; consequently, minor differences between HCGS and SGS readings may occur. A tornado touching down within the PROTECTED AREA warrants declaration of an UNUSUAL EVENT regardless of the measured wind speed at the meteorological tower. A Salem Page 1 of 2 Rev. 0 (draft E) EAL#: H]i.2

SGS ECG - EAL Technical Bases EP-SC-1 11-207 tornado is defined as a violently rotating column of air in contact with the ground and extending from the base of a thunderstorm. The National Weather Service can be contacted for further information about existing or projected Adverse Weather Conditions: o Phila/Mount Holly (609) 261-6600 o NWS Web site http://www.erh.noaa.qov/er/phi 

                   ..oh o   Phila/Mount Holly        (609) 261-6604
   " Phila/Mount Holly (609) 261-6602 Definitions:

PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is- controlled at the Security Center.... OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of:emergency classification, -area fioom the PSEG:.Nuclear access road checkpoint and inward towards the stations is considered theOCA. - VISIBLE DAMAGE: Damage to equipment or structuire that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example.damage in*,udes: deformation due to heat or impact, denting, penetration, rupture, cracking,-and 'paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU1 Example EAL.#2 .
2. UFSAR 3.3.1.1 Design wind Velocity and Loading
3. OP-AA-108-1 11-1001 Severe Weather and Natural Disaster Guidelines
4. NC.CH-SC.MET-1206(Q) Meteorological Monitoring System Calibration and Maintenance
5. SC.OP-AB.ZZ-0001 (Q) Adverse Environmental Conditions Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:[UI]2

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HU1.3 - UNUSUAL EVENT EAL: Basis: This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators. This EAL addresses main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Generator seal damage observed after generator purge does not meet the intent of this EAL because it did not impact normal operation of the plant. Of major concern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs. Actual fires and flammable gas build up are appropriately classified via EAL HU2.1 and EAL HU3.1. This EAL is consistent with the definition of an UNUSUAL EVENT while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment. Escalation of this emergency classification level, if appropriate, would be to EAL HA1.3 based on damage done by projectiles generated by the failure or by any radiological releases in Category R. Explanation/Discussion/Definitions: Main Turbine rotating component failures of sufficient magnitude to cause damage to the turbine casing or turbine/generator seals increases the potential for leakage of combustible/explosive gases and of combustible liquids to the Turbine Building or damage to Salem Page 1 of 2 Rev. 0 (draft E) EAL#: HIU 1. 3

SGS ECG - EAL Technical Bases EP-SC-1 11-207 plant systems due to PROJECTILES. The presence of H 2 gas in sufficient quantities may present a combustion hazard. Actual fires and flammable gas build up is classified under fire and flammable gas EALs. Generator seal damage observed after generator purge does not meet the intent of this EAL since it did not impact normal plant operations. Turbine rotating component failures may also result in other direct damage to plant systems and components. Damage may rupture the turbine lubricating oil system, which would release flammable liquids to the Turbine Building. Potential rupture of the condenser and condenser tubes may cause flooding in the lower levels 6f the Turbine Building. This damage 'should be readily observable. Escape of H 2 gas from the generator due to a loss of seal oil pumps or turbine lube oil without a turbine rotating component failure sh6uld not be'classified under this event but' should be reviewed lAW EALs in Subcategory H.3, Hazardous Gas. Definitions: PROTECTED AREA (PA). A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the. Salem & Hope Creek Generating Station complex. For the purpose of emergency classification. area from the PSEG Nuclear access road checkpoint and invard toWards the stations is considered the OCA. PROJ.ECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability or personnel safety. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU1 Example EAL #4
2. UFSAR 3.5.4 Turbine Missile Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: HUJl3

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HU1.4 - UNUSUAL EVENT EAL: Internal Flooding that has the potential to affect safe shutdown systems or components required by Technical Specifications for the current operating mode in ANY Table H-1 plant structure Table H-1 Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Basis: This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators. This EAL addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps. Escalation of this emergency classification level, if appropriate, would be based on DEGRADED PERFORMANCE via EAL HA1.4, or by other plant conditions. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: HU1]o4

SGS ECG - EAL Technical Bases EP-SC-1 11-207 Explanation/Discussion/Definitions: Flooding as used in this EAL describes a condition where water is entering the room faster than installed equipment is capable of removal, resulting in a rise of water level within the room. Classification of this EAL should not be delayed while corrective actions are being taken to isolate the water source. The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I. Flooding can occur from several sources including the Circulating Water System, Service Water System, Demineralized Water, Component Cooling Water, Fire Protection and Refueling Water Storage-Tank. Flooding is determined. in these areas byvisual report from staff or by confirmatibn of sump alarms. S1(S2).OP-AB.ZZ-0002 (Q) directs the operators to determine the exact location and severity of flooding. Attachments in this procedure delineate the affected plant areas; potential source(s) of-water, affected vital equipment, flood rate and time to- submerge vital equipment. If mitigating actions to control-flooding have been unsuccessful and the flooding level has reached 50% of the equipment disabled level(s) as specified in S1.(S2).OP-AB.ZZ-0002, FLOODING, then the flooding is severejis in excess of sump handling capability and has the potential to affect safety equipment and therefore, classification under this EAL is warranted. The source of the flooding and the status of the sump pumps are not factors in evaluating this EAL. For areas that do not have a flooding level specified in S1 (S2).OP-AB.ZZ-0002, SM judgment should be used. Definitions: PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. - OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: HUIA

SGS ECG - EAL Technical Bases EP-SC-1 11-207 DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit o Insufficient system pressure from keep-fill pumps

  • Elevated area temperatures or radiation levels o Increased sump pump operation in areas in which the system is located EAL Bases Reference(s):
1. NEI 99-01, Rev. 05, HU1 Example EAL #3
2. UFSAR 3.2 Classification of Structures, Components and Systems
3. S1(S2).OP-AB.ZZ-0002 (Q) Flooding Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: H U 1]o4

SGS ECG - EAL Technical Bases EP-SC-I 11-207 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: HUM

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HUI.5 - UNUSUAL EVENT (Common Site) EAL: River level > 99.5' OR River level < 80.0' Basis: See Explanation Section below: Explanation/Discussion/Definitions: The first condition of this EAL indicates river level conditions that can threaten the level of safety of the plant due to flooding. River level greater than 99.5' (+10.5' Mean Sea Level, MSL) is indication of impending site flood conditions. Flood protection measures are required by Salem Technical Specifications and procedure at 99.5'(+10.5'MSL). At this river level precautionary actions are taken, including filling outside tanks and ensuring that perimeter flood doors are closed. These actions ensure that the facility flood protection features are in place prior to a river level that would necessitate their use. Hope Creek performs these actions at 95.0' (+6.0'MSL). The High river level threshold is below the river level that would require a plant shutdown. Technical Specification actions required by a River Level of >100.5' includes placing the plant in at least Hot Standby within the next 6 hours and in Cold Shutdown within the next 30 hours. This is based on the river level at which facility flood protection features provide protection to safety related equipment. Hope Creek performs similar actions are at 99.5' (+1 0.5'MSL). The grade level at the Salem station is lower than that for Hope Creek (Salem = 99.5', Hope Creek = 101.5'). The second condition of this EAL indicates river level conditions, River level < 80.0' (-9.0'MSL), approaching the loss of the Service Water Intake (Ultimate Heat Sink). The low Salem Page 1 of 2 Rev. 0 (draft E) EAL#:HUIo5

SGS ECG - EAL Technical Bases EP-SC-111-207 level threshold indicates a river level condition that is one foot lower than the historical low water level of 81.0' (-8.0'MSL) (December 31, 1962) and is higher than the Service Water pumps design level. These events will be escalated, based on damage to plant safety systems, loss of fission product barriers or abnormal radiological releases* as discussed in other EAL categories. River level indication is displayed in Unit 1 on LA-8639 which has a range of 70' to 110'. The National Weather Service can be contacted for further information about existing or projected Adverse Weather Conditions: o Phila/Mount Holly (609) 261-6600 o NWS Web site http://www.erh.noaa.gov/er/phi o Phila/Mount Holly (609) 261-6604 o Phila/Mount Holly (609) 261-6602 Definitions: PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. 

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

EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU1 Example EAL #5
2. Technical Specifications 3/4.7.5 Flood Protection
3. UFSAR 2.4 Hydraulic Engineering
4. UFSAR Figure 2.4-3 Service Water Intake
5. UFSAR Fig-ure-3.4-1 Datum and Water Level Relationships
6. S1(S2).OP-AB.CW-0001(Q) Circulating Water System Malfunction
7. S1(S2).OP-AB.ZZ-0002(Q) Flooding
8. OP-AA-1 08-111-1001 Severe Weather and National Disaster Guidelines Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:HU].5

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting VITAL AREAS Mode Applicability: All EAL# & Classification Level: HAI.1 -ALERT EAL: Actuation of the Hope Creek OBE Seismic Switch (> 0.1g) has occurred as verified by the Hope Creek Shift Manager AND Earthquake confirmed by ANY of the following: o Earthquake felt in plant by Control Room Operators

  • National Earthquake Information Center (NEIC) (Note 4) o Control Room indication of DEGRADED PERFORMANCE of safe shutdown systems Note 4: The NEIC can be contacted by calling (303) 273-8500. Select option #1 and inform the analyst you wish to confirm recent seismic activity in the vicinity of Salem/Hope Creek Generating Station. Provide the analyst with the following coordinates: 390 27' 46" (39.4650) north latitude, 750 32' 08" (75.5370) west longitude.

Basis: This EAL escalates from HU1.1 in that the occurrence of the event may have resulted in damage to plant structures or areas containing equipment necessary for a safe shutdown, or may have caused damage to the safety systems in those structures evidenced by Control Room indications of degraded system response or performance. The occurrence of damage and/or degraded system response is intended to discriminate against lesser events. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage. The significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation. I Salem Page 1 of 4 Rev. 0 (draft E) EAL#:AI

SGS ECG -EAL Technical Bases EP-SC-1'1 1-207 Escalation of this emergency classification level, if appropriate, would be based on System Malfunction EALs. Seismic events of this magnitude can result in a VDTAL AREA being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems.". ' The National Earthquake Information Center can confirm if an earthquake has occurred in the area of the plant. Explanation/Discussion/Definitions: Ground motion acceleration of 0.1g is the Operating.Basis Earthquake (OBE) for SGS. As defined in the EPRI-sponsored Guidelines for Nuclear Plant Response to- an Earthquake, dated October 1989, a "felt earthquake" is: An earthquake of sufficient intensity such that: (a) the vibratory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of Control Room operators on duty at the time, and (b)for plants with operable seismic instrumentation, the seismic switches of the plant are activated. The NEIC can confirm seismic activity in the vicinity of the SGS/HCGS site. Refer to Note 4 to contact the NEIC. Alternatively go to the USGS NEIC website: http ://earthquake.usgs.gov/eqcenter/ On the US map, click on 'New Jersey' and then click on earthquake indicator for information. The maps are updated within 5 min.. of a measured earthquake. Additional Earthquake information can be found on the internet at: o http://www.earthquake.usgs.gov o http://www.mgs.md.gov (click on "Live Earthquake Data online") o http://eaqhqu'ake.usgs~gov/regional/neic An approximate relationship between acceleration units in gravity-and magnitude reported per the Richter scale is as follows: An Acceleration of::.-: is approx. equal to-a Richter Scale MaQnitude of: 0.01g., 4.0 0.02g- . 4.5 0.1g 5.5 0.2g 6.5 Salem Page 2 of 4 Rev. 0 (draft E) EAL#: H I

SGS ECG - EAL Technical Bases EP-SC-1 11-207 Definitions: VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit o Insufficient system pressure from keep-fill pumps o Elevated area temperatures or radiation levels o Increased sump pump operation in areas in which the system is located PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. Salem Page 3 of 4 Rev. 0 (draft E) EAL#:HAI.i

SGS ECG - EAL Technical Bases EP-SC-111-207 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HAl Example EAL #1
2. UFSAR Table 7.7-3 Seismic Monitoring Instrumentation
3. SC.OP-AB.ZZ-0004(Q) Earthquake
4. Si.OP-AR.ZZ-0001(Q) OHA A-37 SEIS RCDR SYS ACT
5. UFSAR 2.1.1 Site Location
6. UFSAR 1.2.4 Seismology Salem Page 4 of 4 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting VITAL AREAS Mode Applicability: All EAL# & Classification Level: HA1.2 - ALERT EAL: Table H-1 Plant Structures Containing Safe Shutdown Systems or Components 0 Auxiliary Building 0 Service Water Intake Structure 0 Control Point Area 0 Inner/Outer Penetration Areas 0 Containment 0 Fuel Handling Building 0 Service Building 0 RWST, PWST, and AFWST Area Salem Page 1 of 4 Rev. 0 (draft E) EAL#: AIA 2

SGS ECG - EAL Technical Bases EP-SC-1 11-207 Basis: This EAL escalates from EAL HU1.2 in that the occurrence of the event has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by Control Room indications of degraded system response or performance. The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage. The significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation. Escalation of this emergency classification level, if alpr6priate, would be based on System Malfunction EALs. This EAL is based on a tornado touching down or high winds that have caused VISIBLE DAMAGE to structures containing functions or systems required for safe shutdown of the plant. Explanation/Discussion/Definitions: Average, as.used in the EAL threshold,. is intended to be the 15 minute rolling average as provided by SPDS and not the instantaneous wind speed. The design wind velocities are 108 mph (including a gust factor of approximately 1.3) at 30 feet above-ground. However' the Control Room wind-speed only provides a display up to 100 mph so the classification threshold has been capped at 95 mph to allow for onscale indication of wind speed. The manner in which the HCGS SPDS processes data from the meteorological instrumentation differs from the SGS SPDS; consequently, minor differences between HCGS and SGS readings may occur. The ALERT classification is a~ppropriate if relevant plant parameters indicate that the performance of safety systems has been degraded. No attempt should be made to fully inventory the actual magnitude of the-damage or quantify the degradation of safety system performance prior to declaration of an ALERT under this threshold. The declaration of an ALERT and the activation of the TSC provide the. Emergency Coordinator with the resources needed to perform detailed damage assessments. The National Weather Service can be contacted for further information about existing or projected Adverse Weather Conditions: o Phila/Mount Holly (609) 261.-.660,0. . o NWS Web site http://www.erh.noaa.gov/er/phi o Phila/Mount Holly (609) 261-6604 o Phila/Mount Holly (609) 261-6602 Salem Page 2 of 4 Rev. 0 (draft E) EAL#:HA] 2

SGS ECG - EAL Technical Bases EP-SC-1 11-207 Definitions: VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit o Insufficient system pressure from keep-fill pumps o Elevated area temperatures or radiation levels o Increased sump pump operation in areas in which the system is located PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, and paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included. Salem Page 3 of 4 Rev. 0 (draft E) EAL#: H1AI.2

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA1 Example EAL #2
2. UFSAR 3.3.1.1 Design wind Velocity and Loading
3. UFSAR 3.2 Severe Weather and Natural Disaster Guidelines
4. OP-AA-1 08-111-1001 Severe Weather and Natural Disaster Guidelines
5. NC.CH-SC.MET-1206(A) Meteorological Monitoring System Calibration and. Maintenance
6. SC.OP-AB.ZZ-0001(Q) Adverse Environmental Conditions
r Salem Page 4 of 4 Rev. 0 (draft E)

EAL#: HA1.2

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting VITAL AREAS Mode Applicability: All EAL# & Classification Level: HA1.3 - ALERT EAL: Turbine failure-generated PROJECTILES resulting in EITHER of the following: o VISIBLE DAMAGE to ANY Table H-I plant structures o Control Room indication of DEGRADED PERFORMANCE of safe shutdown systems Table H-1 Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Basis: This EAL escalates from EAL HU1.3 in that the occurrence of the event has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by Control Room indications of degraded system response or performance. The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual Salem Page 1 of 4 Rev. 0 (draft E) EAL#: HAII ,

SGS ECG - EAL Technical Bases EP-SC-1 11-207 magnitude of the damage. The significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation. Escalation of this emergency classification level, if appropriate, would be based on System Malfunction EALs. This EAL addresses the threat to safety related equipment imposed by PROJECTILES generated by main turbine rotating component failures. Therefore, this EAL is consistent with the definition of an ALERT in that the potential exists for actual or substantial potential degradation of the level of safety of the plant. Explanation/Discussion/Definitions: Definitions: VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability:' o Electrical faults on power s upplies o Normally closed breakers in tripped position o System annunciators activated o System warning lights !it. . o Insufficient system pressure from keep-fill pumps o Elevated area temperatures or radiation levels o Increased sump pump operation in. areas in which the system is located Salem Page 2 of 4 Rev. 0 (draft E) EAL#: Ai]AI .3

SGS ECG - EAL Technical Bases EP-SC-1 11-207 PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, and paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included. PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability or personnel safety. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HAI Example EAL #4
2. UFSAR 3.5.4 Turbine Missiles Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: HA o3

SGS ECG - EAL Technical Bases .. EP-SC-1 11-207 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#:HAIo3

SGS ECG - EAL Technical Bases EP-SC-1 11-207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting VITAL AREAS Mode Applicability: All EAL# & Classification Level: HA1.4 - ALERT EAL: Internal Flooding in ANY Table H-1 plant structure AND The Flooding is of a magnitude that results in EITHER of the following: o Indication of DEGRADED PERFORMANCE of a Safety System within a Table H-1 Structure. o An Industrial Safety Hazard (Electrical Shock, High Temp, etc.) resulting in access restrictions to operate or monitor Safety System equipment. Table H-I Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Basis: This EAL escalates from EAL HU1.4 in that the occurrence of the event has resulted in an electrical shock hazard precluding access to plant structures containing safe shutdown Salem Page 1 of 4 Rev. 0 (draft E) EAL#: HAI .o4

SGS ECG - EAL Technical Bases EP-SC-1 11-207 systems or components or damage to the safety systems or components in those structures as evidenced by Control Room indications of degraded system response or performance. The lack of access or occurrence of degraded system response is intended to discriminate against lesser events. The initial report should not be interpreted as mandating a lengthy assessment prior to. classification. No attempt is made in this EAL to assess the actual magnitude of any damage. The significance hee .is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this lack of access or performance degradation. Escalation of this emergency classification level, if appropriate, would be based on System Malfunction EALs. This EAL addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps. It is based on the DEGRADED PERFORMANCE of systems, or has created industrial safety hazards (e.g., electrical shock) that preclude necessary access to operate or monitor safety equipment. The inability to access, operate or monitor safety equipment represents an actual or substantial potential degradation of the level of safety of the plant. Flooding as used in this EAL describes a condition where water is entering the room faster than installed equipment is capable of removal, resulting in a rise of water level within the room. Classification of this.EAL. shoul~d. not be delayed while corrective actions are being taken to isolate the water source. . Explanation/Discussion/Definitions: Flooding is an event or condition in excess of the available sump pump handling capability (installed or temporary) that results in. a conditio.n where water is entering a room faster than it is being removed resulting in a rise in water level within the room. Classification should not be delayed while taking corrective actions to isolate the source of the flooding. This EAL addresses the effects of: flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps where flooding is.occurring in areas that affect safety related equipment. This EAL is based on the degraded performance of systems, or has created industrial safetylhazards (electrical shock) that preclude necessary access to operate or monitor safety equipment. The ihability to'.adcess, operate.ormonitor safety equipment represents an actual or substantial potential degradation of the level of safety of the plant meeting the definition of an ALERT. In those cases where it is believed that DEGRADED PERFORMANCE due to flooding may have caused damage t6 a Safety System, an ALERT declaration is warranted since the full extent of the damage need not be known:-A Safety System is defined as any system required to maintain safe operation or to establish or maintain Cold Shutdown. If the flooding has reached the level(s) specified in OP-AB.ZZ-0002, FLOODING, then the flooding-is severe, is in excess of sump handling capability and has degraded the performance of safety related e-quipient. Conseq'uently, if the flo6ding has reached the levels specified in Salem Page 2 of 4 Rev. 0 (draft E) EAL#: AIA 4

SGS ECG - EAL Technical Bases EP-SC-1 11-207 OP-AB.ZZ-0002, Flooding, then classification under this EAL is warranted. The source of the flooding and the status of the sump pumps are not factors in evaluating this EAL. For areas that do not have a Flooding level specified in OP-AB.ZZ-0002, SM judgment should be used. Flooding is determined in these areas by visual report from staff or by confirmation of sump alarms. S1(S2).OP-AB.ZZ-0002 (Q) directs the operators to determine the exact location and severity of Flooding. Attachments in this procedure delineate the affected plant areas, potential source(s) of water, affected vital equipment, flood rate and time to submerge vital equipment. Definitions: VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit o Insufficient system pressure from keep-fill pumps o Elevated area temperatures or radiation levels o Increased sump pump operation in areas in which the system is located Salem Page 3 of 4 Rev. 0 (draft E) EAL#: A* 4

SGS ECG - EAL Technical Bases EP-SC-1 11-207 PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part.of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG- Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA1 Example EAL #3
2. UFSAR 3.2 Classification of Structures, Components and Systems'
3. SI(S2).OP-AB.ZZ-0002 (Q) Flooding Salem Page 4 of 4 Rev. 0 (draft E)

EAL#: ]AIA

SGS ECG - EAL Technical Bases EP-SC-1 11 -207 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting VITAL AREAS Mode Applicability: All EAL# & Classification Level: HA1.6 - ALERT EAL: Vehicle Crash or PROJECTILE Impact with or within ANY Table H-I Structure AND The Vehicle Crash or PROJECTILE Impact results in EITHER of the following: o Control Room indication of DEGRADED PERFORMANCE of a Safety System within Table H-I Structure o VISIBLE DAMAGE to ANY of the plant structures in Table H-1 Table H-I Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Basis: The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial report should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess Salem Page 1 of 4 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-207 the actual magnitude of the damage. The significance here is not that a particular system or structure incurred damage, but rather that the event was of sufficient magnitude to cause either VISIBLE DAMAGE to the safety systems in Table H-1 structures or Control Room indications of degraded system performance. Escalation of this emergency classification level, if appropriate, would be based on EALs in Category S, System Malfunctions. This EAL addresses vehicle crashes or PROJECTILE impacts within the PROTECTED AREA that results in VISIBLE DAMAGE to VITAL AREAS or indication of damage to safety structures, systems, or components containing functions and systems required for safe shutdown-of the plant: Explanation/Discussion/Definitions: The primary concern in this EAL is the magnitude of the vehicle crashes/ PROJECTILE impacts. A detailed assessment of'systemr damage is not required prior to 'classification. Vehicle Crash includes AIRCRAFT, Helicopters, Ships, Barges, Trucks, Autos, or any other vehicle types of sufficient momentum to' potentially damage the structure. Minorcontacts (not crashes) by onsite vehicles such as trucks, autos, forklifts, etc., are excluded from classification under this EAL. PROJECTILE impact includes flying objects from either offsite or onsite, rotating equipment or turbine failure causing-turbine-casing penetration. A Safety System is any system required to maintain safe operation or to establish or maintain cold shutdown. In those cases where it is believed that the vehicle crash/ PROJECTILE impact may have caused VISIBLE DAMAGE to a Safety System, an ALERT declaration is warranted since the full. extent of the damage may not be known. The turbine building is not a safety structure and would not be considered for..this EAL. No lengthy or time-consuming assessment of damage is required prior to classification. In this EAL, no attempt is made to quantify the magnitude of the damage to any safety system but instead an attempt is made to identify any damage in order to quantify the magnitude and extent of the vehicle crashes/PROJECTILE impact.' In short, if the vehicle crash/ PROJECTILE impact is big enough that it has damaged a Safety System/Safety Structure or cause Safety System DEGRADED PERFORMANCE, then the vehicle crash/ PROJECTILE impact is big enough to justify an ALERT declaration. Any security aspects or suspected. HOSTILE ACTIONS that. involve vehicles or PROJECTILE impact should be considered under EALs in Subcategory H.4. This event will be escalated based on further damage to plant safety systems, fission product barriers, or abnormal radiation releases. The Emergency Coordinator may use discretion and escalate the classification to a SITE-AREA EMERGENCY based on the nature of the damage. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: =A1,6

SGS ECG - EAL Technical Bases EP-SC-1 11-207 Definitions: VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability, or personnel safety. DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit o Insufficient system pressure from keep-fill pumps o Elevated area temperatures or radiation levels o Increased sump pump operation in areas in which the system is located PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. Salem Page 3 of 4 Rev. 0 (draft E) EAL#: HAI °6

SGS ECG - EAL Technical Bases EPý-SC-l 11-207 VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example damage includes: deformation due to heat or impact,, denting, penetration, rupture, cracking-, and paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included. AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the Use' of violent force to destroy'equipment, take HOSTAGES, and/or intimidate PSEG to achieve an 'end. This includes attack by air, land, or Water'using' guns;' explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other gcts that satisfy the overall intent may be included. HOSTILE'ACTION should not be construded toinclude acts of civilrdisobedience or felonious acts that are n'ot part of a concerted attack on Salem or Hb05e Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OCA). '- HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA1 Example EAL #5
2. UFSAR 3.2 Classification of Structures, Components and Systems Salem Page 4 of 4 Rev. 0 (draft E)

EAL#: HA .

SGS ECG - EAL Technical Bases EP-SC-1 11 -208 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 2 - Fire or Explosion Initiating Condition: FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HU2.1 - UNUSUAL EVENT EAL: FIRE NOT extinguished within 15 minutes of EITHER of the following: o Control Room notification/report of a FIRE o Verified FIRE detection system alarm/actuation AND FIRE is located in the Turbine Building or ANY Table H-I plant structure (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Table H-I Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building 

                               " RWST, PWST, and AFWST Area Salem                                         Page 1 of 4                        Rev. 0 (draft E)

EAL#: HU2.1

SGS ECG - EAL Technical Bases EP-SC-1 11-208 Basis: This EAL addresses the magnitude and extent of FIRES that may be potentially significant precursors of damage to safety systems. It addresses the FIRE, and not the degradation in performance of affected systems that may result. The 15 minute time period begins with a credible notification/report that a FIRE is occurring, or upon verification that a FIRE detection system alarm/actuation is due to a FIRE.

a. A credible notification/report to the Control room would be a communications from a member of the plant staff (in-house or contractor) that identifies the observation of a FIRE in a specific location.

NOTE: In this case, the 15 minute clock to assess the EAL and to extinguish the FIRE runs concurrently and starts upon Control Room receipt of the FIRE"notification/report.

b. Verification that a FIRE detection system alarm/actuation is due to a FIRE (not a spurious/false alarm) includes either one of the following:
1. Control Room (or other nearby site-specific location) receipt of related independent alarm(s) (FIRE, temperature, deluge, FIRE pump start, etc.)

NOTE: In this Case, the 15 minute clock to asses's the EAL and to extinguish the' FIRE runs concurrently and starts upon receipt of the independent alarm(s) related to the FIRE,.

2. On/Near-scene visual confirmation if only a single FIRE/smoke detector has alarmed.

NOTE: In this case, the 15 minute clock to assess the EAL and to extinguish the FIRE runs concurrently ahd starts uponan on/near-sceneconfirmation of a FIRE related to the single FIRE/smoke detector that had alarmed. The intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste'paper basket). The Turbine Building and Table H-1 list is limited and applies to buildings and areas in actual contact with or immediately adjacent toVGTAL AREAS or other significant buildings or areas. The intent of this EAL is not to include buildings (i.e., warehouses) or areas that are not in actual contact with or immediately adjacent to VITAL AREAS. This excludes FIRES within administration buildings, waste-basket FIRES, and other. small FIRES of no safety consequence. Immediately adjacent implies that the area immediately adjacent contains or may contain equipment or cabling that could impact equipment located in VITAL AREAS or the FIRE could damage biquipmehlt inside VITAL AREAS or that precludes access to VITAL AREAS. Salem Page 2 of 4 Rev. 0 (draft E) EAL#:Hf=U2ii1

SGS ECG - EAL Technical Bases EP-SC-1 11-208 Escalation of this emergency classification level, if appropriate, would be based on EAL HA2.1. Explanation/Discussion/Definitions: The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I. Definitions: PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU2 Example EAL #1
2. UFSAR 3.2 Classification of Structures, Components and Systems Salem Page 3 of 4 Rev. 0 (draft E)

EAL#:HU=2 0Il

SGS ECG - EAL Technical Bases EP-SC-1 11-208 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: jUI2

SGS ECG - EAL Technical Bases EP-SC-1 11-208 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 2 - Fire or Explosion Initiating Condition: FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HU2.2 - UNUSUAL EVENT EAL: EXPLOSION within the PROTECTED AREA Basis: This EAL addresses the magnitude and extent of EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the EXPLOSION, and not the degradation in performance of affected systems that may result. This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA. No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration. The Emergency Coordinator also needs to consider any security aspects of the EXPLOSION, if applicable. Escalation of this emergency classification level, if appropriate, would be based on EAL HA2.2. Explanation/Discussion/Definitions: If the EXPLOSION is determined to be hostile in nature, the event is classified under EAL HS4.1. Definitions: PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:HU2,2

SGS ECG - EAL Technical Bases EP-SC-1 11-208 OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. FIRE: Combustion. characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU2 Example EAL #2 Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: HU2°2

SGS ECG - EAL Technical Bases EP-SC-1 11-208 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 2 - Fire or Explosion Initiating Condition: FIRE or EXPLOSION in a VITAL AREA affecting the operability of plant safety systems required to establish or maintain safe shutdown Mode Applicability: All EAL# & Classification Level: HA2.1 - ALERT EAL: FIRE in ANY Table H-I plant structure affecting the operability of plant safety systems required to establish or maintain safe shutdown AND _ 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Table H-1 Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure 

                                , Control Point Area
  • Inner/Outer Penetration Areas o Containment
  • Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Salem Page 1 of 4 Rev. 0 (draft E)

EAL#: HA2°I

SGS ECG - EAL Technical Bases EP-SC-1 11-208 Basis: The significance here is that the FIRE was large enough to cause damage to these systems. The declaration of an ALERT and the activation of the Technical Support Center will provide the Emergency Coordinator with the resources needed to perform detailed damage assessments. Escalation of this emergency classification level, if appropriate, will be based on EALs in Category S, System Malfunctions, Category F, Fission Product Barrier Degradation, or Category R, Abnormal Rad Levels / Rad Effluent. Explanation/Discussion/Definitions: The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I. Definitions: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES.. Observation of flame is preferred but is NOT. required if large quantities of smoke and heat are observed. EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. ViTAL AREAS: Typicallyany site' specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiatibn-PROTECTED AREA (PA): A. security controlled area within the OWNER CONTROLLED AREA (OCA)that is enclosed by the security perimete'r fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of th e Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. Salem Page 2 of 4 Rev. 0 (draft E) EAL#:HA21=Aif

SGS ECG - EAL Technical Bases EP-SC-1 11 -208 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA2 Example EAL #1
2. UFSAR 3.2 Classification of Structures, Components and Systems Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: HA2oI1

SGS ECG - EAL Technical Bases EP-SC-1 11-208 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: HA2.i1

SGS ECG - EAL Technical Bases EP-SC-1 11-208 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 2 - Fire or Explosion Initiating Condition: FIRE or EXPLOSION in a VITAL AREA affecting the operability of plant safety systems required to establish or maintain safe shutdown Mode Applicability: All EAL# & Classification Level: HA2.2 - ALERT EAL: EXPLOSION in ANY Table H-1 plant structure affecting the operability of plant safety systems required to establish or maintain safe shutdown Table Hi1 Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Basis: The significance here is that the EXPLOSION was large enough to cause damage to these systems. The declaration of an ALERT and the activation of the Technical Support Center will provide the Emergency Coordinator with the resources needed to perform detailed damage assessments. The Emergency Coordinator also needs to consider any security aspects of the EXPLOSION. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: HA2o2

SGS ECG - EAL Technical Bases EP-SC-1 11-208 Escalation of this emergency classification level, if appropriate, will be based on EALs in Category S, System Malfunctions, Category F, Fission Product Barrier Degradation, or Category R, Abnormal Rad Levels / Rad Effluent. Explanation/Discussion/Definitions: If the EXPLOSION is determined to be hostile in nature, the event is classified under EAL HS4.1. The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I.- Definitions: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipme.nt.do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are 

      -obs&rved.

EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. VITAL AREAS: Typically any site specific-areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. PROTECTED AREA (PA):A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosedby the security perimeter fence and monitored by intrusion detection systems.. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as piart of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA2 Example EAL #1
2. UFSAR 3.2 Classification of Structures, Components and Systems Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:HA2o2

SGS ECG - EAL Technical Bases EP-SC-1 11-209 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 3 - Hazardous Gas Initiating Condition: Release of toxic, corrosive, asphyxiant or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS Mode Applicability: All EAL# & Classification Level: HU3.1 - UNUSUAL EVENT EAL: Release of toxic, corrosive, asphyxiant or flammable gas in amounts (excluding small or incidental releases) that have or could adversely affect NORMAL PLANT OPERATIONS Basis: This EAL is based on the release of toxic, corrosive, asphyxiant or flammable gases of sufficient quantity to affect normal plant operations. The fact that SCBA or other respiratory protection may be worn does not eliminate the need to declare the event. This EAL is not intended to require significant assessment or quantification. It assumes an uncontrolled process that has the potential to affect NORMAL PLANT OPERATIONS. This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation. An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death. Escalation of this emergency classification level, if appropriate, would be based on EAL HA3.1. Explanation/Discussion/Definitions: The release may have originated within the Site Boundary, or it may have originated offsite and subsequently drifted onto the Site Boundary. Offsite events (e.g., tanker truck accident releasing toxic gases, etc.) resulting in the plant being within the evacuation area should also be considered in this EAL because of the adverse affect on NORMAL PLANT OPERATIONS. Salem Page 1 of 4 Rev. 0 (draft E) EAL#:

  • U 3o J

SGS ECG - EAL Technical Bases EP-SC-1 11 -209 Should the release affect plant VITAL AREAS, escalation to an ALERT would be based on EAL HA3.1. Should an EXPLOSION or FIRE occur due to flammable gas within an affected plant area, an ALERT may be appropriate based on EAL HA2.1 or EAL HA2.2. A Toxic Gas is considered to be any substance that is dangerous to life or limb by reason of inhalation or skin contact' A Flammable Gas is considered to be any substance that can result in an ignition, sustained burn or detonation. Carbon dioxide (CO 2 ) is an asphyxiant'gas. A 20 lb C02 extinguisher discharge will not create a hazardous atmosphere unless the room volume is less than 2500 cubic feet. A Corrosive Gas is a highiy reactive substance that causes obvious damage to living tissue. Corrosivesact either directly, by chemically destroying the part or indirectly by causing inflammation. Acids and bases are common corrosive materials. Corrosives such-as these are also sometimes referred to as caustics. This EAL should not be construed to include confined spaces that must be ventilated prior to entry or situations involving the fire department personnel who are using respiratory equipment during the performance of their duties unless it also affects personnel not involved with the fire department activates. In addition, those situations that require personnel to wear respiratory protection equipment as the result of airborne contamination as required by Radiation Protection personnel do not meet the intent of this EAL.. Definitions: NORMAL PLANT OPERATIONS: Activities at the plant site associated with routine testing, maintenance, or equipment operations, in accordance with normal operating or administrative procedures. Entry into abnormal or emergency operating procedures, or deviation from normal security or radiological controls posture, is a departure from NORMAL PLANT OPERATIONS. VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains. equipment, systems, components, or material;.the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security: Center. OWNERp CONTROLLED AREA'(OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergericy classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. Salem Page 2 of 4 Rev. 0 (draft E) EAL#:HU3.1

SGS ECG - EAL Technical Bases EP-SC-1 11-209 FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU3 Example EAL #1
2. OE25324 Alert Declared Due to C02 Fire Extinguisher Discharge Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: H UJ3oi

SGS ECG - EAL Technical Bases EP-SC-1 11-209 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#:HU3.]

SGS ECG - EAL Technical Bases EP-SC-1 11-209 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 3 - Hazardous Gas Initiating Condition: Release of toxic, corrosive, asphyxiant or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS Mode Applicability: All EAL# & Classification Level: HU3.2 - UNUSUAL EVENT (Common Site) EAL: Notification by Local, County, or State Officials for evacuation or sheltering of site personnel based on an off-site gas release event that includes toxic, corrosive, asphyxiant, or flammable gas Basis: The fact that SCBA or other respiratory protection may be worn does not eliminate the need to declare the event. An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death. Escalation of this emergency classification level, if appropriate, would be based on EAL HA3.1. Explanation/Discussion/Definitions: This EAL is based on the existence of an uncontrolled release originating offsite and local, county or state officials have reported the need for evacuation or sheltering of site personnel. State and local officials may determine the evacuation area for an offsite spill or release by using "The Emergency Response Guidebook (ERG2008)" developed by the US Department of Transportation. Should the release affect plant VITAL AREAS, escalation to an ALERT would be based on EAL HA3.1. Should an EXPLOSION or FIRE occur due to flammable gas within an affected plant area, an ALERT may be appropriate based on EAL HA2.1. A Toxic Gas is considered to be any substance that is dangerous to life or limb by reason of inhalation or skin contact. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: HU3o2

SGS ECG - EAL:Technical Bases EP-SC-1 11-209 A Flammable Gas is considered to be any substance that can result in an ignition, sustained burn or detonation. Carbon dioxide (C02) is an asphyxiant gas. A20 lb. C02 fire extinguisher discharge will not create a hazardous atmosphere unless the room volume is less than 2500 cu.ft. A Corrosive Gas is'a highly reactive substance that causes obvious damage to living tissue. Corrosives act either directly, by chemically destroying the part or indirectly by causing inflammation. Acids and bases are common corrosive materials. Corrosives such as these are also sometimes referred to as caustics. Definitions: NORMAL PLANT OPERATIONS: Activities at the plant site associated with routine testing, maintenance, or equipment operations, in accordance with normal operating or administrative procedures. Entry into abnormal or emergency operating procedures, or deviation from normal security or radiological controls posture, is a departure from NORMAL PLANT OPERATIONS. VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, Or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (0CA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the. Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by-. PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA... FIRE: Combust.ion, ch.aracterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. . EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: *] 2

SGS ECG - EAL Technical Bases EP-SC-1 11-209 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU3 Example EAL #2
2. The Emergency Response Guide (ERG2008)
3. OE25354 Alert Due to C02 Fire Extinguisher Discharge Salem Page 3 of 4 Rev. 0 (draft E)

EAL#:HU3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-209 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: H=UT3 .2

SGS ECG - EAL Technical Bases EP-SC-1 11-209 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 3 - Hazardous Gas Initiating Condition: Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shut down the reactor Mode Applicability: All EAL# & Classification Level: HA3.1 - ALERT EAL: Access to ANY Table H-I plant structure is prohibited due to toxic, corrosive, asphyxiant, or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shut down the reactor (Note 5) Note 5: If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should NOT be declared as it will have NO adverse impact on the ability of the plant to safely operate or safely shut down beyond that already allowed by Technical Specifications at the time of the event. Table H-1 Plant Structures Containing Safe Shutdown Systems or Components o Auxiliary Building o Service Water Intake Structure o Control Point Area o Inner/Outer Penetration Areas o Containment o Fuel Handling Building o Service Building o RWST, PWST, and AFWST Area Basis: Gases in a VITAL AREA can affect the ability to safely operate or safely shut down the reactor. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: HA3.I

SGS ECG - EAL Technical Bases EP-SC-1 11-209 The fact that SCBA or other respiratory protection may be worn does not eliminate the need to declare the event. Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases. This could be based Upon documented analysis, indication of personal ill effects from exposure, or operating experience with the hazards. An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed' environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.- An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnell injury. Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene - used. in weldihg). This EAL assumes concentrations of flammable gasses which can ignite/support combustion. Escalation of this emergency classification level" if appropriate, will be based on EALs in Category S, System. Malfunctions, Category F, Fission Product Barrier Degradation, or Category R,;Abnormal:Rad Levels / Rad Effluent. Explanation/Discussion/Definitions:-..... This EAL is based on gases that have entered a plant structure in concentrations that could be unsafe for plant personnel and, therefore,-preclude access to'equipment necessary for the safe operation or safe shutdown of the plant. The Table H-i Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I. A Toxic Gas is considered to be any substance that is dangerous to life or limb by reason of inhalation or skin contact. A Flammable Gas is considered to be any substance that can result in an ignition, sustained burn or detonation. Carbon dioxide (C0 2 ) is an asphyxiant gas. A 20 lb CO 2 extinguisher discharge will not create a hazardous atmosphere unless the room volume is less than 2500 cubic feet. A Corrosive Gas is a highly reactive substance thatcauses obvious damage to living tissue. Corrosives act either directly, by chemically destroying the part or indirectly by causing inflammation. Acids and bases are common corrosive materials. Corrosives such as these are also sometimes referred to as caustics. Salem Page 2 of 4 Rev. 0 (draft E) EAL#:HA3.1

SGS ECG - EAL Technical Bases EP-SC-1 11-209 This EAL should not be construed to include confined spaces that must be ventilated prior to entry or situations involving the fire department personnel who are using respiratory equipment during the performance of their duties unless it also affects personnel not involved with the fire department activates. In addition, those situations that require personnel to wear respiratory protection equipment as the result of airborne contamination as required by Radiation Protection personnel do not meet the intent of this EAL. Definitions: VITAL AREA: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA3 Example EAL #1
2. UFSAR 3.2 Classification of Structures, Components and Systems
3. OE25324 Alert Declared Due to C02 Fire Extinguisher Discharge Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: HA3o 1A

SGS ECG - EAL-Technical Bases EP-SC-1 11-209 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: HA3.1

SGS ECG - EAL Technical Bases EP-SC-11 11-210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant Mode Applicability: All EAL# & Classification Level: HU4.1 - UNUSUAL EVENT (Common Site) EAL: A SECURITY CONDITION that does NOT involve a HOSTILE ACTION as reported by the Security Operations Supervisor or designee (Note 8) OR Receipt of a CREDIBLE/ACTUAL THREAT to Salem or Hope Creek station - (determined by security in accordance with SY-AA-101-132, "Threat Assessment") (Note 8) OR A VALIDATED notification from NRC providing information of a Salem/Hope Creek AIRCRAFT threat (Note 8) NOTE 8: Shift Manager (SM) should implement the Prompt Actions of NC.EP-EP.ZZ-0102, EC Response, Attachment 10, prior to classification of a security emergency. Key Information to obtain from Security Supervision upon SM notification of a security event: 

              "   Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION o   If a HOSTILE ACTION, is location the OCA or PA?

Basis: Security events which do not represent a potential degradation in the level of safety of the plant are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under EAL HA4.1, EAL HS4.1 and EAL HG4.1. Salem Page 1 of 6 Rev. 0 (draft E) EAL#: H U4.1

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 A higher initial classification could be made based upon the nature and timing of the security threat and potential consequences. The Emergency Coordinator shall consider upgrading the emergency response status and emergency classification level in accordance with the Salem - Hope Creek Security Contingency Plan. 1 st Condition (SECURITY CONDITION) Reference is made to the specific security shift supervision (Security Operations Supervisor or designee) because these individuals are the designated personnel on-site qualified and trained to confirm that a security event is occurring or has occurred. Training on security event classification confirmation is closely controlled due to the strict secrecy controls placed on the Salem - Hope Creek Security Contingency Plan. This threshold is based on the Salem - Hope Creek Security Contingency Plan. The Salem - Hope Creek Security Contingency Plan is based on guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Security Contingency Plan and ISFSI Program. 2 nd Condition (CREDIBLE I ACTUAL THREAT) This threshold is included to ensure that appropriate notifications for the security threat are made in a timely manner. This includes information of a credible threat. Only the site to which the specific threat is made needs declare the Notification of an UNUSUAL EVENT. The determination of CREDIBLE is made through use of information found in Threat Assessment, SY-AA-101-132. 3 rd Condition (AIRCRAFT Threat) The intent of this part of the EAL is to ensure that notifications for the AIRCRAFT threat are made in a timely manner and that offsite response organization (OROs) and plant personnel are at a state of heightened awareness regarding the credible threat. It is not the intent of this EAL to replace existing non-hostile related EALs involving AIRCRAFT. This EAL is met when a plant (site) receives information regarding an AIRCRAFT threat from NRC. Validation is performed by calling the NRC or by other approved methods of authentication. Only the site to which the specific threat is made need declare the UNUSUAL EVENT. Salem Page 2 of 6 Rev. 0 (draft E) EAL#: HU4o]

SGS ECG - EAL Technical Bases EP-SC-1 11-210 The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an AIRLINER (AIRLINER is meant to be a large AIRCRAFT with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC. Escalation to ALERT emergency classification level would be via EAL HA4.1 and would be appropriate if the threat involves an AIRLINER within 30 minutes of the plant or a HOSTILE ACTION in the OCA or PA. Explanation/Discussion/Definitions: If the security events do not meet the threshold for an UNUSUAL EVENT classification, they may result in the need to make a non-emergency report per RAL Section 11.7.1 .a, One Hour Non-Emergency Safeguards Event (10 CFR 73.71) as determined by Security per SY-AA-1002, "Safeguards Event Report." Security will be focused on actions to mitigate the security event and will provide the SM with key information as the event progresses. Communications between the SMs and the Security Team Leader should be accurate, concise, and focused on EAL criteria and protection of key target sets. As Security and Operations terminology sometimes differ, clarifying questions should be asked to ensure accurate information exchange. 1st Condition (SECURITY CONDITION) Page 6 of this EAL Basis is a "Security Contingency Event Summary Table" that indicates which Security Contingency Events could result in Security Supervision determining that a SECURITY CONDITION exists and therefore an UNUSUAL EVENT classification should be made OR, could result in Security Supervision determining that a HOSTILE ACTION is or has occurred and therefore classification at the ALERT or higher level should be made based on the location (OCA or PA) of the HOSTILE ACTION. 2 nd Condition (CREDIBLE / ACTUAL THREAT) This threshold is included to ensure that threat information from any source which is assessed by security supervision as being a "CREDIBLE/ACTUAL THREAT" is classified as an UNUSUAL EVENT. Only the site to which the specific threat is made needs to declare the UNUSUAL EVENT. For Security Events, Salem and Hope Creek is considered a single site, therefore a "CREDIBLE/ACTUAL THREAT" to either Salem or Hope Creek would affect the entire site and a "Common Site" UE declaration would be made. Timely classification will ensure that Offsite Response Organizations and plant personnel are notified in a timely manner resulting in a state of heightened awareness. Threats are evaluated by security per Threat Assessment, SY-AA-1 01-132. Security threats that do not meet the definition of a "CREDIBLE/ACTUAL THREAT" should be dispositioned lAW Threat Assessment, SY-AA-101-132. Salem Page 3 of 6 Rev. 0 (draft E) EAL#: [HU4°1

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 3 rd Condition (AIRCRAFT Threat) AIRCRAFT threat calls from the NRC should be VALIDATED by use of NRC authentication code or a return call to the NRC Headquarter Operations Center. For security events, Salem and Hope Creek is considered a single site, therefore, a "VALIDATED AIRCRAFT THREAT" to either Salem or Hope Creek would affect the entire site and a "Common Site" UE declaration would be made. Definitions: SECURITY CONDITION: Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION. VALIDATED: AIRCRAFT threat call from the NRC that is confirmed to be authentic. Calls from the NRC are VALIDATED by use of the NRC provided authentication code or by making a return call to the NRC Headquarter Operations Center and confirming threat information with the NRC Operation Officer. AIRCRAFT threat calls from other agencies, NORAD, FAA, or FBI should be VALIDATED by calling the NRC Operations Officer. AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. A large AIRCRAFT is referred to as an AIRLINER. AIRLINER/LARGE AIRCRAFT: Any size or type of AIRCRAFT with the potential for causing significant damage to the plant (refer to the Security Contingency Plan for a more detailed definition). CREDIBLE / ACTUAL THREAT: Is a threat which poses a likely and serious danger to the safe operation of the facility or to site personnel and public safety. HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OCA). Salem Page 4 of 6 Rev. 0 (draft E) EAL#: H U 4.1

SGS ECG - EAL Technical Bases EP-SC-1 11-210 OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, the area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security center. PROJECTILE: An object that impacts Salem/Hope Creek that could cause concern for continued operability, reliability, or personnel safety. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU4 Example EAL #1, #2, #3
2. Salem - Hope Creek Security Contingency Plan
3. SY-AA-101-132 Threat Assessment
4. SC.OP-AB.CR-0004(Q) - Security Event
5. SC.OP-AB.CR-0005(Q) - Airborne Threat Salem Page 5 of 6 Rev. 0 (draft E)

EAL#:HU4o1

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 Security Contingency Event Summary Table Event Could Event Could Result in Result in Contingency Determination Determination Event of a of a Number SECURITY HOSTILE CONDITION ACTION (UE ONLY) (ALERT or Higher) Yes / No Yes / No 

                   # 1               Yes              Yes
                   #2                Yes              Yes
                   # 3               Yes              No
                   #4                 No              Yes
                   #5                Yes              Yes
                   #6                 No              No
                   #7                 No              No
                   #8                Yes              Yes
                   #9                Yes              Yes
                   #10               Yes              Yes
                   # 11              Yes              No
                   # 12              Yes              No
                   # 13              Yes              No
                   # 14              Yes              No
                   # 15              Yes              No
                   # 16              Yes              Yes
                   # 17              Yes              Yes
                   # 18              No               Yes
                   # 19             Yes               Yes
                   # 20             Yes               No Salem                               Page 6 of 6                     Rev. 0 (draft E)

EAL#: H] U 4. 1

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat Mode Applicability: All EAL# & Classification Level: HA4.1 - ALERT EAL: A HOSTILE ACTION is occurring or has occurred within the OCA as reported by the Security Operations Supervisor or designee (Note 8) OR A VALIDATED notification from NRC of a AIRLINER attack threat < 30 minutes away from Salem/Hope Creek (Note 8) NOTE 8: Shift Manager (SM) should implement the Prompt Actions of NC.EP-EP.ZZ-0102, EC Response, Attachment 10, prior to classification of a security emergency. Key Information to obtain from Security Supervision upon SM notification of a security event: 

               "    Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION o    If a HOSTILE ACTION, is location the OCA or PA?

Basis: This EAL addresses the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. They are not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements. The fact that the site is under serious attack or is an identified attack target with minimal time available for further preparation or additional assistance to arrive requires a heightened state of readiness and implementation of protective measures that can be effective (such as on-site evacuation, dispersal or sheltering). Salem Page 1 of 6 Rev. 0 (draft E) EAL#: HfA4o]

SGS ECG - EAL Technical Bases EP-SC-1 11-210 1 st Condition (OCA HOSTILE ACTION) This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION within or directed towards the OWNER CONTROLLED AREA (OCA). It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small AIRCRAFT impact, hunters, or physical disputes between employees within the OCA. Those events are adequately addressed by other EALs or RALs Note that this EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. If not previously notified by the NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, although not certain, that notification by an appropriate Federal agency would follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. However, the declaration should not be unduly delayed awaiting Federal notification. 2 nd Condition (AIRLINER Threat) This EAL addresses the immediacy of an expected threat (AIRLINER) arrival or impact on the site within a relatively short time (< 30 minutes). The intent of this EAL is to ensure that notifications for the AIRLINER attack threat are made in a timely manner and that OROs and plant personnel are at a state of heightened awareness regarding the credible threat. AIRLINER is meant to be a large AIRCRAFT with the potential for causing significant damage to the site. This EAL is met when a plant receives information regarding an AIRLINER attack threat from NRC and the AIRLINER is within 30 minutes of the plant. Only the site to which the specific threat is made need declare the ALERT. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an AIRLINER (AIRLINER is meant to be a large AIRCRAFT with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC. Salem Page 2 of 6 Rev. 0 (draft E) EAL#: M4.1

SGS ECG - EAL Technical Bases EP-SC-1 11-210 Explanation/Discussion/Definitions: This event will be escalated to a SITE AREA EMERGENCY based upon HOSTILE ACTION affecting the PROTECTED AREA (PA). Also, if Hope Creek declares an SAE due to their PA being affected by the security event, Salem will escalate to SAE to match them. 1 st Condition (OCA HOSTILE ACTION) Reference is made to the specific security shift supervision (Security Operations Supervisor or designee) because these individuals are the designated personnel on-site qualified and trained to confirm that a HOSTILE ACTION is occurring or has occurred. This EAL condition is not premised solely on adverse health effects caused by a radiological release. Rather the issue is the immediate need for assistance due to the nature of the event and the potential for significant and indeterminate damage. Although nuclear plant security officers are well trained and prepared to protect against HOSTILE ACTION, it is appropriate for Offsite Response Organizations (OROs) to be notified and encouraged to begin activation to be better prepared should it be necessary to consider further actions. Page 6 of this EAL Basis is a "Security Contingency Event Summary Table" that indicates which Security Contingency Events could result in Security Supervision determining that a HOSTILE ACTION is or has occurred and therefore classification at the ALERT or higher level should be made based on the location (OCA or PA) of the HOSTILE ACTION. Security events that do not involve a HOSTILE ACTION may result in Security Supervision determining that a SECURITY CONDIITION exists and therefore an UNUSUAL EVENT classification should be made per EAL HU4.1. 2 nd Condition (AIRLINER Threat) The fact that the site is an identified attack candidate with minimal time available for further preparation requires a heightened state of readiness and implementation of protective measures that can be effective (onsite evacuation, dispersal, or sheltering) before arrival or impact. This EAL is met when a plant receives VALIDATED information regarding an AIRLINER attack threat from NRC and the AIRLINER is less than 30 minutes away from the site. Only the site (Salem and Hope Creek is considered a single site for Security event classifications) to which the specific threat is made needs declare the ALERT. AIRLINER threat calls from the NRC should be VALIDATED by use of NRC authentication code or a return call to the NRC Headquarter Operations Center. Salem Page 3 of 6 Rev. 0 (draft E) EAL#:H~lA4jj1

SGS ECG - EAL Technical Bases EP-SC-1 11-210 Definitions: HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA). OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. A large AIRCRAFT is referred to as an AiRLINER. AIRLINER/LARGE AIRCRAFT: Any size or type of AIRCRAFT with the potential for causing significant damage to the plant (refer to the Security Contingency Plan for a more detailed definition). SECURITY CONDITION: Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION. PROJECTILE: An object directed toward Salem/Hope Creek that could cause concern for its continued operability, reliability, or personnel safety. Salem Page 4 of 6 Rev. 0 (draft E) EAL#:[A4o]

SGS ECG - EAL Technical Bases EP-SC-1 11-210 VALIDATED: AIRCRAFT threat call from the NRC that is confirmed to be authentic. Calls from the NRC are VALIDATED by use of the NRC provided authentication code or by making a return call to the NRC Headquarter Operations Center and confirming threat information with the NRC Operation Officer. AIRCRAFT threat calls from other agencies, NORAD, FAA, or FBI should be VALIDATED by calling the NRC Operations Officer. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA4 Example EAL #1, #2
2. Salem - Hope Creek Security Contingency Plan
3. SC.OP-AB.CR-0004(Q) - Security Event
4. SC.OP-AB.CR-0005(Q) - Airborne Threat Salem Page 5 of 6 Rev. 0 (draft E)

EAL#: HA4°]

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 Security Contingency Event Summary Table Event Could Event Could Result in Result in Contingency Determination Determination Event of a of a Number SECURITY HOSTILE CONDITION ACTION (UE ONLY) (ALERT or Higher) Yes / No Yes / No 

                   # 1               Yes              Yes
                   # 2               Yes              Yes
                   # 3               Yes               No
                   # 4                No              Yes
                   #5                Yes              Yes
                   #6                 No               No
                   #7                 No               No
                   #8                Yes              Yes
                   #9                Yes              Yes
                   #10               Yes              Yes
                   # 11              Yes               No
                   # 12              Yes               No
                   # 13              Yes               No
                   # 14              Yes               No
                   # 15              Yes               No
                   # 16              Yes              Yes
                   #17               Yes              Yes
                   # 18               No              Yes
                   # 19              Yes              Yes
                   # 20              Yes               No Salem                               Page 6 of 6                     Rev. 0 (draft E)

EAL#: HIMA4o i

SGS ECG - EAL Technical Bases EP-SC-1 11-210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: HOSTILE ACTION within the PROTECTED AREA Mode Applicability: All EAL# & Classification Level: HS4.1 - SITE AREA EMERGENCY EAL: A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the Security Operations Supervisor or designee (Note 8) NOTE 8: Shift Manager (SM) should implement the Prompt Actions of NC.EP-EP.ZZ-0102, EC Response, Attachment 10, prior to classification of a security emergency. Key Information to obtain from Security Supervision upon SM notification of a security event: 

              "    Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION o    If a HOSTILE ACTION, is location the OCA or PA?

Basis: This condition represents an escalated threat to plant safety above that contained in the ALERT in that a HOSTILE FORCE has progressed from the OWNER CONTROLLED AREA to the PROTECTED AREA. This EAL addresses the contingency for a very rapid progression of events due to a HOSTILE ACTION within or directed towards the PROTECTED AREA (PA). Plant VITAL AREAS are within the PROTECTED AREA and are generally controlled by card key readers. A HOSTILE ACTION in the PROTECTED AREA (which includes VITAL AREAS) could represent a situation that threatens the safety of plant personnel and the general public. Salem Page 1 of 6 Rev. 0 (draft E) EAL#: S4o i

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 These EALs address the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. It is not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements. The fact that the site is under serious attack with minimal time available for further preparation or additional assistance to arrive requires Offsite Response Organization (ORO) readiness and preparation for the implementation of protective measures. This EAL is not intended to address incidents that are accidental events or acts of civil disobedience, such as small AORCRAFT impact, hunters, or physical disputes between employees within the PROTECTED AREA. Those events are adequately addressed by other EALs or RALs. Although nuclear plant security officers are well trained and prepared to protect against HOSTILE ACTION, it is appropriate for OROs to be notified and encouraged to begin preparations for public protective actions to be better prepared should it be necessary to consider further actions. If not previously notified by NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, although not certain, that notification by an appropriate Federal agency would follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. However, the declaration should not be unduly delayed awaiting Federal notification. Escalation of this emergency classification level to a GENERAL EMERGENCY, if appropriate, would be based upon the actual loss of physical control of the facility. If necessary, Salem will declare this event. Explanation/Discussion/Definitions: The Security Shift Supervision is defined as the Security Operations Supervisor or designee. These individuals are the designated on-site personnel qualified and trained to confirm that a security event is occurring or has occurred. Training on security event classification confirmation is closely controlled due to the strict secrecy controls placed on the Salem - Hope Creek Security Contingency Plan (Safeguards) information. PROJECTILES that are directed into or that have impacted the PA from the OCA or beyond are considered under this EAL as HOSTILE ACTIONS within the PA. Salem Page 2 of 6 Rev. 0 (draft E) EAL#: H34.1

SGS ECG - EAL Technical Bases EP-SC-1 11-210 Page 5 of this EAL Basis is a "Security Contingency Event Summary Table" that indicates which Security Contingency Events could result in Security Supervision determining that a HOSTILE ACTION is or has occurred and therefore classification at the ALERT or higher level should be made based on the location (OCA or PA) of the HOSTILE ACTION. Security events that do not involve a HOSTILE ACTION may result in Security Supervision determining that a SECURITY CONDDTION exists and therefore an UNUSUAL EVENT classification should be made per EAL HU4.1. Definitions: HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OCA). OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. SECURITY CONDITION: Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION. AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. A large AIRCRAFT is referred to as an AIRLINER. Salem Page 3 of 6 Rev. 0 (draft E) EAL#:HS4.1

SGS ECG - EAL Technical Bases EP-SC-1 11-210 AIRLINERILARGE AIRCRAFT: Any size or type of AIRCRAFT with the potential for causing significant damage to the plant (refer to the Security Contingency Plan for a more detailed definition). PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability, or personnel safety. VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. EAL Bases Reference(s): '1. NEI 99-01, Rev. 05, HA4 Example EAL #1, #2

2. Salem - Hope Creek Security Contingency Plan
3. SC.OP-AB.CR-0004(Q) - Security Event
4. SC.OP-AB.CR-0005(Q)- Airborne Threat Salem Page 4 of 6 Rev. 0 (draft E)

EAL#: 346.1

SGS ECG - EAL Technical Bases EP-SC-1 11-210 Security Contingency Event Summary Table Event Could Event Could Result in Result in Contingency Determination Determination Event of a of a Number SECURITY HOSTILE CONDITION ACTION (UE ONLY) (ALERT or Higher) Yes / No Yes / No 

                       #1              Yes               Yes
                       # 2             Yes               Yes
                       # 3              Yes               No
                       # 4              No               Yes
                       #5               Yes              Yes
                       #6               No                No
                       # 7              No                No
                       #8               Yes              Yes
                       #9               Yes               Yes
                       #10              Yes               Yes
                       # 11             Yes               No
                       # 12             Yes               No
                       #13              Yes               No
                       # 14             Yes               No
                       #15              Yes               No
                       # 16             Yes               Yes
                       # 17             Yes               Yes
                       # 18             No                Yes
                       # 19             Yes               Yes
                       #20              Yes               No Salem                                Page 5 of 6                    Rev. 0 (draft E)

EAL#: ni 4o.]1

SGS ECG - EAL Technical Bases EP-SC-1 11 -210 This page intentionally blank Salem Page 6 of 6 Rev. 0 (draft E) EAL#: M3]4o.1

SGS ECG - EAL Technical Bases EP-SC-1 11-210 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 4 - Security Initiating Condition: HOSTILE ACTION resulting in loss of physical control of the facility Mode Applicability: All EAL# & Classification Level: HG4.1 - GENERAL EMERGENCY EAL: A HOSTILE ACTION has occurred such that plant personnel are unable to operate equipment required to maintain safety functions (i.e., reactivity control, RCS inventory, or secondary heat removal) at Salem or Hope Creek (Note 8) OR A HOSTILE ACTION has caused failure of Spent Fuel Cooling Systems and IMMINENT fuel damage is likely at Salem or Hope Creek (Note 8) NOTE 8: Shift Manager (SM) should implement the Prompt Actions of NC.EP-EP.ZZ-0102, EC Response, Attachment 10, prior to classification of a security emergency. Key Information to obtain from Security Supervision upon SM notification of a security event: 

             "    Determination if the security event is a HOSTILE ACTION or SECURITY CONDITION o    If a HOSTILE ACTION, is location the OCA or PA?

Basis: 1st Condition This EAL encompasses conditions under which a HOSTILE ACTION has resulted in a loss of physical control of VITAL AREAS (containing vital equipment or controls of vital equipment) required to maintain safety functions and control of that equipment cannot be transferred to and operated from another location. Typically, these safety functions are reactivity control (ability to shut down the reactor and keep it shutdown), RCS inventory (ability to cool the core), and secondary heat removal (ability to remove decay heat). Salem Page 1 of 4 Rev. 0 (draft E) EAL#:HG4.]

SGS ECG - EAL Technical Bases EP-SC-11 11-210 If control of the plant equipment necessary to maintain safety functions can be transferred to another location, then the threshold is not met. 2nd Condition This EAL addresses failure of spent fuel cooling systems as a result of HOSTILE ACTION if IMMINENT fuel damage is likely. Explanation/Discussion/Definitions: Definitions: HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OCA). PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability, or personnel safety. VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: HG4.1

SGS ECG - EAL Technical Bases EP-SC-1 11-210 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HG1 Example EAL #1, #2
2. SC.OP-AB.CR-0004(Q) - Security Event
3. SC.OP-AB.CR-0005(Q) - Airborne Threat Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: [*(.14o]

SGS ECG - EAL Technical Bases EP-SC-11 11 -210 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: H86*4.1

SGS ECG - EAL Technical Bases EP-SC-1 11-211 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 5 - Control Room Evacuation Initiating Condition: Control Room evacuation has been initiated Mode Applicability: All EAL# & Classification Level: HA5.1 - ALERT EAL: Control Room evacuation has been initiated Basis: With the Control Room evacuated, additional support, monitoring and direction through the Technical Support Center and/or other emergency response facilities may be necessary. Inability to establish plant control from outside the Control Room will escalate this event to a SITE AREA EMERGENCY per EAL HS5.1. Explanation/Discussion/Definitions: Control Room evacuation represents a serious plant situation since the degree of plant control at the Remote Shutdown Panel (RSP) is not as complete as from the Control Room. The intent of this EAL is to declare an ALERT when the determination to evacuate the Control Room has been made based on environmental/personnel safety concerns, and the physical process of evacuating the Control Room per S1 (S2).OP-AB.CR-0001 (Q), Control Room Evacuation, or S1 (S2).OP-AB.CR-0002(Q) Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room or 4kV Switchgear Room, has commenced. The Shift Manager (SM) determines if the Control Room requires evacuation. Control Room inhabitability may be caused by fire, dense smoke, noxious fumes, bomb threat in or adjacent to the Control Room, or other life threatening conditions. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA5 Example EAL #1
2. S1(S2).OP-AB.CR-0001 (Q) Control Room Evacuation
3. SI(S2).OP-AB.CR-0002(Q) Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room or 4kV Switchgear Room
4. SC.OP-AB.CR-0003(Q) Control Room Habitability Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: HAM

SGS ECG - EAL Technical Bases EP-SC-1 11-211 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: HAS. I

SGS ECG - EAL Technical Bases EP-SC-1 11-211 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 5 - Control Room Evacuation Initiating Condition: Control Room evacuation has been initiated and plant control CANNOT be established Mode Applicability: All EAL# & Classification Level: HS5.1 - SITE AREA EMERGENCY EAL: Control Room evacuation has been initiated AND Control of the plant CANNOT be established within 15 minutes (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: The intent of this EAL is to capture those events where control of the plant cannot be reestablished in a timely manner. In this case, expeditious transfer of control of safety systems has not occurred (although fission product barrier damage may not yet be indicated). The intent of the EAL is to establish control of important plant equipment and knowledge of important plant parameters in a timely manner. Primary emphasis should be placed on those components and instruments that supply protection for and information about safety functions. These safety functions are reactivity control (ability to shutdown the reactor and maintain it shutdown), RCS inventory control (ability to cool the core), and secondary heat removal (ability to maintain a heat sink). The determination of whether or not control is established at the remote shutdown panel is based on Emergency Coordinator judgment. The Emergency Coordinator is expected to make a reasonable, informed judgment within the allocated 15 minutes that the licensee has control of the plant from the remote shutdown panel. Escalation of this emergency classification level, if appropriate, would be by EALs in Category F, Fission Product Barrier Degradation, or Category R, Abnormal Rad Levels/Rad Effluent. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:HS5oi

SGS ECG - EAL Technical Bases EP-SC-1 11-211 Explanation/Discussion/Definitions: The Shift Manager determines if the Control Room is inoperable and requires evacuation. Control Room inhabitability may be caused by fire, dense smoke, noxious fumes, bomb threat in or adjacent to the Control Room, or other life threatening conditions. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HS5 Example EAL #1
2. Sl(S2).OP-AB.CR-0001(Q) Control Room Evacuation
3. S1(S2).OP-AB.CR-0002(Q) Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear .Room .or 4kV Switchgear Room
4. SC.OP-AB.CR-0003(Q) Control Room Habitability Salem- Page 2 of 2 Rev. 0 (draft E)

EAL#:

  • 5oI.1

SGS ECG - EAL Technical Bases EP-SC-1 11-212 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 6 - EC Judgment Initiating Condition: Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of an UNUSUAL EVENT Mode Applicability: All EAL# & Classification Level: HU6.1 - UNUSUAL EVENT EAL: Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. NO releases of radioactive material requiring off-site response or monitoring are expected unless further degradation of safety systems occurs Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the UNUSUAL EVENT emergency classification level. Explanation/Discussion/Definitions: None EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HU5 Example EAL #1 Salem Page 1 of 2 Rev. 0 (draft E)

EAL#:HU6.1

SGS ECG - EAL Technical Bases EP-SC-1 11'212 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: HIU6.1

SGS ECG - EAL Technical Bases EP-SC-1 11-212 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 6 - EC Judgment Initiating Condition: Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of an ALERT Mode Applicability: All EAL# & Classification Level: HA6.1 - ALERT EAL: Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. ANY releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the ALERT emergency classification level. Explanation/Discussion/Definitions: Definitions: HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek plants. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for its continued operability, reliability, or personnel safety. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: tHA6oi

SGS ECG - EAL Technical Bases EP-SC-1 11-212 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HA6 Example EAL #1 Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: HAM

SGS ECG - EAL Technical Bases EP-SC-1 11-212 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 6 - EC Judgment Initiating Condition: Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of a SITE AREA EMERGENCY Mode Applicability: All EAL# & Classification Level: HS6.1 - SITE AREA EMERGENCY EAL: Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. ANY releases are NOT expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the emergency classification level description for SITE AREA EMERGENCY. Explanation/Discussion/Definitions: Definitions: HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek plants. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: 61

SGS ECG - EAL Technical Bases EP-S C- 111 -ý-212 PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for its continued operability, reliability, or personnel safety. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HS3 Example EAL #1 Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: ]36.1

SGS ECG - EAL Technical Bases EP-SC-1 11-212 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 6 - EC Judgment Initiating Condition: Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of a GENERAL EMERGENCY Mode Applicability: All EAL# & Classification Level: HG6.1 - GENERAL EMERGENCY EAL: Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area Basis: This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the emergency classification level description for GENERAL EMERGENCY. Explanation/Discussion/Definitions: Definitions: HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on Salem or Hope Creek plants. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for its continued operability, reliability, or personnel safety. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: H G (*,

SGS ECG - EAL Technical Bases EP-SC-1 11-212 IMMINENT: Mitigation actions have. been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, HG2 Example EAL #1 Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:HGB.]

BAILs foro Sysftems MaffundiRons

SGS ECG - EAL Technical Bases EP-SC-1 11-213 EAL Category: S - System Malfunction EAL Subcategory: 1 - Loss of AC Power Initiating Condition: Loss of all offsite AC power to vital buses for 15 minutes or longer Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SUI.1 - UNUSUAL EVENT EAL: Loss of all Offsite AC power to all 4KV Vital Buses AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: Prolonged loss of off-site AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete loss of AC power to vital buses. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power. Explanation/Discussion/Definitions: The AC power distribution is summarized in Attachment 2, page 2. Emergency Classification escalates to an ALERT under EAL SAl. 1 based on AC power to 4KV vital buses being reduced to a single source. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05 - SU1 Example EAL #1
2. UFSAR Figure 8.2-2 500 kV Switchyard Diagram
3. UFSAR Figure 8.3-1 Auxiliary Power System Diagram Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: S U i]l

SGS ECG - EAL Technical Bases EP-SC-1 11-213

4. UFSAR 8.1.1 Utility Grid System and Interconnections
5. UFSAR 8.3.1 Power
6. SGS Technical Specifications 3.8.1 A.C. Sources
7. SGS Technical Specifications 3.8.2 Onsite Power Distribution Systems
8. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
9. 1(2)-EOP-LOPA-1 Loss of All AC Power 10.S1.(S2).OP-AB.LOOP-0001(Q) -Loss of Off-Site Power 11 .S1(S2).OP-AB.4KV-0001(Q) Loss of 1A(2A) 4KV Vital Bus
12. S1(S2).OP-AB.4KV-0002(Q) Loss of 1B(2B) 4KV Vital Bus
13. S1(S2).OP-AB.4KV-0003(Q) Loss of 1C(2C) 4KV Vital Bus Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: S U 1.

SGS ECG - EAL Technical Bases EP-SC-1 11 -213 EAL Category: S - System Malfunction EAL Subcategory: 1 - Loss of AC Power Initiating Condition: AC power capability to vital buses reduced to a single power source for 15 minutes or longer such that any additional single failure would result in complete loss of AC power to vital buses Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SAI.1 -ALERT EAL: Loss of 4KV Vital Bus Power Sources (Offsite and Onsite) which results in the availability of only one 4KV Vital Bus Power Source (Offsite or Onsite) AND a 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: The condition indicated by this EAL is the degradation of the offsite and onsite AC power systems such that any additional single failure would result in a complete loss of AC power to vital buses. This condition could occur due to a loss of off-site power with a concurrent failure of all but one emergency diesel generator to supply power to its vital bus. The subsequent loss of this single power source would escalate the event to a SITE AREA EMERGENCY in accordance with EAL SS1.1. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power. Explanation/Discussion/Definitions: 

"Availability" means the power source can be aligned to provide power to a vital bus within 15 minutes or is currently supplying power to at least one vital bus.

Salem Page 1 of 2 Rev. 0 (draft E) EAL#: SAi*

SGS ECG - EAL Technical Bases EP-SC-1 11-213 The availability of EDGs that have not been challenged to start during degradation of AC power sources to the 4KV vital buses should be based on meeting Technical Specification action requirements for loss of offsite AC power sources. The AC power distribution is summarized in Attachment 2, page 2. This hot condition Alert EAL is equivalent to the cold condition Unusual Event EAL CUi.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05 - SA5 Example EAL #1
2. UFSAR Figure 8.2-2 500 kV Switchyard Diagram
3. UFSAR Figure 8.3-1 Auxiliary Power System Diagram
4. UFSAR 8.1.1 Utility Grid System and Interconnections
5. UFSAR 8.3.1 Power
6. SGS Technical Specifications-3.8.1 A.C. Sources
7. SGS Technical Specifications 3.8.2 Onsite Power Distribution Systems
8. 1(2)-EOP-TRIP-1 Reactor Trip or Safety lIje6ction
9. 1(2)-EOP-LOPA-1 Loss of All AC Power
10. S1 (S2).OP-AB.LOOP-0001 (Q) Loss of Off-Site Power
11. S1 (S2).OP-AB.4KV-0001 (Q) Loss of 1A(2A) 4KV Vital Bus..
12. S1 (S2).OP-AB.4KV-0002(Q) Loss of, 1B(2B) 4KV Vital Bus
13. S1 (S2).OP-AB.4KV-0003(Q)'Loss of 1C(2C) 4KV Vital Bus, Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: 3 I.]

SGS ECG - EAL Technical Bases EP-SC-1 11-213 EAL Category: S - System Malfunction EAL Subcategory: 1 - Loss of AC Power Initiating Condition: Loss of all offsite power and all onsite AC power to vital buses for 15 minutes or longer Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SS1.1 - SITE AREA EMERGENCY EAL: Loss of all Power (Onsite and Offsite) to all 4KV Vital Buses AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: Loss of all AC power to vital buses compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink (Service Water). Prolonged loss of all AC power to vital buses will lead to loss of Fuel Clad, RCS, and Containment, thus this event can escalate to a GENERAL EMERGENCY. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power. Escalation to GENERAL EMERGENCY is via EALs in Category F, Fission Product Barrier Degradation, or EAL SG1.1, "Prolonged Loss of All Offsite Power and Prolonged Loss of All Onsite AC Power." Explanation/Discussion/Definitions: The intent of this EAL is to classify degraded AC power events that result in a loss of all offsite 13.8 KV power sources to the 4KV vital buses along with a loss of all onsite power sources (EDGs). The AC power distribution is summarized in Attachment 2, page 2. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: S SIoI

SGS ECG - EAL Technical Bases EP-SC-1 11-213 This hot condition Site Area Emergency EAL is equivalent to the cold condition Alert EAL CA1.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05'-'SS1 Example EAL #1
2. UFSAR Figure 8.2-2 500 kV Switchyard Diagram
3. UFSAR Figure 8.3-1 Auxiliary Power System Diagram
4. UFSAR 8.1.1 Utility Grid System and Interconnections
5. UFSAR 8.3.1 Power
6. SGS Technical Specifications 3.8.1 A.C. Sources
7. SGS Technical Specifications 3.8.2 Onsite Power Distribution Systems
8. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
9. 1(2)-EOP-LOPA-1 Loss of All AC Power-
10. S1 (S2).OP-AB.LOOP-0001 (Q) Loss of Off-Site Power
11. S1(S2).OP-AB.4KV-0001(Q) Loss of 1A(2A) 4KV Vital Bus
12. S1 (S2).OP-AB.4KV-0002(Q) Loss of 1B(2B) 4KV Vital Bus
13. Sl (S2).OP-AB.4KV-0003(Q) Loss of I C(2C) 4KV Vital Bus Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: 193 *o I]

SGS ECG - EAL Technical Bases EP-SC-1 11-213 EAL Category: S - System Malfunction EAL Subcategory: 1 - Loss of AC Power Initiating Condition: Prolonged loss of all offsite and all onsite AC power to vital buses Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SGI.1 - GENERAL EMERGENCY EAL: Loss of all Power (Onsite and Offsite) to all 4KV Vital Buses AND EITHER of the following: o Restoration of at least one Vital Bus in < 4 hrs is NOT likely o CFST Core Cooling RED or PURPLE path exists Basis: Loss of all AC power to vital buses compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink (Service Water). Prolonged loss of all AC power to vital buses will lead to loss of Fuel Clad, RCS, and Containment, thus this event can escalate to a GENERAL EMERGENCY. This EAL is specified to assure that in the unlikely event of a prolonged station blackout, timely recognition of the seriousness of the event occurs and that declaration of a GENERAL EMERGENCY occurs as early as is appropriate, based on a reasonable assessment of the event trajectory. The likelihood of restoring at least one vital bus should be based on a realistic appraisal of the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions. In addition, under these conditions, fission product barrier monitoring capability may be degraded. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: SGIl

SGS ECG - EAL Technical Bases EP-SC-1 11-213 Explanation/Discussion/Definitions: The AC power distribution is summarized in Attachment 2, page 2. Four hours is the station blackout coping time. The ýstatus and availability of DC power may limit or prevent restoration activities. When prolonged powering of inverters and DC loads has occurred without AC power available for the battery chargers, DC voltage will degrade. This degradation of DC power may, limit monitoring and as-6ssment capabilities as instrumentation and control power may not be available. Since monitoring of overall plant conditions will be difficult with no AC power, CFST indications for determining barrier loss are used. - The likelihood of restoring at least one Vital Bus should be based on a realistic appraisal of the, situation since a delay in-an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions. In addition, under these conditions, fissio h product barrier monitoring capability may be' degraded. Although it may be difficult to predict when power can be restored, it is necessary to give the Emergency Coordinator reasonable idea of how quickly he may need to declare a General Emergency based on two major considerations:

1. Are there any present indications that, core cooling is already degraded to the point that loss or potential loss of fission product barriers is imminent?
2. If there are no present indications of such core cooling degradation, how likely is it that pow6 r--n be r-est6rd in timot6 as*ure tliat a lossof two barriers with-a-potential loss of the third barrier can be prevented?

It is estimated that.seve.ra! hours are required to fully evacuate the 10-mile EPZ. Taking into consideration the above factors, declaring a General Emergency leaves sufficient time for the offsite auth'orities to implement Protectiv e Actions.well before a radioactive release would occur whild"providing sufficient time. foron-site and off-site mitigation activitie.s to restore AC power. CFST status will.n6t be 'used for eventc as if ication unti Ithe ControI Roo" Staff hIas imple.menfýed th6 CFSTs. The Core C*ooing CFST is illustrated in Attachment 2, 'page 4.' EAL Bases Reference(s):

1. NEI 99-01, Rev. 05 - SG1 Example EAL #1
2. UFSAR Fig urb 8.2-2 500 kV Switchyard Diagram
3. UFSAR Figure 8.3-1 Auxiliary Power System Diagram
4. UFSAR-I8.1.1 Utility Grid System and Interconnections
5. UFSAR 8.3.1 Power
6. SGS Technical Specifications 3.8.1 A.C. Sources
7. SGS Technical Specifications 3.8.2 Onsite Power Distribution Systems Salem Page 2 of 4 Rev. 0 (draft E)

EAL#: 38 1. 1

SGS ECG - EAL Technical Bases EP-SC-1 11-213

8. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
9. 1(2)-EOP-LOPA-1 Loss of All AC Power
10. S1(S2).OP-AB.LOOP-0001 (Q) Loss of Off-Site Power
11. S1(S2).OP-AB.4KV-0001(Q) Loss of 1A(2A) 4KV Vital Bus
12. S1 (S2).OP-AB.4KV-0002(Q) Loss of 1B(2B) 4KV Vital Bus
13. S1 (S2).OP-AB.4KV-0003(Q) Loss of 1C(2C) 4KV Vital Bus 14.UFSAR 3.12.1.1 Conformance to NRC Rule on Station Blackout 15.ES-45.003(Q) Station Blackout Duration Calculation
16. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - Figure 2 Core Cooling Status Tree 17.PSE&G Emergency Operating Procedure Setpoint Document Salem Units 1 & 2 Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: SG oi

SGS ECG - EAL Technical Bases EP-SC-1 11-213 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: S GI'.1

SGS ECG - EAL Technical Bases EP-SC-1 11-214 EAL Category: S - System Malfunction EAL Subcategory: 2 - Loss of DC Power Initiating Condition: Loss of all vital DC power for 15 minutes or longer Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SS2.1 - SITE AREA EMERGENCY EAL: < 114 VDC bus voltage indications on All 125 VDC vital buses for > 15 minutes (Note 3) OR < 25 VDC bus voltage indications on both 28 VDC vital buses for _ 15 minutes (Note 3) AND loss of control of Safety Related Equipment from the Control Room has been confirmed Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: Loss of all DC power compromises ability to monitor and control plant safety functions. Prolonged loss of all DC power will cause core uncovering and loss of containment integrity when there is significant decay heat and sensible heat in the reactor system. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Escalation to a General Emergency would occur by EALs in Category R, Abnormal Rad Levels/Rad Effluent, or Category F, Fission Product Barrier Degradation. Explanation/Discussion/Definitions: The specified bus voltage indications (rounded for readability on Control Room instrumentation) are the minimum voltage requirements for operability of the 125 VDC buses and 28 VDC buses following battery discharge tests. Although continued operation may occur with degraded voltage, these values signify the minimum operable voltages allowed. This Site Area Emergency EAL is the hot condition equivalent of the cold condition loss of DC power Unusual Event EAL CU2.1. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: SS2,,'

SGS ECG - EAL Technical Bases EP-SC-1 11 -214 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SS3 Example EAL #1
2. SC.MD-ST.125-0004 (Q) 125 Volt Station Batteries 18 Month Service Test and Associated Surveillance Testing Using BCT-2000,
3. SC.MD-ST.28D-0004 (Q) 28 Volt Station Batteries 18 Month Service Test and Associated Surveillance Using BCT-2000
4. UFSAR 8.312 DC Power
5. SGS Technical Specifications 3.8.2.3 125 Volt DC Distribution - Shutdown
6. SGS Technical Specifications 3.8.2.5 28 Volt DC Distribution - Shutdown
7. S1($2).OP-SO.125-0005 1(2)A 125VDC Bus Operation
8. S1($2).OP-SO.125-0006 1(2)B 1-25VDC Bus Operation
9. S1(S2).OP-SO.125-0007.1(2)C 125VDC Bus Operation Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:332o1

SGS ECG - EAL Technical Bases EP-SC-1 11-215 EAL Category: S - System Malfunction EAL Subcategory: 3 - ATWT / Criticality Initiating Condition: Inadvertent Criticality Mode Applicability: 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SU3.1 - UNUSUAL EVENT EAL: UNPLANNED sustained positive startup rate observed on nuclear instrumentation Basis: This EAL addresses inadvertent criticality events. This EAL indicates a potential degradation of the level of safety of the plant, warranting a UE classification. This EAL excludes inadvertent criticalities that occur during planned reactivity changes associated with reactor startups (e.g., criticality earlier than estimated). Escalation would be by the Fission Product Barrier Table, as appropriate to the operating mode at the time of the event. Explanation/Discussion/Definitions: The term "sustained" is used in order to allow exclusion of expected short term positive startup rates from planned fuel bundle or control rod movements during core alteration. These short term positive startup rates are the result of the increase in neutron population due to subcritical multiplication. Positive reactor startup rate may be identified by: o Source range startup rate indicators NI31D and N132D o NIS Recorder NR45 o Audio count rate o SPDS o Process Computer This EAL is the hot condition equivalent of the cold condition EAL CU6.1. Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: SU 3.1*

SGS ECG - EAL Technical Bases EP-SC-1 11-215 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU8 Example EAL #1.
2. Technical Specifications 3.3.1.1 Reactor Trip System Instrumentation
3. UFSAR Table 7.5-2 Main Control Room Indicators and/or Recorders Available to Plant Operators to Monitor Significant Plant Parameters During Normal Operations
4. SC.IC-CC.NIS-0011(Q) N31 Source Range
5. SC.IC-CC.NIS-0012(Q) N32 Source Range I -

Salem Page 2 of 2 Rev. 0 (draft E) EAL#: S 3Ui

SGS ECG - EAL Technical Bases EP-SC-1 11-215 EAL Category: S - System Malfunction EAL Subcategory: 3 - ATWT / Criticality Initiating Condition: Automatic trip fails to shut down the reactor and the manual actions taken from the reactor control console are successful in shutting down the reactor Mode Applicability: 1 - Power Operations, 2 - Startup EAL# & Classification Level: SA3.1 - ALERT EAL: An automatic trip failed to shut down the reactor AND Manual trip actions taken at the reactor control console (reactor trip switches, trip bkr bezels, supply breakers 1/2E6D and 1/2G6D) successfully shut down the reactor as indicated by reactor power < 5% Basis: The reactor should be considered shutdown when it producing less heat than the maximum decay heat load for which the safety systems are designed (5% power). This EAL equates to the criteria used to determine a valid CFST Shutdown Margin Red Path. Manual trip actions taken at the reactor control console are any set of actions by the reactor operator(s) which causes or should cause control rods to be rapidly inserted into the core and shuts down the reactor. The reactor trip switches on the Control Room console are an automatic input into the Reactor Protection System. A failure to trip after actuating both reactor trip switches without any other automatic input would make this threshold applicable. This condition indicates failure of the automatic protection system to trip the reactor. This condition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient. Thus the plant safety has been compromised because design limits of the fuel may have been exceeded. An ALERT is indicated because conditions may exist that lead to potential loss of fuel clad or RCS and because of the failure of the Reactor Protection System to automatically shutdown the plant. If manual actions taken at the reactor control console fail to shut down the reactor, the event would escalate to a SITE AREA EMERGENCY. Salem Page 1 of 4 Rev. 0 (draft E3) EAL#: SA31]

SGS ECG - EAL Technical Bases EP-SC-1 11-215 Explanation/Discussion/Definitions: This EAL identifies the need to cease critical reactor operations by actuation of the automatic Reactor Protection System (RPS) trip function. A reactor trip is automatically initiated by the Reactor Protection System (RPS) when-c6rtain continuously monitored parameters exceed predetermined setpoints. Following a successful reactor trip, rapid insertion of the control rods occurs. Nuclear power promptly drops to a fraction of the original power level and then decays to a level several decades less with a negative period. The reactor power drop continues until reactor power reaches the point at which the influence of source neutrons on reactor power'starts to be observable. A predictable post-trip response from an automatic reactor trip signal should therefore consist of a prompt.drop in reactor power as-sensed by the nuclear instrumentation and a lowering of power into the source range. A successful trip has therefore occurred when there is sufficient rod insertion from the trip of RPSto: býring reactor power to below 5%, the value used to determine a valid Shutdown Margin Status Tree Red Path. CSFST Shutdown Margin red path is illustrated in Attachment 2, page 5. For the purposes of emergency classification- at the Alert level,""sujccessful manual trip actions are those which can be quickly performed from the reactor control console (i.e.,. reactor trip.. switches, trip bkr bezels, supply breakers 1/2E6D and. 1/2G6D). EOP-FRSM-1 requires an Equipment Operator to locally open the Reactor Trip Breakers and trip the Rod Drive MG Sets. These actions are performed outside the Main Control Room and are NOT to be credited as a successful manual trip. Following.'a-ny autormatic RPS trip signal EOPs preScribe insertion of redundant manual trip*. signals to-back up the automatic RPS'trip-fuinction and -ensure reactor shutdown is achieved. afte.r the Even if the first subsequent manrual trip' signal fully-ins'erts all control rods immediately initial failure of the automatic trip, the lowest level of classification that must be declared is an Alert. *I . -"- ' " - In the event that the operator identifies a reactor trip is imminent and initiates a successful manual reactor trip before the automatic trip setpoint is reached, no declaration is required. The successful mahual trip of the -reactor before it reaches its automatic trip setpoint or reactor trip signals caused by instrumentatiori channel failures"do not lead toa potential fiasion product barrier loss. If manual reactor trip -actions fail toreduce reactor power below 5%, the event escalates to the Site Area Emergency under EAL 'SS3I.:" If by procedure, operator actions includeIthe initiation of an immediate manual trip following receipt of an automatic trip signal and ther6 are no clear indidations that the automatic trip failed (such. as a time delay following indications that a trip setpoint vwas exceeded), it may be difficult to determine if the reactor was shut down because ofiautomatic trip or manual actions. If a subsequent review of the trip-actuatio'n indications reveals that the automatic trip did not cause the reactor to be shut down, consideration should be gliven to evaluating the fuel for Salem Page 2 of 4 Rev. 0 (draft E3) EAL#:SA3o

SGS ECG - EAL Technical Bases EP-SC-1 11-215 potential damage, and the reporting requirements of 10CFR50.72 should be considered for the transient event. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SA2 Example EAL #1
2. UFSAR 7.1.1.1 Reactor Trip Systems
3. UFSAR Table 7.2-1 List of Reactor Trips, Engineered Safety Features, Containment and Steam Line Isolation and Auxiliary Feedwater
4. Technical Specifications Table 3.3-1 Reactor Trip System Instrumentation
5. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
6. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - Figure 1 Shutdown Margin Status Tree
7. 1(2)-EOP-FRSM-1 Response to Nuclear Power Generation Salem Page 3 of 4 Rev. 0 (draft E3)

EAL#:SA3o ]

SGS ECG - EAL Technical Bases EP-SC-I 11-215 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E3) EAL#:SA3o1

SGS ECG - EAL Technical Bases EP-SC-1 11-215 EAL Category: S - System Malfunction EAL Subcategory: 3 - ATWT / Criticality Initiating Condition: Automatic trip fails to shut down the reactor and manual actions taken from the reactor control console are not successful in shutting down the reactor. Mode Applicability: 1 - Power Operations, 2 - Startup EAL# & Classification Level: SS3.1 - SITE AREA EMERGENCY EAL: An automatic trip failed to shut down the reactor AND Manual trip actions taken at the reactor control console (reactor trip switches, trip bkr bezels, supply breakers 1/2E6D and 1/2G6D) do NOT shut down the reactor as indicated by reactor power > 5% Basis: The reactor should be considered shutdown when producing less heat than the maximum decay heat load for which the safety systems are designed (5% power). This EAL equates to the criteria used to determine a valid CFST Shutdown Margin Red Path. Under these conditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed and efforts to bring the reactor subcritical are unsuccessful. A SITE AREA EMERGENCY is warranted because conditions exist that lead to IMMINENT loss or potential loss of both fuel clad and RCS. Manual trip actions taken at the reactor control console are any set of actions by the reactor operator(s) at which causes or should cause control rods to be rapidly inserted into the core and shuts down the reactor. Escalation of this event to a GENERAL EMERGENCY would be due to a prolonged condition leading to an extreme challenge to either core cooling or heat removal. Explanation/Discussion/Definitions: This EAL addresses any automatic reactor trip signal followed by a manual trip that fails to shut down the reactor to an extent the reactor is producing energy in excess of the heat load for which the safety systems were designed. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: 853.OI

SGS ECG - EAL Technical Bases EP-SC-111-215 For the purposes of emergency classification at the Site Area Emergency level, successful manual trip actions are those which can be quickly performed from the reactor control console (i.e., reactor trip switches, trip bkr bezels, supply breakers 1(2)E6D and 1(2)G6D). EOP-FRSM-1 requires an Equipment Operator to locally open the Reactor Trip Breakers and trip the Rod Drive MG, Set§s.These'actions are performed outside the Main Control Roo m and are not to be credited as a successful manual trip. For emergency classification purposes, the reactor should be considered shutdown when it is producing less heat than the maximuM- decay heat load foe which the safety systems are designed. This equates to <.5% power, the value used to determine a valid Shutdown Margin Status Tree Red Path. CSFST Shutdown Margin red path is illustrated in Attachment 2, page 5. Entry into EOP-FRSM-1 will be required if the manual trip from the console "trip handles" or Turbine Trip and P-9 (> 49% Power) is not successful: EOP-FRSM-1 requires an Equipment Operator to locally open the Reactor Trip Breakers and trip the Rod Drive MG Sets. Since this action is outside the Control Room, a successful remote Reactor Trip will still require classification under this EAL because the, design limits of the fuel. may have been exceeded or because of the gross failure of the.RIPS to shut down the plantl The threshold' value of' <5% reactor power was selected to be 6onsistenttwith CFST EOP-FRSM-1 entry criteria. Mode 2. is included in this EAL to include events which result in a return to > 5% reactor power from' so m e -IdweP -aIu-o ......... . ...... .. . . . ... . . . ~ ..-- . -... ...... .. ..... Escalation of this event to a GENERAL EMERGENCY would be under EAL SG3.1 or Emergency Coordinator judgment. Definitio'ns .: . . IMMINENT: Mitigation actions have been ineffective, additional actions are not p'ectf6d to b'e successfuli a"r*d trended information indicaktes that the event or condinion will occur within- approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SS2 Example-EAL#1.
2. 1(2)-EOP-Tr, IP--i 'Re-a'ctor Trip*or safety injectionr
3. 1(2)-EOP-FRSM-1 Response to Nuclear Power Generation
4. 1(2)-EOP-CFST-1 Critical .Safety Function Status Trees - Figure 1 Shutdown Margin Status Tree Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: 33.

SGS ECG - EAL Technical Bases EP-SC-1 11 -215 EAL Category: S - System Malfunction EAL Subcategory: 3 - ATWT / Criticality Initiating Condition: Automatic trip and all manual actions fail to shut down the reactor and indication of an extreme challenge to the ability to cool the core exists Mode Applicability: 1 - Power Operations, 2 - Startup EAL# & Classification Level: SG3.1 - GENERAL EMERGENCY EAL: An automatic trip failed to shut down the reactor AND All manual actions do NOT shut down the reactor as indicated by reactor power > 5% AND EITHER of the following: o CFST Core Cooling RED path exists o CFST Heat Sink RED path exists due to actual loss of secondary heat sink and heat sink is required Basis: The reactor should be considered shutdown when it producing less heat than the maximum decay heat load for which the safety systems are designed (5% power). This EAL equates to the criteria used to determine a valid CFST Shutdown Margin Red Path. Under these conditions, the reactor is producing more heat than the maximum decay heat load for which the safety systems are designed and efforts to bring the reactor subcritical are unsuccessful. In the event either of these challenges exists at a time that the reactor has not been brought below the power associated with the safety system design, a core melt sequence exists. In this situation, core degradation can occur rapidly. For this reason, the GENERAL EMERGENCY declaration is intended to be anticipatory of the fission product barrier table declaratiohI to permit maximum offsite intervention time. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:SG3ol

SGS ECG - EAL Technical Bases EP-SC-1 11-215 Explanation/Discussion/Definitions: For emergency classification purposes, the reactor should be considered shutdown when it is producing less heat than the maximum decay heat load for which the safety systems are designed, This equates to < 5% power, the value used to determine a valid Shutdown Margin Status Tree Red Path. CSFST Shutdown Margin. red path is illustrated in Attachment 2, page 5. Entry into EOP-FRSM-1 will be. required if the manual.trip from the console "trip handle" or Turbine Trip and P-9 (> 49% Power) is not successful. EOP-FRSM-1 requires an Equipment Operator to locally open the Reactor-Trip Breakers and trip the Rod Drive MG Sets. Since this action is outside the control room, a successful remote Reactor Trip will require classification under this EAL. The threshold value of 5% reactor power was selected to be consistent with CFST EOP-FRSM-1 entry criteria. For events, which result in a return to > 5% reactor power from some lower value, classification under this EAL would be required. Further degradation is indicated by the occurrence of valid CFST Core Cooling red path or Heat Sink red path. The Core Cooling red path is indicative of a loss of core cooling and the Heat Sink red path of a potential loss of core cooling. CFST status will not be used for event classification until the Control Room Staff has implemented the CFSTs. CFST Core Cooling and CFST Heat Sink are illustrated in Attachment 2 page 4 and 6, respectively. If the Heat Sink red path is due to a procedurally directed action, classification under this EAL is not required. EOP-FRSM-1 directs the operators to minimize feedwater flow to the steam generators in order to minimize cooldown and control reactivity. A heat sink red path is generated as a result of this operator action. However, actual loss of control of the heat sink does not occur due to these actions. In addition, the heat sink red path is precursor to a loss of core cooling and is backed up by the core cooling red path. Declaration of a General Emergency- is not justified if the heat sink red path is a result of procedurally directed actions. EAL Bases Reference(s):

1. NEI: 99,-01, Rev. 05, SG2. Example EAL #1
2. 1(2)-EOP-FRSM-1lResponse to Nuclear Power Generation
3. 1(2)-EOP-TRIP-1 Reactor Tripori Safety Injection
4. 1(2)-EOP-CFST-1 Critical Safety Function Status.Trees - Figure 1 Shutdown Margin Status Tree.,
5. PSE&G Emergency Operating Procedure Setpoint Document Salem Units 1 & 2
6. 1(2)-EOP-CFST-1 Critica.l Safety Function Status Trees - Figure 2 Core Cooling Status Tree
7. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - Figure 3 Heat Sink Status Tree Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: 303.1

SGS ECG - EAL Technical Bases EP-SC-1 11-216 EAL Category: S - System Malfunction EAL Subcategory: 4 - Inability to Reach or Maintain Shutdown Conditions Initiating Condition: Inability to reach required shutdown within Technical Specification limits Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Shutdown EAL# & Classification Level: SU4.1 - UNUSUAL EVENT EAL: Plant is NOT brought to required operating mode within Technical Specifications LCO action statement time Basis: Limiting Conditions of Operation (LCOs) require the plant to be brought to a required operating mode when the Technical Specification required configuration cannot be restored. Depending on the circumstances, this may or may not be an emergency or precursor to a more severe condition. In any case, the initiation of plant shutdown required by the site Technical Specifications requires a four hour report under 10 CFR 50.72 (b) Non-emergency events. The plant is within its safety envelope when being shut down within the allowable action statement time in the Technical Specifications. An immediate UE is required when the plant is not brought to the required operating mode within the allowable action statement time in the Technical Specifications. Declaration of a UE is based on the time at which the LCO-specified action statement time period elapses under the site Technical Specifications and is not related to how long a condition may have existed. Explanation/Discussion/Definitions: Depending on the circumstances, this may or may not be a precursor to a more severe condition. A shutdown required by the Technical Specifications requires a report under 10 CFR 50.72 (b) non-emergency events. The plant is within its safety envelope when actions are completed within the allowable Action Statement time in the T/S. If the times specified within the Action Statements are not met, the plant may be in an unsafe condition. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU2 Example EAL #1
2. SGS Technical Specifications Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: 8U4o1

SGS ECG - EAL Technical Bases EP-SC-1 11 -216 This page intentionally blank. Saleni Page 2 of 2 Rev. 0 (draft E) EAL#: SU4DII

SGS ECG - EAL Technical Bases EP-SC-1 11-217 EAL Category: S - System Malfunction EAL Subcategory: 5 - Instrumentation Initiating Condition: UNPLANNED loss of safety system annunciation or indication in the Control Room for 15 minutes or longer Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SU5.1 - UNUSUAL EVENT EAL: UNPLANNED loss of > approximately 75% of Control Room Overhead Annunciators for > 15 minutes (Note 3) OR UNPLANNED loss of > approximately 75% of Control Room Indications associated with the following safety functions for _>15 minutes (Note 3): o Reactivity Control o RCS Inventory o Decay Heat Removal o Fission Product Barriers Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: This EAL is intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. Recognition of the availability of computer based indication equipment is considered. 

"Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.

Salem Page 1 of 4 Rev. 0 (draft E) EAL#: S USoI1

SGS ECG.- EAL Technical Bases EP-SC-1 11 -217 Quantification is arbitrary, however, it is estimated that if approximately 75% of the annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is further re'cognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is 'mo're likely than afailure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status". This will be baddressed bytthe-specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action,. the UE-is based on SU4.1 "Inability to Reach Required Shutdow"n Witlhin Technic al Specificatiorn L'imits." Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. This UE-will be escalated to an ALERT based on a concurrent loss of.compensatory indicatiohs or aSIGNIFICANT TRANSIENT is occurring during a loss of annunciators/indications. Explanation/Discussion/Definitions: This EAL recognizes the difficulty associated with monitoring changing plant'conditions without the use of a major portion of the annunciation or indication equipment.. A. UNPLANNED loss of most or all Control Room Overhead Annunciators orother key"cobtrol room safety function indicators without a plant transient in MODES 1, 2, 3, or 4 for > 15.:., minutes warrants a heightened awareness by Control Room Operators. Quantification of 75% is left to the discretion of the Shift Manager (SM), and is considered approximately 75%. It is-not intended that a detailed count be performed,. but that a rough approximation be used to determine the severity of the loss.. OP-AB.ANN-0001 '(Q)details in*ceaSbd Finbioitoririg and surveillahie req iiorenients as-woll as alternate indicators. 15 minutes is used as a threshold to exclude transient or momentary power losses. The 15 minutes clock starts when the annunciators or other key Control Room safety function, indications have been lost,.or are determined-to. have been lost. If upon time of discovery it is determined that the:annunciators or key safety functio bindications have been lost for at least-15'minutes prior to discovery,'classification 'should be made under this EAL regardless of,time- required for. restoration. If it is determined that.the annunciators were lost. for at least 15 minutes with the annunciators now available at the time of discovery, classification is not *required .under this. EAL, but.a review of the-"After.The iFact" RA.L (11.6) should be completed. Salem Page 2 of 4 Rev. 0 (draft E) EAL#: SUM

SGS ECG - EAL Technical Bases EP-SC-1 11-217 Definitions: UNPLANNED: a parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. An UNPLANNED loss of annunciators and loss other key control room indication systems excludes scheduled maintenance and testing activities. SIGNIFICANT TRANSIENT: An UNPLANNED event based on EC judgment, but includes as a minimum any one of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, or (4) Safety Injection Activation. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU3 Example EAL #1
2. SI(S2).OP-AB.ANN-0001(Q) Loss of Overhead Annunciator System
3. UFSAR 7.7.2.10 Plant Alarm and Annunciator Systems
4. UFSAR Table 7.7-2 Overhead Annunciator Groupings Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: S U 5o I

SGS ECG - EAL Technical Bases EP-SC-1 11-217 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: SUM

SGS ECG - EAL Technical Bases EP-SC-1 11-217 EAL Category: S - System Malfunction EAL Subcategory: 5 - Instrumentation Initiating Condition: UNPLANNED loss of safety system annunciation or indication in the Control Room with either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SA5.1 - ALERT EAL: UNPLANNED loss of > approximately 75% of Control Room Overhead Annunciators for > 15 minutes (Note 3) OR UNPLANNED loss of > approximately 75% of Control Room Indications associated with the following safety functions for _ 15 minutes (Note 3): o Reactivity Control o RCS Inventory o Decay Heat Removal o Fission Product Barriers AND EITHER of the following: o A SIGNIFICANT TRANSIENT is in progress, Table S-1 o Compensatory indications are NOT available per OP-AB.ANN-0001(Q) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: SAM

SGS ECG - EAL Technical Bases EP-SC-1 11-217 Table S-1 SIGNIFICANT TRANSIENTS o Automatic turbine runback > 25% thermal reactor power o Electrical load rejection > 25% full electrical load o Reactor Trip o Safety Injection Activation Basis: This EAL is intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a SIGNIFICANT TRANSIENT. "Planned" loss of annunciators orindicators includes scheduled maintenance and testing activities. Quantification is arbitrary, however, it is estimated that if approximately 75% of the annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed. count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of'system operation. It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. Ifthe shutdown is not in compliance with the Technical Specification action, the 'UE is ba§sed on SU4.1 n'hability to Reach Required Shutdown Within Technical Specification Limits." "Compensatory indications" in this context includes computer based information such as the Plant Computer System and SPDS (see OP-AB.ANN-0001(Q)). If both a major portion of the annunciation-system and all compUter monitoring are unavailable, the ALERT is required. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Salem Page 2 of 4 Rev. 0 (draft E) EAL#:SA 5o

SGS ECG - EAL Technical Bases EP-SC-1 11-217 This ALERT will be escalated to a SITE AREA EMERGENCY if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a SIGNIFICANT TRANSIENT in progress during the loss of annunciation or indication. Explanation/Discussion/Definitions: OP-AB.ANN-0001(Q) details increased monitoring and surveillance requirements as well as alternate indicators during a loss of Control Room Overhead Annunciators. The 15 minute clock starts when the annunciators or other key control room safety function indications have been lost, or are determined to have been lost. If upon time of discovery it is determined that the annunciators or key safety function indications have been lost for at least 15 minutes prior to discovery, classification should be made under this EAL regardless of time required for restoration. SIGNIFICANT TRANSIENTS are listed in Table S-1 and include response to automatic or manually initiated functions such as reactor trips, automatic turbine runback greater than 25% thermal reactor power, electrical load rejection greater than 25% full electrical load, or Safety Injection activation. The Plant Computer System and Safety Parameter Display System (SPDS) serve as redundant indicators which may be utilized as compensatory measures in lieu of the Control Room Overhead Annunciators and Control Room indicators associated with safety functions. The judgment of the Shift Manager should be used as the threshold for determining the severity of the plant conditions. If the operating crew cannot monitor the transient in progress, the ALERT escalates to a SITE AREA EMERGENCY under EAL SS5.1. Definitions: UNPLANNED: a parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. An UNPLANNED loss of annunciators and loss other key control room indication systems excludes scheduled maintenance and testing activities. SIGNIFICANT TRANSIENT: An UNPLANNED event based on EC judgment, but includes as a minimum any one of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, or (4) Safety Injection Activation. Salem Page 3 of 4 Rev. 0 (draft E) EAL#: SA5~1J

SGS ECG - EAL Technical Bases EP-SC-1 11-217 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SA5 Example EAL #1
2. S1(S2).OP-AB.ANN-0001(Q) Loss of Overhead Annunciator System
3. UFSAR 7.7.2.10 Plant Alarm and Annunciator Systems
4. UFSAR Table 7.7-2 Overhead Annunciator Grouping Salem Page 4 of 4 Rev. 0 (draft E)

EAL#: Sz5.1

SGS ECG - EAL Technical Bases EP-SC-1 11-217 EAL Category: S - System Malfunction EAL Subcategory: 5 - Instrumentation Initiating Condition: Inability to monitor a SIGNIFICANT TRANSIENT in progress Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SS5.1 - SITE AREA EMERGENCY EAL: Loss of > approximately 75% of Control Room Overhead Annunciators for > 15 minutes (Note 3) OR Loss of > approximately 75% of Control Room Indications associated with the following safety functions for ? 15 minutes (Note 3): o Reactivity Control o RCS Inventory o Decay Heat Removal o Fission Product Barriers AND A SIGNIFICANT TRANSIENT is in progress, Table S-1 AND Compensatory indications are NOT available per OP-AB.ANN-0001 (Q) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: SIS 5.1

SGS ECG - EAL Technical Bases EP-SC-1 11-217 Table S-1 SIGNIFICANT TRANSIENTS o Automatic turbine runback > 25% thermal reactor power o Electrical load rejection > 25% full electrical load o Reactor Trip o Safety Injection Activation Basis: This EAL is intended to recognize the threat to plant safety associated with the complete loss of capability of the control room staff to monitor plant response to a SIGNIFICANT TRANSIENT. "Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not a factor. Quantification is arbitrary, however, it is estimated that if approximately 75% of the annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the 15ant conditions. It is also not intended that the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation. It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of.. annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a.Technical .Specification imposed plant shutdown related to.the instrument loss will be reported v"ia 10 CFR 50.72. If the shutdown is' not in complianc6 with the Technical. Specification action, the UE is based on SU4.l "Inability to Reach Required Shutdown Within Technical Specification Limits." A SITE AREA EMERGENCY is considered to exist if the Control Room staffcannot monitor safety functions needed for protection of the public while a significant transient is in progress. Site specific indications needed to monitor safety functions necessary for protection of the public must include Control Room indications, computer generated indications and dedicated annunciation capability. Salem Page 2 of 4 Rev. 0 (draft E) EAL#:

SGS ECG - EAL Technical Bases EP-SC-1 11-217 "Compensatory indications" in this context includes computer based information such as the Plant Computer System and SPDS (see OP-AB.ANN-0001 (Q)). This should include all computer systems available for this use depending on specific plant design and subsequent retrofits. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Explanation/Discussion/Definitions: OP-AB.ANN-0001(Q) details increased monitoring and surveillance requirements as well as alternate indicators during a loss of Control Room Overhead Annunciators. The 15 minute clock starts when the annunciators or other key control room safety function indications have been lost, or are determined to have been lost. If upon time of discovery it is determined that the annunciators or key safety function indications have been lost for at least 15 minutes prior to discovery, classification should be made under this EAL regardless of time required for restoration. SIGNIFICANT TRANSIENTS are listed in Table S-1. The Plant Process Computer System (PPC) and Safety Parameter Display System (SPDS) serve as redundant indicators which may be utilized as compensatory measures in lieu of the Control Room Overhead Annunciators and Control Room indicators associated with safety functions. The judgment of the Shift Manager should be used as the threshold for determining the severity of the plant conditions. Definitions: UNPLANNED: a parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. An UNPLANNED loss of annunciators and loss other key control room indication systems excludes scheduled maintenance and testing activities. SIGNIFICANT TRANSIENT: An UNPLANNED event based on EC judgment, but includes as a minimum any one of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, or (4) Safety Injection Activation. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SS6 Example EAL #1
2. SI(S2).OP-AB.ANN-0001(Q) Loss of Overhead Annunciator System
3. UFSAR 7.7.2.10 Plant Alarm and Annunciator Systems
4. UFSAR Table 7.7-2 Overhead Annunciator Grouping Salem Page 3 of 4 Rev. 0 (draft E)

EA L#: ISIS 15 A

SGS ECG - EAL Technical Bases EP-SC-1 11-217 This page intentionally blank, Salem Page 4 of 4 Rev. 0 (draft E) EAL#: 3J5o

SGS ECG - EAL Technical Bases EP-SC-1 11-218 EAL Category: S - System Malfunction EAL Subcategory: 6 - Communications Initiating Condition: Loss of all onsite or offsite communicati6ns capabilities Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SU6.1 - UNUSUAL EVENT EAL: Loss of all Table S-2 Onsite communication methods affecting the ability to perform routine operations OR Loss of all Table S-2 Offsite communication methods affecting the ability to perform offsite notifications Table S-2 Communications Systems System Onsite Offsite Direct Inward Dial System (DID) X X Station Page System (Gaitronics) X Station Radio System X Nuclear Emergency Telephone X System (NETS) Centrex Phone System (ESSX) X NRC (ENS) X Salem Page 1 of 4 Rev. 0 (draft E) EAL#:SU6o

SGS ECG - EAL Technical Bases EP-SC-1 11-218 Basis: The purpose of this EAL is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate issues with off-site authorities. The availability of one method of ordinary off-site communications is sufficient to inform federal, state, and local authorities of plant problems. This EAL is intended to be used only when extraordinary means (e.g., relaying of information from non-routine radio transmissions, individuals being sent to off-site locations, etc.) are being used to make communications possible. Explanation/Discussion/Definitions: Onsite and offsite communications include one or more of the systems listed in Table S-2. Direct Inward Dial System (DID) Direct Inward Dial (DID) system is named for the dominant feature of the com'm'ercial telephone service provided by the local telephone company for the site. DID allows station telephQn-es to.beextensions por tied. li.nes-of the.same systems. These exchanges can take advantage of. backup power supplies provided to the stations, and may use either PSEG microwave, commercial telephone system microwave, or buried cable transmission systems to maintain external.communications. This commercial telephone, service is available as an additional backup for the NETS and Centrex/ESSX 1 system.. Station Page System (Gaitronics) Gaitronics is a compl6tely transistoriz6d'/vice 6comirm(unicati-on system with five voice channels: one page and five party. The system is designed for use in extreme environmental conditions such as dust, moistu're, heat and noise. The system consists of handsets, speakers and their associated amplifiers. The power for this system is 120 volts AC from an inverted DC source to provide reliable communications during an emergency. Station Radio System The Operations and Fire Protection Department UHF radio system is a multi-frequency system used routinely by both station Operations Departments and the Fire Protection Department. When an emergency event is declared, these radiofrequencies serve both station Operations Support Centers (OSC).. Nuclear Emerqenc, Telephone Systerm (NETS) The Nuclear Emergency Telecommunications System (NETS) is a privately controlled, self-contained telephone exchange that operates as a closed system, not accessible from other phone exchanges. This feature allows the system to be dedicated to emergency response Salem Page 2 of 4 Rev. 0 (draft E) EAL#: S us.I

SGS ECG - EAL Technical Bases EP-SC-1 11-218 use. The system may use PSEG microwave, commercial telephone system microwave, fiber optics, or buried cable transmission as needed. The exchange switching equipment is maintained at the Environmental & Energy Resource Center (EERC). As an independent system with an uninterruptible power supply, it may operate with or without local phone service or external power. Centrex Phone System (ESSX) The Centrex/Electronic Switch System Exchange 1 (CentrexiESSX 1) is also a privately controlled exchange, which PSEG operates with its own microwave signal system. This system is also independent of local phone service, since each circuit is independently wired. The microwave signal is generated from corporate facilities in Newark, NJ, separated from any local effects of weather or telephone use. The exchange is accessible from other exchanges, but circuits are located only in PSEG facilities. It is considered the primary backup for the NETS system. NRC (ENS) The Emergency Notification System (ENS) is a dedicated communications system with the NRC, which is part of the Federal Telecommunications System (FTS) and consists of direct lines to the NRC. FTS lines are used to provide general accident information. These telephones are installed in the Control Room, TSC, and the EOF. This EAL is the hot condition equivalent of the cold condition EAL CU5.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU6 Example EAL #1, #2
2. PSEG Nuclear Emergency Plan, Section 7
3. UFSAR 9.5.2 Communications System Salem Page 3 of 4 Rev. 0 (draft E)

EAL#:SU(.1

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SGS ECG - EAL Technical Bases EP-SC-1 11-219 EAL Category: S - System Malfunction EAL Subcategory: 7 - Fuel Clad Degradation Initiating Condition: Fuel clad degradation Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SU7.1 - UNUSUAL EVENT EAL: VALID Letdown Line Monitor readings indicating fuel clad degradation greater than EITHER of the following Technical Specification allowable limits: o 1R31Ain warning o 2R31 in alarm Basis: This EAL is included because it is a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant. Escalation of this EAL to the ALERT level is via the Fission Product Barriers. This threshold addresses letdown radiation monitor readings that provide indication of a degradation of fuel clad integrity. Explanation/Discussion/Definitions: Letdown Line Monitors serve as a failed fuel detector by monitoring gamma levels in the reactor coolant letdown line. Unit 1 Letdown Line Monitor (1 R31A) is a gross iodine monitor. The Unit 2 Letdown Line Monitor (2R31) is an ion chamber which measures letdown line activity. The Letdown Line Monitor "warning" setpoints are administratively set at 50% of the "alarm" setpoints. o 1R31A "alarm" setpoint is based on 1% failed fuel. The "warning" setpoint represents about 0.5% failed fuel and has been selected because the setpoint would be readily identifiable on Control Room instrumentation. o 2R31 "alarm" setpoint is based on 0.1% failed fuel. This setpoint is readily identifiable and also representative of typical values of coolant activity at Technical Specification limits. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:SU7.1

SGS ECG - EAL Technical Bases EP-SC-1 11-219 Read-outs for these monitors can be obtained in the Control Room. Other radiation monitors that may be used to confirm a valid Letdown Line Monitor alarm include: o 1(2)R4 Charging Pump Room o 1(2)R26 Reactor Coolant Filter o Containment Area Rad Monitors (1(2)R2, 1(2)7, 1(2)1QA, 1(2)1OB) Definitions: VALIb: -An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU4 Example EAL #1
2. PSBP 315733 Radiation Monitoring System Manual, Unit 1
3. PSBP 315734 Radiation Monitoring System Control Manual, Unit 2
4. UFSAR 9.3.5:3 Safety Evaluation (*ailed fuel Detection System)
5. UFSAR 11.4 Radiological Monitoring
6. Sl(S2).OP-AB.RC-0002 (Q) High Activity in the Reactor Coolant System Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: S U7.1*

SGS ECG - EAL Technical Bases EP-SC-1 11-219 EAL Category: S - System Malfunction EAL Subcategory: 7 - Fuel Clad Degradation Initiating Condition: Fuel clad degradation Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SU7.2 - UNUSUAL EVENT EAL: Basis: This EAL is included because it is a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant. Escalation of this EAL to the ALERT level is via the Fission Product Barriers. This threshold addresses coolant samples exceeding coolant technical specifications for transient iodine spiking limits (Technical Specification Figure 3.4-1). Explanation/Discussion/Definitions: An Unusual Event is only warranted when actual fuel clad damage is the cause of the elevated coolant sample (as determined by RCS sample analysis confirmation). Escalation to an ALERT or higher emergency classification occurs if a sample analysis of reactor coolant activity exceeds 300 pCi/gm DEI-1 31 via EAL FB4-L. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU4Example EAL #2
2. SGS Technical Specification Section 3.4.8 - Unit 1 Specific Activity
3. SGS Technical Specification Section 3.4.9 - Unit 2 Specific Activity
4. Sl(S2).OP-AB.RC-0002(Q) High Activity in Reactor Coolant System Salem Page 1 of 2 Rev. 0 (draft E)

EAL#:SU7.2

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SGS ECG - EAL Technical Bases EP-SC-1 11-220 EAL Category: S - System Malfunction EAL Subcategory: 8 - RCS Leakage Initiating Condition: RCS Leakage Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Classification Level: SU8.1 - UNUSUAL EVENT EAL: UNIDENTIFIED LEAKAGE or PRESSURE BOUNDARY LEAKAGE > 10 gpm (Note 6) OR IDENTIFIED LEAKAGE > 25 gpm (Note 6) Note 6: See the Fission Product Barrier Table for possible escalation above the UNUSUAL EVENT due to RCS Leakage Basis: This EAL is included as a UE because it may be a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant. The 10 gpm.value for the UNIDENTIFIED or PRESSURE BOUNDARY LEAKAGE was selected as it is observable with normal Control Room indications. Lesser values must generally be determined through time-consuming surveillance tests (e.g., mass balances). Relief valve normal operation should be excluded from this EAL. However, a relief valve that operates and fails to close per design should be considered applicable to this EAL if the relief valve cannot be isolated. The EAL for identified leakage is set at a higher value due to the lesser significance of IDENTIFIED LEAKAGE in comparison to UNIDENTIFIED or PRESSURE BOUNDARY LEAKAGE. In either case, escalation of this EAL to the ALERT level is via Fission Product Barrier Degradation EALs. Explanation/Discussion/Definitions: RCS Leakage is defined as any leakage of Reactor Coolant this is unisolable or affects Pressurizer level. RCS Leakage of the magnitude described in this EAL is consistent with an Unusual Event classification and should be declared immediately. Salem Page 1 of 4 Rev. 0 (draft E) EAL#: SU o

SGS ECG - EAL Technical Bases EP-SC-1 11-220 The Technical Specification definitions for UNIDENTIFIED LEAKAGE, IDENTIFIED LEAKAGE and PRESSURE BOUNDARY LEAKAGE are provided below. Relief valve normal operation (e.g., PZR PORV or safety valves) should be excluded from emergency classification under this EAL. A relief valve that fails to close per design and cannot be isolated from the Control Room, however, should be considered applicable to this EAL. Utilizing the leak before break concept, it is anticipated that there will be indications of minor RCS boundary leakage prior to a fault escalating to a major leak or rupture. Detection of low levels of leakage while pressurized piermits monitoring for catastrophic failure or rupture precursors. The Control Room staff is equipped with the Plant Computer (PRIM SYS LEAKRATE program) and manual methods 'of determining the extent of RCS leakage. Examples of RCS leakage and applicability include: Example #1: A rapidly lowering Volume Control Tank (VCT) level: is'identified during a-: Radwaste e.volution i.nvolving the draining of..the. #12 Mixed Bed D-emineralizer (MBD). The Control Room' staff identifies the Cdondition and the drain valve on the MBD is closed. Charging flow has not changed and VCT level is stabilized within 3 minutes. The calculated leak rate is 73 gpm for 3minutes: ...... ...... ...... This is not reportablebecause the leakage did not affect pressurizerlevel and the leak,' was isolable from the RCS.. Note that Tech Spec limits still apply. Example #2: A Unit 2 RCS leakrate calculation identified a 30-gpm leak. VCT level has started. to drop unexpectedly and enough time has passed. that there are minor variations in pressurizer level. The source of the leak is unknown. After about 20 minutes, it was determined that the source of the leak was the stem leakoff line from the 2CV55.- 

      .. This eveht should be classified within the 15 minute-clock'and declared-'an'Unusual Event even though the leak could have been isolated.Any reduction in pressurizer.

level, which can be attributedto a Reactor Coolant System leak should be quantified' and the Technical Specification entered and the applicable EAL entered as appropriate. The,Use of increasingcharging flo. to quantfy Reactor Colant System leakage is acceptable provided there is an actual Reactor Coolant System leak. This -couldresult in'a stable pressurizer'leveland should be reviewed against Technical Specifications and the ECG as applicable. If at any time the source of the leakage is unknown and it meets the ECG criteria, the Emergency Coordinatorshould classify the event. Escalation to the ALERT emergency classification level is via EALs in Category F. Note 6 has been added to remind the. EAL-user to review the Fission Product Barrier EALs for possible escalation to higher emergency classifications. Definitions: Salem Page 2 of 4 Rev. 0 (draft E) EAL#:SU8,

SGS ECG - EAL Technical Bases EP-SC-1 11-220 UNIDENTIFIED LEAKAGE: As defined in T/S, shall be all leakage which is not IDENTIFIED LEAKAGE. PRESSURE BOUNDARY LEAKAGE: As defined in T/S, shall be leakage (except steam generator tube leakage) through a non-isolable fault in a Reactor Coolant System component body, pipe wall or vessel wall. IDENTIFIED LEAKAGE: As defined in T/S, shall be leakage (except Reactor Coolant Pump Seal Water Injection) into closed systems, such as pump seal or valve packing leaks that are captured and conducted to a sump or collecting tank, or, shall be leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of the leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE, or, shall be Reactor coolant system leakage through a steam generator to the secondary system (primary-to-secondary leakage). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SU4 Example EAL #2
2. Technical Specifications, Definitions
3. Technical Specifications 3.4.6.2 - Unit 1 Operational Leakage
4. Technical Specifications 3.4.7.2 - Unit 2 Operational Leakage
5. UFSAR 5.2.7.2 Indication in Control Room
6. S1(S2).OP-AB.RC-0001(Q) Reactor Coolant System Leak
7. S1(S2).OP-SO.RC-0004(Q) Identifying and Measuring Leakage
8. SC.RA-AP.ZZ-0051 Leakage Monitoring and Reduction Program
9. S1(S2).OP-ST.RC-0008(Q) Reactor Coolant System Water Inventory Balance Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: SU ,

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EAL s foro Fassion F0 0 Produc~t Barrie(rs

SGS ECG - EAL Technical Bases E P-SC- 111 -221 EAL Category: F - Fission Product Barrier Degradation Subcategory: CFSTs Initiating Condition: Potential Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FBI-P (4 points) EAL: CFST Core Cooling PURPLE path exists Basis: Core Cooling PURPLE indicates subcooling has been lost and that some clad damage may occur. Explanation/Discussion/Definitions: CFST status will not be used for event classification until the Control Room staff has implemented the CFSTs. The Core Cooling CFST is illustrated in Attachment 2, page 4. Adverse Containment setpoints appear in the Heat Sink CFST. Adverse Containment conditions exist if Containment pressure exceeds 4 psig or R44 Containment radiation dose rates exceed 1 E05 R/hr or R44 dose exceeds 1 E06 R. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Potential Loss 1.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree
3. NC.EP-EP.ZZ-0201 (Q) TSC - Integrated Engineering Response Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: FBI]P

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SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: CFSTs Initiating Condition: Potential Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB2-P (4 points) EAL: Basis: Heat Sink RED when heat sink is required indicates the ultimate heat sink function is under extreme challenge. Explanation/Discussion/Definitions: CFST Heat Sink RED Path entry conditions affects both the Fuel Clad and RCS Barriers. Therefore, minimum classification would be SAE. A barrier loss classification should not be made if the Heat Sink RED Path is the result of procedurally required Auxiliary Feedwater Flow control. CFST status will not be used for event classification until the Control Room staff has implemented the CFSTs. The Heat Sink CFST is illustrated in Attachment 2, page 6. Adverse Containment setpoints appear in the Heat Sink CFST. Adverse Containment conditions exist if Containment pressure exceeds 4 psig or R44 Containment radiation dose rates exceed 1E05 R/hr or R44 dose exceeds 1E06 R. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Potential Loss 1 .B
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.03 Heat Sink Status Tree
3. 1(2)-EOP-FRHS-1 Response to Loss of Secondary Heat Sink
4. NC.EP-EP.ZZ-0201 (Q) TSC - Integrated Engineering Response Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: FB2oP

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SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: Core Exit TCs Initiating Condition: Potential Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB3-P (4 points) EAL: 5 or more CETs > 700°F Basis: The five core exit thermocouple (CET) temperatures > 700°F indicates a loss of subcooling. Explanation/Discussion/Definitions: Core exit thermocouple (CET) readings greater than 700'F signal a CFST Core Cooling PURPLE path condition. CET readings are used as a fission product barrier threshold in addition to the CFST thresholds to address events in which the CFSTs may not yet be in use. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Potential Loss 3.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: FB3-P

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SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Potential Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB4-P (4 points) EAL: RVLIS < Table F-1 thresholds Table F-1 RVLIS Thresholds RVLIS RCPs Full Range 39% None 44% 4 30% 3 Dynamic Range 20% 2 13% 1 Basis: There is no Loss threshold associated with this item. The specific values for the Potential Loss thresholds correspond to approximately the top of the active fuel. Explanation/Discussion/Definitions: The specified RVLIS readings (Table F-1) and the associated number of running RCP pumps are used in the CFSTs to signal core uncovery and are, therefore, indication of inadequate coolant inventory. If the RVLIS thresholds are exceeded, a core covered condition cannot be confirmed. According to the CFST Core Cooling PURPLE path, this water level indicates subcooling has been lost and that some fuel clad damage may occur. RVLIS readings are used as a fission product barrier threshold in addition to the CFST thresholds to address events in which the CFSTs may not yet be in use. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: FIB4-P

SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Potential Loss 4.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: F[4 ,

SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: EC Judgment Initiating Condition: Potential Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB5-P (4 points) EAL: ANY condition in the opinion of the Emergency Coordinator that indicates potential loss of the Fuel Clad barrier Basis: This threshold addresses any other factors that are to be used by the Emergency Coordinator in determining whether the Fuel Clad barrier is potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this threshold as a factor in Emergency Coordinator judgment that the barrier may be considered potentially lost. Explanation/Discussion/Definitions: The Emergency Coordinator judgment threshold addresses any other factors relevant to determining if the Fuel Clad barrier is potentially lost. Such a determination should include IMMINENT barrier degradation, barrier monitoring capability and dominant accident sequences. o Barrier degradation exists if the degradation will likely occur within two hours based on a projection of current safety system performance. o Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration of offsite monitoring results. o Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of AC power (Station Blackout) and ATWT EALs to assure timely emergency classification declarations. Salem Page 1 of 2 Rev. 3(draft E) EAL#: FB5-P

SGS ECG - EAL Technical Bases EP-SC- 111-221 Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):.

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Potential Loss 8.A Salem Page 2 of 2 Rev. 3(draft E)

EAL#: [*[5-Fl

SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: CFSTs Initiating Condition: Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FBI-L (5 points) EAL: CFST Core Cooling RED path exists Basis: Core Cooling RED indicates significant superheating and core uncovery and is considered to indicate loss of the Fuel Clad Barrier. Explanation/Discussion/Definitions: CFST status will not be used for event classification until the Control Room Staff has implemented the CFSTs. The Core Cooling CFST is illustrated in Attachment 2, page 4. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Loss 1.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: FBI L

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SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: Core Exit TCs Initiating Condition: Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB2-L (5 points) EAL: 5 or more CETs > 1200'F Basis: The five core exit thermocouple (CET) temperatures > 1200°F indicates significant superheating of the coolant. Explanation/Discussion/Definitions: Core exit thermocouple (CET) readings greater than 1,200'F signal a CFST Core Cooling RED path condition. CET readings are used as a fission product barrier threshold in addition to the CFST thresholds to address events in which the CFSTs may not yet be in use. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Loss 3.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: FB2oL

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SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: Radiation Initiating Condition: Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB3-L (5 points) EAL: Containment radiation monitor R44A or R44B reading > 300 RPhr Basis: The site specific reading is a value which indicates the release of reactor coolant, with elevated activity indicative of fuel damage, into the containment. Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within technical specifications and are therefore indicative of fuel damage. This value is higher than that specified for RCS barrier Loss RB1-L. Thus, this threshold indicates a loss of both the Fuel Clad barrier and RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency. There is no Potential Loss threshold associated with this item. Explanation/Discussion/Definitions: 1(2)R44A and 1(2)R44B are the Containment High Range area radiation monitors. The threshold value of 300 R/hr has been calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration of 300 pCi/gm Dose Equivalent 1-131 into the Containment atmosphere. 300 pCi/gm Dose Equivalent Iodine-1 31 (DEI-1 31) corresponds to approximately 2.8% fuel clad damage. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Loss 6.A
2. Calculation by Nuclear Fuels Group file title DS1.6-0098 "Verification of Emergency Action Levels for Event Classification" date 02/10/95 Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: FIB3oL

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SGS ECG - EAL Technical Bases E P-SC- 111 -221 EAL Category: F - Fission Product Barrier Degradation Subcategory: Other Initiating Condition: Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB4-L (5 points) EAL: Coolant activity> 300 pCi/gm dose equivalent 1-131 Basis: The site specific value is 300 ItCi/gm dose equivalent 1-131. Assessment by the NEI EAL Task Force indicates that this amount of coolant activity is well above that expected for iodine spikes. This amount of radioactivity indicates significant clad damage and thus the Fuel Clad Barrier is considered lost. There is no Potential Loss threshold associated with this item. Explanation/Discussion/Definitions: The threshold value of 300 pCi/gm Dose Equivalent lodine-1 31 (DEl-1 31) is based upon an engineering calculation and corresponds to approximately 2.8% fuel clad damage. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Loss 2.A
2. Calculation by Nuclear Fuels Group file title DS1.6-0098 "Verification of Emergency Action Levels for Event Classification" date 2/10/95
3. S1(S2).OP-AB.RC-0002 (Q) High Activity in Reactor Coolant System Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: FB4oL

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SGS ECG - EAL Technical Bases EP-SC-1 11-221 EAL Category: F - Fission Product Barrier Degradation Subcategory: EC Judgment Initiating Condition: Loss of Fuel Clad Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: FB5-L (5 points) EAL: Basis: This threshold addresses any other factors that are to be used by the Emergency Coordinator in determining whether the Fuel Clad barrier is lost. In addition, the inability to monitor the barrier should also be incorporated in this threshold as a factor in Emergency Coordinator judgment that the barrier may be considered lost. Explanation/Discussion/Definitions: The Emergency Coordinator judgment threshold addresses any other factors relevant to determining if the Fuel Clad barrier is lost. Such a determination should include IMMINENT barrier degradation, barrier monitoring capability and dominant accident sequences. o Barrier degradation exists if the degradation will likely occur within two hours based on a projection of current safety system performance.

  • Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators.

This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration of offsite monitoring results.

  • Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of AC power (Station Blackout) and ATWT EALs to assure timely emergency classification declarations.

Salem Page 1 of 2 Rev. 0 (draft E) EAL#: F oL

SGS ECG - EAL Technical Bases EP-SC-1 11-221 Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless.a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Fuel Clad Loss 8.A Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: F[5-[L

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: Isolation Initiating Condition: Potential Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RB1-P (4 points) EAL: CFST Thermal Shock RED path exists Basis: RCS Thermal Shock RED indicates an extreme challenge to the safety function derived from appropriate instrument readings. There is no Loss threshold associated with this item. Explanation/Discussion/Definitions: CFST status will not be used for event classification until the Control Room staff has implemented the CFSTs. The Thermal Shock CFST is illustrated in Attachment 2, pages 7 and

8. The Heat Sink CFST is illustrated in Attachment 2, page 6. Adverse Containment setpoints appear in the Heat Sink CFST. Adverse Containment conditions exist if Containment pressure exceeds 4 psig or R44 Containment radiation dose rates exceed 1 E05 R/hr or R44 dose exceeds 1E06 R.

EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Barrier Potential Loss 1.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.04 Thermal Shock Status Tree
3. NC.EP-EP.ZZ-0201 (Q) TSC - Integrated Engineering Response Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: RBI* 'P

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SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: Isolation Initiating Condition: Potential Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RB2-P (4 points) EAL: Basis: Heat Sink RED when heat sink is required indicates the ultimate heat sink function is under extreme challenge. There is no Loss threshold associated with this item. Explanation/Discussion/Definitions: CFST Heat Sink RED Path entry conditions affects both the Fuel Clad and RCS Barriers. Therefore, minimum classification would be SAE. A barrier loss classification should not be made if the Heat Sink RED Path is the result of procedurally required Auxiliary Feedwater Flow control. CFST status will not be used for event classification until the Control Room staff has implemented the CFSTs. The Thermal Shock CFST is illustrated in Attachment 2, pages 7 and

8. The Heat Sink CFST is illustrated in Attachment 2, page 6. Adverse Containment setpoints appear in the Heat Sink CFST. Adverse Containment conditions exist if Containment pressure exceeds 4 psig or R44 Containment radiation dose rates exceed 1E05 PJhr or R44 dose exceeds 1E06 R.

Salem Page 1 of 2 Rev. 0 (draft E) EAL#: RB2P

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Barrier Potential Loss 1.B
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.03 Heat Sink Status Tree
3. 1(2)-EOP-FRHS-1 Response to Loss of Secondary Heat Sink
4. NC.EP-EP.ZZ-0201 (Q) TSC - Integrated Engineering Response Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: RB2-P

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Potential Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RB3-P (4 points) EAL: Basis: This threshold is based on the apparent inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control System which is considered to be the flow rate equivalent to one charging pump discharging to the charging header. Minimizing letdown is a standard abnormal operating procedure action and may prevent unnecessary classifications when a non-RCS leakage path such as a CVCS leak exists. The intent of this condition is met if the leak is in Letdown and attempts to isolate Letdown are NOT successful. Additional charging pumps being required is indicative of a substantial RCS leak. Explanation/Discussion/Definitions: Significant leakage from the RCS requires implementation of S1 (S2).OP-AB.RC-0001(Q). Actions required by this procedure specify the use of one Centrifugal Charging Pump, discharging to the charging header, and Letdown reduced to a minimum. If RCS leakage results in an inability to maintain the specified Pressurizer (PZR) level with a normal charging lineup and minimum Letdown flow using one Centrifugal Charging Pump, an RCS inventory loss is occurring that would require initiation of Reactor Trip and Safety Injection (SI) and entry into EOP-TRIP-1. This RCS Potential Loss assumes that any event that would result in significant RCS mass loss will require at least an Alert emergency classification. Non-RCS leakage events (such as steam or feedwater system breaks) in which no mass is lost from the RCS should not be classified under this RCS barrier Loss. SGTRs that result in entry into 1(2)-EOP-SGTR-1 shall be classified under RCS Barrier Loss RB3-L. If a SGTR does not result in 1(2)-EOP-SGTR-1 entry, it should be classified as a minimum under this RCS barrier Potential Loss if PZR level cannot be maintained above 17%. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:RB3-P

SGS ECG " EAL Technical Bases EP-SC-1 11-222 When PZR level drops to 17%, Letdown isolates and pressurizer heaters deenergize. This condition is signaled by overhead annunciatorE-36, PZR HTR OFF LVL LO. Pressurizer level is indicated on LI-459A, LI-460A, LI-461, associated computer points and SPDS. The design flowrate of one centrifugal charging pump is 150 gpm. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Barrier Potential Loss 2.A
2. S1(S2).OP-AB.RC-0001(Q) Reactor Coolant System Leak
3. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
4. 1(2)-EOP-SGTR-1 Steam Generator Tube Rupture
5. S1(S2).OP-AR.ZZ-0005(Q) OHA E-36, PZR HTR OFF LVL LO
6. SI(S2).OP-SO.CVC-0002(Q) ChargingPump Operation Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:RB3-P

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: EC Judgment Initiating Condition: Potential Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RB4-P (4 points) EAL: ANY condition in the opinion of the Emergency Coordinator that indicates potential loss of the RCS barrier Basis: This threshold addresses any other factors that are to be used by the Emergency Coordinator in determining whether the RCS barrier is I potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this-threshold as a factor in Emergency Coordinator judgment that the barrier may be considered potentially lost. Explanation/Discussion/Definitions: The Emergency Coordinator judgment threshold addresses any other factors relevant to determining if the RCS barrier is potentially lost. Such a determination should include IMMINENT barrier degradation, barrier monitoring capability and dominant accident sequences. o Barrier degradation exists if the degradation will likely occur within two hours based on a projection of current safety system performance. o Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration of offsite monitoring results. o Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of AC power (Station Blackout) and ATWT EALs to assure timely emergency classification declarations. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:RB4=P

SGS ECG -EAL Technical Bases EP-SC-1 11 -222 Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Potential Loss 8.A Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:RB4-P

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: Radiation Initiating Condition: Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RBI-L (5 points) EAL: ANY of the following Containment radiation monitor readings: o 1(2)R2 > 1000 mR/hr o 1(2)R44A > 10 PRhr 1(2)R44B > 10 R/hr Basis: The readings are values which indicate the release of reactor coolant to the containment. The readings will be less than that specified for Fuel Clad barrier threshold FB3-L. Thus, this threshold would be indicative of a RCS leak only. If the radiation monitor reading increased to that specified by Fuel Clad barrier threshold, fuel damage would also be indicated. There is no Potential Loss threshold associated with this item. Explanation/Discussion/Definitions: 130' Containment Area Rad Monitor 1(2)R2 has an instrument scale range of 0.1 mR/hr to 10 RJhr and, therefore, offers the preferred method of assessing this RCS Barrier Loss. 1 R/hr on this monitor is indicative of the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with Technical Specification concentrations into the Containment atmosphere. These readings are less than that specified for Fuel Clad Barrier Loss FB3-L since this EAL attempts to identify RCS leakage assuming RCS activity is at the Technical Specification limit. I Classification under this EAL should not be made based upon crud burst evolutions or other non-RCS leakage events. I Salem Page 1 of 2 Rev. 0 (draft E) EAL#: RB 1] L

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Barrier Loss 6.A
2. Calculation by Nuclear Fuels Group file title DS1.6-0098 "Verification of Emergency Action Levels for Event Classification" date 2/10/95 Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:RBI -L

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RB2-L (5 points) EAL: Subcooling < 0°F (as a result of RCS leakage) Basis: This threshold addresses conditions where leakage from the RCS is greater than available inventory control capacity such that a loss of subcooling has occurred. The loss of subcooling is the fundamental indication that the inventory control systems are inadequate in maintaining RCS pressure and inventory against the mass loss through the leak. Explanation/Discussion/Definitions: RCS subcooling of 0°F or less is a criterion in the CFST Core Cooling YELLOW path (or higher) and is monitored in the Continuous Action Summary (CAS). Subcooling is indicated in the Control Room on Subcooling Margin Monitor Channel A and Channel B. This threshold focuses on RCS inventory loss due to LOCA conditions. Non-RCS leakage events (such as steam or feedwater system breaks) in which no mass is lost from the RCS should not be classified under this RCS barrier Loss. Subcooling equal to or less than 0°F is indication that leakage from the RCS barrier is greater than the available inventory control capacity. This threshold does not apply to primary-to-secondary leakage events since adequate injection capability should be available for the spectrum of such events including Steam Generator Tube Rupture (SGTR). Refer to RCS barrier Loss RB3-L for SGTR. EOP directed actions resulting in deliberate subcooling reduction (e.g. during SGTR saturated recovery), steam/feedwater line breaks, or momentary reductions below 0°F that are recoverable (e.g. Sl flow reduction sequence) should not be classified under this EAL. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Barrier Loss 2.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: IBI2-L

SGS ECG - EAL Technical Bases EP-SC-1 11-222 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#:RB2-L

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RB3-L (5 points) EAL: SGTR requiring ECCS (SI) Actuation Basis: This threshold addresses the full spectrum of Steam Generator (SG) tube rupture events in conjunction with Containment barrier Loss thresholds. It addresses RUPTURED SG(s) for which the leakage is large enough to cause actuation of ECCS (SI). This is consistent to the RCS leak rate barrier Potential Loss threshold. By itself, this threshold will result in the declaration of an Alert. However, if the SG is also FAULTED (i.e., two barriers failed), the declaration escalates to a Site Area Emergency per Containment barrier Loss thresholds. There is no Potential Loss threshold associated with this item. Explanation/Discussion/Definitions: This EAL is indicative of a loss of RCS inventory due to a Steam Generator Tube Rupture (SGTR) in which the leakage is large enough to cause actuation of Safety Injection (SI). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Barrier Loss 4.A
2. 1(2)-EOP-SGTR-1 Steam Generator Tube Rupture
3. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: RB3-L

SGS ECG - EAL Technical Bases EP-SC-1 11 -222 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: RB3-L

SGS ECG - EAL Technical Bases EP-SC-1 11-222 EAL Category: F - Fission Product Barrier Degradation Subcategory: EC Judgment Initiating Condition: Loss of RCS Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: RB4-L (5 points) EAL: Basis: This threshold addresses any other factors that are to be used by the Emergency Coordinator in determining whether the RCS barrier is lost. In addition, the inability to monitor the barrier should also be incorporated in this threshold as a factor in Emergency Coordinator judgment that the barrier may be considered lost. Explanation/Discussion/Definitions: The Emergency Coordinator judgment threshold addresses any other factors relevant to determining if the RCS barrier is lost. Such a determination should include IMMINENT barrier degradation, barrier monitoring capability and dominant accident sequences. o Barrier degradation exists if the degradation will likely occur within two hours based on a projection of current safety system performance. o Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration of offsite monitoring results. o Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of AC power (Station Blackout) and ATWT EALs to assure timely emergency classification declarations. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: RIB4oL

SGS ECG - EAL Technical Bases EP-SC-1 11-222 Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 RCS Loss 8.A Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:RB4-L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: CFSTs Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB1-P (2 points) EAL: CFST Containment RED path exists Basis: RED path indicates an extreme challenge to the safety function derived from appropriate instrument readings and/or sampling results, and thus represents a potential loss of containment. Conditions leading to a Containment RED path result from RCS barrier and/or Fuel Clad Barrier Loss. Thus, this threshold is primarily a discriminator between Site Area Emergency and General Emergency representing a potential loss of the third barrier. There is no Loss threshold associated with this item. Explanation/DiscussionlDefinitions: Critical Safety Function Status Tree (CFST) Containment RED path exists if Containment pressure is greater than or equal to 47 psig. The Containment RED path is in the Containment Environment CFST illustrated in Attachment 2, page 9. Containment pressure of this magnitude results from RCS barrier loss or a faulted S/G inside Containment and signifies an extreme challenge to the Containment. For this condition, all Containment isolations, as well as automatic Containment Spray and CFCU "low speed" operation should be initiated before this threshold is reached. The Containment barrier is considered potentially lost at 47 psig even though the Containment yield strength is much higher that 47 psig. Thus, this threshold is primarily a discriminator between a Site Area Emergency and a General Emergency (i.e., a potential loss of the third barrier). CFST status will not be used for event classification until the Control Room staff has implemented the CFSTs. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CBI]P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 1.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.05 Containment Environment Status Tree
3. UFSAR 6.2 Containment Systems
4. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: CS] -P

SGS ECG - EAL Technical BasesS EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: CFSTs Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB2-P (2 points) EAL: CFST Core Cooling RED path exists AND Restoration procedure 1(2)EOP-FRCC-1 NOT effective within 15 minutes Basis: See discussion below. Explanation/Discussion/Definitions: CFST status will not be used for event classification until the Control Room Staff has implemented the CFSTs. The Core Cooling CFST is illustrated in Attachment 2, page 4. This threshold is redundant to Containment Barrier Potential Losses CB3-P and CB-4P. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 1.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Tree - F.02 Core Cooling Status Tree
3. UFSAR 6.2 Containment Systems
4. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: CB2-P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#:CB2[P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Core Exit TCs Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB3-P (2 points) EAL: Basis: There is no Loss threshold associated with this item. The conditions in these thresholds represent an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. In conjunction with the Core Cooling and RCS Leakage criteria in the Fuel and RCS barrier columns, this threshold would result in the declaration of a General Emergency -- loss of two barriers and the potential loss of a third. If the function restoration procedures are ineffective, there is no "success" path. The function restoration procedures are those emergency operating procedures that address the recovery of the core cooling critical safety functions. The procedure is considered effective if the temperature is decreasing or if the vessel water level is increasing. Whether or not the procedures will be effective should be apparent within 15 minutes. The Emergency Coordinator should make the declaration as soon as it is determined that the procedures have been, or will be ineffective. Explanation/Discussion/Definitions: If core exit thermocouple (CET) readings are greater than 1,200'F, Fuel Clad barrier is lost. CETs provide an indirect indication of fuel clad t~mperature by measuring the temperature of the reactor coolant that leaves the core region. Although clad rupture due to high temperature is not expected for CET readings less than the threshold, temperatures of this magnitude Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CB3-P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 signal significant superheating of the reactor coolant and core uncovery. Events that result in CET readings above the loss threshold are severe accidents and are a severe accident management "Badly Damaged (BD)" condition. The BD descriptor signifies possible core overheating to the point that clad ballooning/collapse may occur and portions of the core may have melted. Severe accident analysis has concluded that functional restoration procedures 66n arrest core degradation within the Reactor Vessel in a significant fraction of the scenarios, and that the likelihood of Containment failure in these scenarios is small. It is appropriate; therefore, to allow a reasonable period of time for the functional restoration procedures to arrest the core melt sequence. The functional restoration procedure, 1(2)-EOP-FRCC-1, is the emergency operating procedures that address the. recovery an inadequate core cooling condition. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information. indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 3.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree
3. 1(2)-EOP-FRCC-1 Response to Inadequate Core Cooling Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CB3-F

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Core Exit TCs Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB4-P (2 points) EAL: ALL of the following: o 5 or more CETs > 700°F o RVLIS < Table F-1 thresholds o Restoration procedure 1(2)EOP-FRCC-1 NOT effective within 15 minutes Table F-I RVLIS Thresholds RVLIS RCPs Full Range 39% None 44% 4 30% 3 Dynamic Range 20% 2 13% 1 Basis: There is no Loss threshold associated with this item. The conditions in these thresholds represent an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. In conjunction with the Core Cooling and RCS Leakage criteria in the Fuel and RCS Barrier columns, this threshold would result in the declaration of a General Emergency -- loss of two Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CB4=P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 barriers and the potential loss of a third. If the function restoration procedures are ineffective, there is no "success" path. The function restoration procedures are those emergency operating procedures that address the recovery of the core cooling critical safety functions. The procedure is considered effective if the temperature is decreasing or if the vessel water level is increasing. Whether or not the procedures will be effective should be apparent within 15 minutes. The Emergency Coordinator should make the declaration as soon as it is determined that the procedures have been, or will be ineffective. Explanation/Discussion/Definitions: This threshold indicates subcooling has been lost (CET readings > 700 0 F), the core is uncovered and some fuel clad damage may be occurring. The Table F-I RVLIS thresholds are used in the CFSTs to signal core uncovery and are, therefore, indication of loss of coolant inventory. If the RVLIS thresholds are exceeded, a core covered condition cannot be confirmed. Severe, accident analysis has concluded that functional restoration procedures can.arrest core degradation within the Reactor Vessel in a significant fraction of the scenarios, and that the likelihood of Containment failure in these scenarios is small..It is appropriate; therefore, to allow a reasonable period of time for the functional restoration procedures to arrest the core melt sequence. The functional restoration procedure, 1(2)-EOP-FRCC-1, is the emergency operating procedures that address the recovery an inadequate core cooling condition Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05,jTable 5-F-3 Containment Potential Loss 3.B
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.02 Core Cooling Status Tree
3. 1(2)-EOP-FRCC-1 Response to Inadequate Core Cooling Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CB4oP

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Radiation Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB5-P (2 points) EAL: Containment radiation monitor 1(2)R44A or 1(2)R44B. reading > 2000 R/hr Basis: There is no Loss threshold associated with this item. The reading is a value which indicates significant fuel damage well in excess of the thresholds associated with both loss of Fuel Clad and loss of RCS Barriers. As stated in NEI 99-01 Section 3.8, a major release of radioactivity requiring off-site protective actions from core damage is not possible unless a major failure of fuel cladding allows radioactive material to be released from the core into the reactor coolant. Regardless of whether Containment is challenged, this amount of activity in Containment, if released, could have such severe consequences that it is prudent to treat this as a Potential Loss of Containment, such that a General Emergency declaration is warranted. Explanation/Discussion/Definitions: 1(2)R44A and 1(2)R44B are the Containment High Range area radiation monitors. The threshold value of 2000 R/hr has been calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with 20% fuel clad damage into the Containment atmosphere. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 6.A
2. Calculation by Nuclear Fuels Group file title DS1.6-0098 "Verification of Emergency Action Levels for Event Classification" date 2/10/95 Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: CB5-P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: CB5-F

SGS ECG - EAL Technical Bases EP-SC-1 11 -223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB6-P (2 points) EAL: Containment pressure > 47 psig and rising Basis: The specific pressure is based on the containment design pressure. Explanation/Discussion/Definitions: The specified Containment pressure (47 psig) is the Containment design pressure. Proper actuation and operation of the Containment heat removal system when required should avoid Containment pressures in excess of this threshold. The threshold is therefore indicative of a loss of both RCS and Fuel Clad barriers in that it should not be exceeded without severe core degradation (metal-water reaction) or failure to trip in combination with RCS breach. This condition would be expected to require the declaration of a General Emergency. Containment Pressure is used as a Containment Barrier threshold in addition to the CFST thresholds to address events in which the CFSTs may not yet be in use. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 2.A
2. 1(2)-EOP-CFST-1 Critical Safety Function Status Trees - F.05 Containment Environment Status Tree
3. Salem EOP Setpoint Basis Document - Vendor Doc. #320832 Salem Page 1 of 2 Rev. 0 (draft E)

EAL#:CB -

SGS ECG - EAL Technical Bases EP-SC-1 11-223 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#:CB6-[P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB7-P (2 points) EAL: Indications of > 4% H 2 inside Containment Basis: Existence of an explosive mixture means a hydrogen and oxygen concentration of at least the lower deflagration limit curve exists. The indications of potential loss under this EAL correspond to some of those leading to the RED path in Containment barrier Potential Loss CB1-P. Explanation/Discussion/Definitions: When hydrogen concentration in the Containment atmosphere exceeds 4%, the possibility of an explosive mixture exists. Elevated hydrogen concentrations are likely to be present in the Containment only as a result of an inadequate core cooling, substantial metal-water reaction and a breach of the RCS barrier. A 4% mixture of H 2 with normal Containment atmosphere represents the deflagration lower limit. Any subsequent ignition and burn of this level mixture releases a substantial amount of energy that must be absorbed by the Containment structure, which is already under stress due to the Loss of the RCS Barrier. Elevated Containment atmosphere hydrogen concentration is alarmed at >-2% by overhead annunciator C-23, CNTMT H 2 LVL HI. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CB7oP

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 2.B
2. 1(2)-EOP-FRCC-1 Response to Inadequate Core Cooling - Basis Document (pg 16)
3. Salem EOP Setpoint Basis Document - Vendor Doc. #320832
4. S1(S2).OP-AR.ZZ-0003(Q) OHA C-23, CNTMT H 2 LVL HI Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: CB7oP

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB8-P (2 points) EAL: Containment pressure > 15 psig AND EITHER of the following:

  • NO Containment Spray Train in service AND
     <5 CFCUs running in low speed o  One Containment Spray Train in service AND
     < 3 CFCUs running in low speed Basis:

This threshold represents a Potential Loss of Containment in that the Containment heat removal/depressurization system is either lost or performing in a degraded manner, as indicated by Containment pressure greater than the setpoint at which the equipment was supposed to have actuated. Explanation/Discussion/Definitions: A Containment pressure rise above 15 psig (the Containment Spray initiation setpoint) indicates a major release of energy to the Containment. No Containment Spray with fewer than five Containment Fan Coil Units (CFCUs) running in low speed or only one train of Containment Spray in service with fewer than 3 CFCUs running in low speed indicates a condition in which systems designed for Containment heat removal and depressurization do not have the capacity to maintain Containment pressure below the structural design limit. The Containment Fan Cooling System is designed to circulate and cool the Containment atmosphere in the event of a LOCA and thereby ensures that Containment pressure will not Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CBS P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 exceed its design value. Five fan-cooler units are capable of transferring heat from the Containment atmosphere at the post-accident design conditions. The UFSAR accident analyses determined a minimum of three fan-cooler units with at least one Containment Spray train is needed to maintain Containment integrity. Either of two Containment Spray trains containing a pump, associated valving and spray headers are independently capable of delivering 2,600 gpm. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 2.C
2. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
3. SGS Technical Specifications 3.6.2.1 Spray Additive System
4. SGS Technica I-Specifications 3.6.2.3 Co ntainment Cooling System
5. UFSAR 6.2.2.1 Containment Spray System
6. UFSAR 6.2.2.2 Containment Fan Cooling System Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: Q98°P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Judgment Initiating Condition: Potential Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB9-P (2 points) EAL: ANY condition in the opinion of the Emergency Coordinator that indicates potential loss of the Containment barrier Basis: This threshold addresses any other factors that are to be used by the Emergency Coordinator in determining whether the Containment barrier is potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this threshold as a factor in Emergency Coordinator judgment that the barrier may be considered potentially lost. The Containment barrier should not be declared potentially lost based on exceeding Technical Specification action statement criteria, unless there is an event in progress requiring mitigation by the Containment barrier. When no event is in progress (Loss or Potential Loss of either Fuel Clad and/or RCS) the Containment barrier status is addressed by Technical Specifications. Explanation/Discussion/Definitions: The Emergency Coordinator judgment threshold addresses any other factors relevant to determining if the Containment barrier is potentially lost. Such a determination should include IMMINENT barrier degradation, barrier monitoring capability and dominant accident sequences. o Barrier degradation exists if the degradation will likely occur within two hours based on a projection of current safety system performance. o Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration I of offsite monitoring results. o Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CBgoP

SGS ECG - EAL Technical Bases EP-SC-111-223 AC power (Station Blackout) and ATWT EALs to assure timely emergency classification declarations. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not 

     - expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified).

EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Potential Loss 8.A Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: cBg°P

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB1-L (3 points) EAL: Basis: Rapid unexplained loss of pressure (i.e., not attributable to containment spray or condensation effects) following an initial pressure increase from a primary or secondary high energy line break indicates a Loss of Containment integrity. This indicator relies on operator recognition of an unexpected response for the condition and therefore does not have a specific value associated with it. The unexpected response is important because it is the indicator for a Containment bypass condition. Explanation/Discussion/Definitions: The term "Unexplained" signifies the pressure drop is not a result of operator actions taken to reduce Containment pressure. The term "rapid" indicates the Containment breach is relatively large. For cases in which secondary coolant provides the source of energy that raised Containment pressure, a faulted Steam Generator is possible. This event would require actions in 1(2)- EOP-LOSC-1 to isolate the Main Steam lines, maintain intact Steam Generators for an RCS Heat Sink, minimize Containment pressure, and minimize RCS cooldown. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CBI]b

SGS ECG - EAL Technical Bases EP-SC-111-223 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Barrier Loss 2.A
2. UFSAR Table 15.4-22 LOCA Containment Response Results (Loss of Offsite Power Assumed)
3. UFSAR Figures 15.4-43a, b and c Containment Pressure (varying initial conditions)
4. UFSAR Figure 15.4-44 Containment Pressure
5. 1(2)-EOP-LOSC-1 Loss of Secondary Coolant Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CBIoL

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB2-L (3 points) EAL: Containment pressure or sump level response NOT consistent with LOCA conditions Basis: Containment pressure and sump levels should increase as a result of mass and energy release into Containment from a LOCA. Thus, sump level or pressure not increasing indicates Containment bypass and a Loss of Containment integrity. This indicator relies on operator recognition of an unexpected response for the condition and therefore does not have a specific value associated with it. The unexpected response is important because it is the indicator for a Containment bypass condition. Explanation/Discussion/Definitions: A LOCA is expected to result in a significant Containment pressure rise. This leak rate should result in the accumulation of RCS inventory in the Containment sump as the level rises. A lack of expected Containment sump level response or Containment pressure not rising indicates that the Containment barrier has been bypassed. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Barrier Loss 2.B
2. UFSAR Table 15.4-22 LOCA Containment Response Results (Loss of Offsite Power Assumed)
3. UFSAR Figures 15.4-43a, b and c Containment Pressure (varying initial conditions)
4. UFSAR Figure 15.4-44 Containment Pressure Salem Page 1 of 2 Rev. 0 (draft E)

EAL#: CB2oL

SGS ECG - EAL Technical Bases EP-SC-111-223 This page intentionally blank Salem Page 2 of 2 Rev. 0 (draft E) EAL#: CB2-L

SGS ECG - EAL Technical Bases EP-SC-111-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB3-L (3 points) EAL: RUPTURED SG that is also FAULTED outside of Containment Basis: The Loss threshold recognizes that SG tube leakage can represent a bypass of the Containment barrier as well as a Loss of the RCS barrier. This Loss threshold and Containment Loss CB4-L could be considered redundant. The inclusion of a threshold that uses terms that are commonly used in Emergency Operating Procedures like "RUPTURED and FAULTED" adds to the ease of the classification process and has been included based on this human factor concern. For SG tube ruptures which may involve multiple steam generators or UNISOLABLE secondary line breaks, this threshold would exist in conjunction with RCS barrier thresholds and would result in a Site Area Emergency. Escalation to General Emergency would be based on "Potential Loss" of the Fuel Clad Barrier. This threshold addresses the condition in which a RUPTURED steam generator is also FAULTED. This condition represents a bypass of the RCS and containment barriers and is a subset of the threshold CB4-L. In conjunction with RCS leak rate barrier loss threshold, this would always result in the declaration of a Site Area Emergency. Explanation/Discussion/Definitions: This threshold is intended to include all flow paths of Contaminated secondary coolant to the environment directly or through systems which exhaust to the Plant Vent (e.g.; leakage to the Auxiliary Building ventilation system). An exception would be if the EOPs require steaming the ruptured Steam Generator to the main condenser. The main condenser off-gas (R1 5) pathway is excluded from this EAL provided the release is both controlled and monitored. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CB3-L

SGS ECG - EAL Technical Bases EP-SC-1 11 -223 Definitions: RUPTURED: (PWRs) In a steam generator, existence of primary-to-secondary leakage of a magnitude sufficient to require or cause a reactor trip and safety injection. FAULTED: (PWRs) In a steam generator, the existence of secondary side..leakage that results in an uncontrolled drop in steam generator pressure or the steam generator being completely depressurized. UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room. EAL Bases Reference(s):

1. NEI 99-0_1, Rev. 05, Table 5-F-3 Containment Barrier Loss 4.A
2. 1(2)-EOP-SGTR-1 Steam Generator Tube Rupture
3. 1(2)-EOP-SGTR-3 SGTR with LOCA - Subcooled Recovery Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: CB3-L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Inventory Initiating Condition: Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB4-L (3 points) EAL: Primary-to-secondary leakrate > 25 gpm AND UNISOLABLE steam release from affected SG to the environment Basis: The Loss threshold recognizes that SG tube leakage can represent a bypass of the Containment barrier as well as a Loss of the RCS barrier. This Loss threshold and Containment Loss CB3-L could be considered redundant. This threshold results in a UE for smaller breaks that; (1) do not exceed the normal charging capacity threshold in RCS leak rate barrier Potential Loss RB3-P, or (2) do not result in ECCS (SI) actuation in RCS SG tube rupture barrier Loss RB3-L. For larger breaks, RCS barrier threshold criteria would result in an Alert. For SG tube ruptures which may involve multiple steam generators or UNISOLABLE secondary line breaks, this threshold would exist in conjunction with RCS barrier thresholds and would result in a Site Area Emergency. Escalation to General Emergency would be based on "Potential Loss" of the Fuel Clad Barrier. This threshold addresses SG tube leaks that exceed 25 gpm in conjunction with an UNISOLABLE release path to the environment from the affected steam generator. The threshold for establishing the UNISOLABLE secondary side release is intended to be a prolonged release of radioactivity from the RUPTURED steam generator directly to the environment. This could be expected to occur when the main condenser is unavailable to accept the contaminated steam (i.e., SG tube rupture with concurrent loss of off-site power and the RUPTURED steam generator is required for plant cooldown or a stuck open relief valve). If the main condenser, is available, there may be releases via air ejectors, gland seal exhausters, and other similar controlled, and often monitored, pathways. These pathways do not meet the intent of an UNISOLABLE release path to the environment. These minor Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CB4-L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 releases are assessed using EALs in Category R, Abnormal Rad Levels / Radiological Effluent. Explanation/Discussion/Definitions: Definitions: RUPTURED: (PWRs) In a steam generator, existence of primary-to-secondary leakage of a magnitude sufficient to require or cause a reactor trip and safety injection. UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Barrier Loss 4.B Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: C[4-L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Other Initiating Condition: Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB5-L (3 points) EAL: Failure of ALL valves in ANY one line to close AND Direct downstream pathway to the environment exists after Containment isolation signal (Note 8) Note 8: A direct downstream release is a pathway from the Containment to any environment outside the Containment when Containment or system isolation is required due to: a safety injection signal, Containment pressure greater than 4 psig, or a VALID containment ventilation isolation signal and the pathway cannot be isolated from the Control Room. Basis: This threshold addresses incomplete containment isolation that allows direct release to the environment. The use of the modifier "direct" in defining the release path discriminates against release paths through interfacing liquid systems. The existence of an in-line charcoal filter does not make a release path indirect since the filter is not effective at removing fission product noble gases. Typical filters have an efficiency of 95-99% removal of iodine. Given the magnitude of the core inventory of iodine, significant releases could still occur. In addition, since the fission product release would be driven by boiling in the reactor vessel, the high humidity in the release stream can be expected to render the filters ineffective in a short period. There is no Potential Loss threshold associated with this item. Explanation/Discussion/Definitions: Indications of Containment failure may be evident without the exact pathway bein g understood at the time of the failure. If the Containment or part of the RCS is required to be isolated and Salem Page 1 of 4 Rev. 0 (draft E) EAL#: (B5=L

SGS. ECG - EAL Technical Bases EP-SC-1 1 1.ý223 there are VALID indications that the Containment is not isolated, the Containment barrier should be considered lost.-- Area Radiation monitor alarms that exceed normal monitor indications without a reason to expect another source such as a gas decay tank, spill, piping shine or fuel handling problem, indicate a loss of the Containment. Area temperature alarms, rising sump level indications or unexpected system flow indications outside Containment may also indicate a loss of the Containment. If the Containment Barrier is lost without a loss of the Fuel Clad Barrier, effluent radiation readings may not increase significantly. Unexpected area temperature alarms, unexpected flow rates or sump level increases outside of Containment, however, may provide the indications that the Containment atmosphere is no longer isolated. In addition, the term "to the environment" is intended to include any leakage that cannot be isolated either directly or through systems that exhaust to the Plant Vent (e.g., leakage to the Auxiliary Building Ventilation System) or directly to any other area outside.the Containment. A safety injection, high Containment pressure or a Containment vent isolation signal represents a situation that requires the Containment to be isolated from the outside environment. . . As indicated in Note 8, this EAL allows for valve closure from the Control Room, prior to event classification, to.isolate.any system not completely isolated. Leakage cannQt be isolated from the Control Room refers to valve(s) that did. not completely close when demanded (either automatically or rmanually)}.-This includes Motor Operated Valves not controlled by isolation logic but are manually controlled-from the Control Room. For example, if the isolation logic fails to cause valve closure but operato.r actions implemented in theControl Room successfully isolates the Containment breach path, classification under this EAL is NOT WARRANTED.... Although this EAL ALLOWS for valve closure from the Control Room, the time to attempt closure and make a decision if containment leak isolation was successful RUNS CONCURRENTLY with the EAL 15-minute assessment clock. o If; during the EAL 15-minute assessment period attempts from the Control Room to. isolate-the containment ARE SUCCESSFUL then, this EAL is NOT exceeded and classification per this EAL-should NOT be made. 

       . If, d~ring the EAL 15-minute assessment period attempts from the Cont'rol Room to isolate the co'ntainment ARE NOT-SUCCESSFUL then, this EAL is exceeded and%

classification should be made at that time. There is no need to wait the full 15 minutes. If near the end of the 15 minute assessment'period and the control roam staff has not been able to attempt containment isolation or the EC is not convinced that an isolation attempt has been successful, then this EAL is exceededand classification should be made at or before the 15-minute assessment time expires. Salem Page 2 of 4 Rev. 0 (draft E) EAL#:CBSL

SGS ECG - EAL Technical Bases EP-SC-1 11-223 Definitions: VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Barrier Loss 5.A
2. SGS Technical Specifications 3.6.3 Containment Isolation Valves
3. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
4. I(2)-EOP-LOCA-6 LOCA Outside Containment Salem Page 3 of 4 Rev. 0 (draft E)

EAL#:CB5oL

SGS ECG - EAL Technical Bases EP-SC-11 11-223 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: CBS-L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 EAL Category: F - Fission Product Barrier Degradation Subcategory: Judgment Initiating Condition: Loss of Containment Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown EAL# & Point Value: CB6-L (3 points) EAL: ANY condition in the opinion of the Emergency Coordinator that indicates loss of the Containment barrier Basis: This threshold addresses any other factors that are to be used by the Emergency Coordinator in determining whether the Containment barrier is lost. In addition, the inability to monitor the barrier should also be incorporated in this threshold as a factor in Emergency Coordinator judgment that the barrier may be considered lost. The Containment barrier should not be declared lost based on exceeding Technical Specification action statement criteria, unless there is an event in progress requiring mitigation by the Containment barrier. When no event is in progress (Loss or Potential Loss of either Fuel Clad and/or RCS) the Containment barrier status is addressed by Technical Specifications. Explanation/Discussion/Definitions: The Emergency Coordinator judgment threshold addresses any other factors relevant to determining if the Containment barrier is lost. Such a determination should include IMMINENT barrier degradation, barrier monitoring capability and dominant accident sequences. o Barrier degradation exists if the degradation will likely occur within two hours based on a projection of current safety system performance. o Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration of offsite monitoring results. o Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of Salem Page 1 of 2 Rev. 0 (draft E) EAL#: CB6-L

SGS ECG - EAL Technical Bases EP-SC-1 11-223 AC power (Station Blackout) and ATWT EALs to assure timely emergency classification declarations. Definitions: IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, Table 5-F-3 Containment Loss 8.A Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CBSoL

EALs fioro Cold Shutdown Condat0 xons o

SGS ECG - EAL Technical Bases EP-SC-1 11-224 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 1 - Loss of AC Power Initiating Condition: AC power capability to vital buses reduced to a single power source for 15 minutes or longer such that any additional single failure would result in complete loss of AC power to vital buses Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CUI.1 - UNUSUAL EVENT EAL: Loss of 4.16 KV Vital Bus Power Sources (Offsite and Onsite) which results in the availability of only one 4.16 KV Vital Bus Power Source (Offsite or Onsite) AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: The condition indicated by this EAL is the degradation of the offsite and onsite AC power systems such that any additional single failure would result in a station blackout. This condition could occur due to a loss of off-site power with a concurrent failure of all but one emergency diesel generator to supply power to its vital bus. The subsequent loss of this single power source would escalate the event to an ALERT in accordance with EAL CA1.1. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power. Explanation/Discussion/Definitions: 

"Availability" means the power source can be aligned to provide power to a vital bus within 15 minutes or is currently supplying power to at least one vital bus.

The availability of EDGs that have not been challenged to start during degradation of AC power sources to the 4KV vital buses should be based on meeting Technical Specification action requirements for loss of offsite AC power sources. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: CUi1.

SGS ECG' EAL Technical Bases EP-SC-1 11 -224 The AC power distribution is summarized in Attachment 2, page 2. Emergency Classification escalates to an ALERT under EAL CA1.1 based on a loss of all offsite and all onsite AC power to all 4KV vital buses. This cold cohdition UNUSUAL EVENT EAL is equivalent to tjhe hot condition ALERT EAL SAI.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05 - CU3 Example EAL #1
2. UFSAR Figure 8.2-2 500 kV Switchyard. Diagram
3. UFSAR Figure 8.3-1 Auxiliary Power System Diagram
4. UFSAR 8.1.1 Utility Grid System and Interconnections
5. UFSAR 83.1 Power
6. SGS Technical Specifications 3.8.1.2 Electrical Power Systems - Shutdown
7. SGS Technical Specifications 3.812.2 AC Distribution - Shutdown
8. 1(2)-EOP-TRI P-1 Reactor Trip or Safety Injection
9. 1(2)-EOP-LOPA-1 Loss of All AC Power
10. Si (S2).OP-AB.LOOP-0001 (Q) Loss of Off-Site Power 11 .S1(S2).OP-AB.4KV-0001 (Q) Loss of 1A 4KV Vital Bus 12.S1 (S2).OP-AB.4KV-0002(Q) Loss of 1B4KV Vital Bus
13. SI(S2).OP-AB.4KV-0003(Q) Loss of 1C 4KV Vital Bus Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: C UM *]I1

SGS ECG - EAL Technical Bases EP-SC-111-224 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: I - Loss of AC Power Initiating Condition: Loss of all offsite and all onsite AC power to vital buses for 15 minutes or longer Mode Applicability: 5 - Cold Shutdown, 6 - Refueling, D - Defueled EAL# & Classification Level: CAI.1 - ALERT EAL: Loss of all Power (Onsite and Offsite) to all 4KV Vital Buses AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal, Spent Fuel Heat Removal and the Ultimate Heat Sink (Service Water). The event can be classified as an ALERT when in cold shutdown, refueling, or defueled mode because of the significantly reduced decay heat and lower temperature and pressure, increasing the time to restore one of the vital busses, relative to that specified for the SITE AREA EMERGENCY EAL. Escalating to SITE AREA EMERGENCY, if appropriate, is by EALs in Category R, Abnormal Rad Levels / RadEffluent. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Exp Ianation/D is cuss ion/Defi n itio ns: The intent of this EAL is to classify degraded AC power events that result in a loss of all offsite power sources (13.8 KV) to the 4KV vital buses along with a loss of all onsite power sources (EDGs). Salem Page 1 of 2 Rev. 0 (draft E) EAL#: CA1,

SGS. ECG - EAL Technical Bases EP-SC-1 11-224 The AC power distribution is summarized in Attachment 2, page 2. This cold condition ALERT EAL is equivalent to the hot condition SITE AREA EMERGENCY EAL SS1.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05 - CA3 Example EAL #1
2. UFSAR Figure 8.2-2 500 kV Switchyard Diagram
3. UFSAR Figure 8.3-1 Auxiliary Power System Diagram
4. UFSAR 8.1.1 Utility Grid System and Interconnections
5. UFSAR 8.3.1 Power
6. SGS Technical Specifications 3.8.1.2 Electrical Power Systems - Shutdown
7. SGS Technical Specifications 3.8.2.2 AC Distribution - Shutdown
8. 1(2)-EOP-TRIP-1 Reactor Trip or Safety Injection
9. 1(2)-EOP-LOPA-1 Loss of All AC Power 10.S1 (S2).OP-AB.LOOP-0001 (Q) Loss of Off-Site Power 11.1S(S2).OP-AB.4KV-0001 (Q) Loss of 1A 4KV Vital Bus
12. S1(S2).OP-AB.4KV-0002(Q) Loss of 1B 4KV Vital Bus 13.S1 (S2).OP-AB.4KV-0003(Q) Loss of 1C04KV Vital Bu's Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: CAI.l

SGS ECG - EAL Technical Bases EP-SC-1 11-225 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 2 - Loss of DC Power Initiating Condition: Loss of required DC power for 15 minutes or longer Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CU2.1 - UNUSUAL EVENT EAL: < 114 VDC bus voltage indications on All 125 VDC vital buses for > 15 minutes (Note 3) OR < 25 VDC bus voltage indications on both 28 VDC vital buses for > 15 minutes (Note 3) AND loss of control of Safety Related Equipment from the Control Room has been confirmed Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: The purpose of this EAL and its associated EALs is to recognize a loss of DC power compromising the ability to monitor and control the removal of decay heat during Cold Shutdown or Refueling operations. It is intended that the loss of the operating (operable) train is to be considered. If this loss results in the inability to maintain cold shutdown, the escalation to an ALERT will be per EAL CA4.1. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Explanation/Discussion/Definitions: The specified bus voltage indications (rounded for readability on Control Room instrumentation) are the minimum voltage requirements for operability of the 125 VDC buses and 28 VDC buses following battery discharge tests. Although continued operation may occur with degraded voltage, these values signify the minimum operable voltages allowed. I This UNUSUAL EVENT EAL is the cold condition equivalent of the hot condition loss of DC power SITE AREA EMERGENCY EAL SS2.1. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CU2.]

SGS ECG - EAL Technical Bases EP-SC-1 11-225 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, SS3 Example EAL #1
2. SC.MD-ST.125-0004 (Q) 125 Volt Station Batteries 18 Month Service Test and Associated Surveillance Testing Using BCT-2000
3. SC.MD-ST.28D-0004 (Q)28 Volt Station Batteries 18 Month Service Test and Associated Surveillance Using BCT-2000
4. UFSAR 8.3.2 DC Power
5. SGS Technical Specifications 3.8.2.3 125 Volt DC Distribution - Shutdown
6. SGS Technical Specifications 3.8.2.5 28 Volt DC Distribution - Shutdown
7. S_1(2).OP-SO.125-0005 1(2)A 125VDC Bus Operation
8. S1(S2).OP-SO.125-0006 1(2)B 125VDC Bus Operation
9. S1($2).bP-SO.125-0007 1(2)C 125VDC Bus Operation Salem Page 2 of 2 Rev. 0 (draft E)

EAL#:CU2.]

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory Mode Applicability: 5 - Cold Shutdown EAL# & Classification Level: CU3.1 - UNUSUAL EVENT EAL: RCS leakage results in the inability to maintain or restore RCS level to EITHER: o Pressurizer Level > 17% (cold calibration value) o Within the target band established by procedure (when the level band is established below the pressurizer) AND _ 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: This EAL is considered to be a potential degradation of the level of safety of the plant. The inability to maintain or restore level is indicative of loss of RCS inventory. Relief valve normal operation should be excluded from this EAL. However, a relief valve that operates and fails to close per design should be considered applicable to this EAL if the relief valve cannot be isolated. Prolonged loss of RCS Inventory may result in escalation to the ALERT emergency classification level via either EAL CA3.1 or EAL CA4.1. Explanation/Discussion/Definitions: When Pressurizer (PZR) level drops to 17%, letdown isolates and pressurizer heaters are deenergized. The Pressurizer cold calibration level is monitored on LI-462. This condition is signaled by overhead annunciator E-36, PZR HTR OFF LVL LoL Cold calibrated Pressurizer level is indicated on computer points and SPDS. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CU3.1

SGS ECG - EAL Technical Bases EP-SC-1 11-226 In Cold Shutdown mode, PZR level may be intentionally lowered below the letdown isolation setpoint (e.g., in preparation.to detension the reactor vessel head, etc.). For such evolutions, this EAL is applicable if RCS level cannot be restored and maintained within the prescribed target band specified in operating procedures. Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. EAL Basis Reference(s):

1. NEI 99-01, Re-v. 05, CU1 Example EAL #1
2. SI(S2).OP-AR.ZZ-0005(Q) OHA- E-36, PZR HTR OFF LVL LO
3. S1(S2).OP-IO.ZZ-0006(Q) Hot Standby to Cold Shutdown
4. S1(S2).OP-IO.ZZ-0007(Q) Cold Shutdown to Refueling
5. S1(S2).OP-SO.RC-0005 (Q) Draining the Reactor Coolant System To >101 Foot Elevation
6. S1(S2).OP-SO.RC-0006 (Q) Draining the Reactor Coolant System < 101ft Elevation with Fuel in the Vessel Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: C UMo

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory Mode Applicability: 6 - Refueling EAL# & Classification Level: CU3.2 - UNUSUAL EVENT EAL: RCS level CANNOT be monitored with a loss of RCS inventory as indicated by ANY unexplained RCS leakage indication, Table C-1 Table C-1 RCS Leakage Indications o Rise in Containment sump pump run frequency o Aux Building sump level rise o PRT level rise o RWST level rise o RCDT level rise o Rise in RCS make-up rate

  • Observation of RCS leakage that is UNISOLABLE Salem Page 1 of 4 Rev. 0 (draft E)

EAL#: CU3.2

SGS ECG - EAL Technical Bases EP-SC-111-226 Basis: This EAL is a precursor of more serious conditions and considered to be a potential degradation of the level of safety of the plant. This EAL addresses conditions in the Refueling mode when normal means of core temperature indication and RCS level indication may not be available. Redundant means of RCS level indication will normally be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted. However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RCS inventory loss was occurring by observing Table C-1 indications. Table C-1 RCS leakage indications must be evaluated against other potential sources of leakage such as cooling water sources inside the containme.nt to ensure they are indicative of RCS leakage. Escalation to the ALERT emergency classification level would be via EAL CA3.2 or EAL CA4.i. Explanation/Discussion/Definitions:. . During refueling, the reactor head and associated RVLIS piping are removed. Visual observation by personnel on the refuel floor in communication with the Control Room may also provide indication of refueling cavity water level and RCS water level. In this EAL, all level indication is unavailable and the RCS.inventory loss must be detected by the leakage indications listed in Table C-1. Level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the Containment to ensure they are indicative of RCS leakage. Visual observation of leakage from systems connected to the RCS in areas inside or outside the Containment that cannotrbe isolated could be indicative of a loss of RCS inventory. Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room. Salem Page 2 of 4 Rev. 0 (draft E) EAL#:CU3o2

SGS ECG - EAL Technical Bases EP-SC-1 11 -226 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, CU2 Example EAL #2
2. Si (S2).OP-SO.RVL-0001 Reactor Vessel Level Instrumentation System
3. UFSAR 5.6.5 Reactor Vessel Water Level
4. UFSAR 7.3.1.1.9 Instrumentation Used During a Loss of Coolant Accident
5. SI(S2).OP-AB.RHR-0002(Q) Loss of RHR at Reduced Inventory
6. S1(S2).OP-SO.RC-0005(Q) Draining the Reactor Coolant System To >101 Foot Elevation
7. UFSAR Figure 6.3-3 Containment Sump Pit
8. UFSAR 6.3.2.2 Equipment and Component Description (ECCS)
9. UFSAR Figure 6.2-17 Containment Isolation Pressurizer Relief Tank Connections
10. S1 (S2).OP-AB.RC-0001(Q) Reactor Coolant System Leak Salem Page 3 of 4 Rev. 0 (draft E)

EAL#:CU3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: CU3o2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory Mode Applicability: 6 - Refueling EAL# & Classification Level: CU3.3 - UNUSUAL EVENT EAL: UNPLANNED RCS level drop below EITHER of the following: o 104 ft (Reactor Vessel flange) o RCS level band (when the RCS level band is established below the Reactor Vessel flange) AND > 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: This EAL is a precursor of more serious conditions and considered to be a potential degradation of the level of safety of the plant. Refueling evolutions that decrease RCS water level below the Reactor Vessel flange are carefully planned and procedurally controlled. An UNPLANNED event that results in water level decreasing below the Reactor Vessel flange, or below the planned RCS water level for the given evolution (if the planned RCS water level is already below the Reactor Vessel flange), warrants declaration of a UE due to the reduced RCS inventory that is available to keep the core covered. The allowance of 15 minutes was chosen because it is reasonable to assume that level can be restored within this time frame using one or more of the redundant means of refill that should be available. If level cannot be restored in this time frame then it may indicate a more serious condition exists. Salem Page 1 of 2 Rev. 0 (draft E3) EAL#:CU3o3

SGS ECG - EAL Technical Bases EP-SC-1 11-226 Continued loss of RCS Inventory will result in escalation to the ALERT emergency classification level via either EAL CA3.1 or EAL CA4.1. This EAL involves a decrease in RCS level below the top of the Reactor Vessel flange that continues for 15 minutes due to an UNPLANNED event. This EAL is not applicable to decreases in flooded refueling cavity level, which is addressed by EAL RU2.1, until such time as the level decreases to the level of the vessel flange. Explanation/Discussion/Definitions" 104 ft is the Reactor Vessel flange elevation. RCS water level is normally monitored using the instrument -ranges illustrated in Attachment 2, page 10. During refueling, the reactor head and associated RVLIS piping are removed. Visual observation by personnel on the refuel floor in communication with the Control Room may also provide indication of refueling cavity water level and RCS water level. In cold conditions, RCS level may be intentionally lowered below the Reactor Vessel flange (e.g., detensioning the Reactor Vessel head, reduced inventory conditions, etc.). For such evolutions, this EAL is applicable if RCS level cannot be restored-and maintained within .the prescribed target band. This Cold Shutdown EAL represents.the hot condition EAL SU7.1, in which RCS leakage is associated with Technical Specification limits. In cold conditions, these limits are not applicable hence,_the use of RCS levelas the parameter of concern in this EAL. Definitions: UNPLANNED: A parameter change.or an event that is not the result of an intended evolution and "equires Corrective oi&mitigative actions. EAL Basis Reference(s):

1. NEI 99-0I Re'V. 05,.CU2 Example EAL #1
2. S1(S2).OP-.S.RC-00_05(Q) Draining the Reactor Coolant System to >101 Foot Elevation
3. S1(S2).OOP-SO.RVL-0001 Reactor Vessel Level Instrumentation System
4. UFSAR 5.6.5 Reactor Vessel Water Level
5. UFSAR 7.3.1.1.9 Instrumentation Used During a Loss of Coolant Accident Salem Page 2 of 2 Rev. 0 (draft E3)

EAL#:CU.

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: Loss of RCS inventory Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CA3.1 - ALERT EAL: RCS level < 97.5 ft Basis: This EAL serves as a precursor to a loss of ability to adequately cool the fuel. The magnitude of this loss of water indicates that makeup systems have not been effective and may not be capable of preventing further RCS level decrease and potential core uncovery. This condition will result in a minimum emergency classification level of an ALERT. The RCS Level setpoint was chosen because at this level remote RCS level indication may be lost and loss of suction to decay heat removal systems may occur. The inability to restore and maintain level after reaching this setpoint would be indicative of a failure of the RCS barrier. If RCS level continues to lower then escalation to SITE AREA EMERGENCY will be via EAL CS3.2. Explanation/Discussion/Definitions: RCS water level is normally monitored using the instrument ranges illustrated in Attachment 2, page 10. The centerline level of the RCS loop hot leg is at approximately 97 ft and the inside diameter of the hot leg penetration is 29 in. The bottom ID would be 97 ft - 29/2 in. or 95 ft 9.5 in. Although NEI desires a level for this threshold that is equal to the bottom of the RCS loop hot leg penetration, the RCS level indication capability does not support detection of a threshold level that low. Mid Loop Level indication is capable of monitoring level to 97.3 ft; so, a setpoint of 97.5 ft has been selected. Local indication is also available to monitor this level. Continued inventory loss could result in a loss of suction to the RHR System. The inability to restore and maintain level after reaching loop centerline (approximately) would therefore be indicative of a failure of the RCS barrier. Salem Page 1 of 2 Rev. 0 (draft E) EAL#: CA3o.1

SGS ECG - EAL Technical Bases EP-SC-111-226 EAL Basis Reference(s):

1. NEI 99-01, Rev. 05, CA1 Example EAL #1
2. SI(S2).OP-SO.RC-0005(Q) Draining the Reactor Coolant System to >101 Foot Elevation
3. UFSAR Figure 5.1-1 Reactor Vessel Schematic
4. Sl(S2).OP-AB.RHR-0002(Q) Loss of RHR at Reduced Inventory
5. UFSAR Figure 6.3-2 & 6.3-3 Containment Sump and Drain Trench & Containment Sump Pit
6. UFSAR 6.3.2.2 Equipment and Component Description (ECCS)
7. UFSAR Figure 6.2-17 Containment Isolation Pressurizer Relief Tank Connections
8. S1 (S2).OP-AB.RC-0001 (Q) Reactor Coolant System Leak Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: CA3o 1

SGS ECG - EAL Technical Bases EP-SC-111-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: Loss of RCS inventory Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CA3.2 - ALERT EAL: RCS level CANNOT be monitored for > 15 minutes with a loss of RCS inventory as indicated by ANY unexplained RCS leakage indication, Table C-I (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Table C-1 RCS Leakage Indications o Rise in Containment sump pump run frequency o Aux Building sump level rise o PRT level rise o RWST level rise o RCDT level rise o Rise in RCS make-up rate 

                       " Observation of RCS leakage that is UNISOLABLE Salem                                         Page 1 of 4                         Rev. 0 (draft E)

EAL#: CA3o2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 Basis: This EAL serves as a precursor to a loss of ability to adequately cool the fuel. The magnitude of this loss of water indicates that makeup systems have not been effective and may not be capable of preventing further RCS level decrease and potential core uncovery. This condition will result in a minimum emergency classification level of an ALERT. In the Cold Shutdown mode, normal RCS level instrumentation systems will usually be available. In the Refueling mode, normal means of RCS level indication may not be available. Redundant means of RCS level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted. However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RCS inventory loss was occurring by observing Table C-1 indications. Table C-1 RCS leakage indications must be evaluated against other potential sources of leakage such as cooling water sources inside the Containment to ensure they are indicative of RCS leakage. Visual observation of leakage from systems connected to the RCS in areas inside or outside the Containment that cannot be isolated could be indicative of a loss of RCS inventory. The 15-minute duration for the loss of level indication was chosen because it is half of the EAL CS3.2 SITE AREA EMERGENCY duration. Significant fuel damage is not expected to occur until the core has been uncovered for greater than 1 hour per the analysis referenced in the EAL CG3.2 basis. Therefore this EAL 'meets the definition for an ALERT. If RCS leakage indications continue and RCS level cannot be monitored for 30 minutes or more, EAL CS3.2 will require escalation to SITE AREA EMERGENCY. Explanation/Discussion/Definitions: In this EAL, all RCS level indication is unavailable and the RCS inventory loss must be detected by the leakage indications listed in Table C-1. Level increases must be evaluated against other potential sources of leakage (SWS, Component Cooling Water, etc.) to ensure they are indicative of RCS leakage. In cold shutdown, the decay heat available to raise RCS temperature during a loss of inventory or heat removal event may be significantly greater than in the Refueling Mode. Entry into cold shutdown conditions may be attained within hours of operating at power or hours after refueling is completed. Entry into the Refueling Mode procedurally may not occur for typically a few days or longer after the reactor has been shutdown. Thus the heatup threat and therefore the threat to damaging the fuel clad may be lower for events that occur in the Refueling Mode with irradiated fuel in the Reactor Vessel (note that the heatup threat could be lower for cold shutdown conditions if the entry into cold shutdown was following a refueling). Salem Page 2 of 4 Rev. 0 (draft E) EAL#:CA3o2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 Definitions: UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room. EAL Basis Reference(s):

1. NEI 99-01, Rev. 05, CA1 Example EAL #2
2. SI (S2).OP-SO.RVL-0001 Reactor Vessel Level Instrumentation System
3. UFSAR 5.6.5 Reactor Vessel Water Level
4. UFSAR 7.3.1.1.9 Instrumentation Used During a Loss of Coolant Accident
5. SI(S2).OP-AB.RHR-0002(Q) Loss of RHR at Reduced Inventory
6. S1 (S2).OP-SO.RC-0005(Q) Draining the Reactor Coolant System To >101 Foot Elevation
7. Reference drawing 208915-A-8823 Sh 1
8. UFSAR Figure 6.3-3 Containment Sump Pit
9. UFSAR 6.3.2.2 Equipment and Component Description (ECCS)
10. UFSAR Figure 6.2-17 Containment Isolation Pressurizer Relief Tank Connections
11. S (S2).OP-AB.RC-0001 (Q) Reactor Coolant System Leak Salem Page 3 of 4 Rev. 0 (draft E)

EAL#: CA3o2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: CA3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CS3.2 - SITE AREA EMERGENCY EAL: RCS level CANNOT be monitored for > 30 minutes with a loss of RCS inventory as indicated by ANY of the following (Note 3): o R44A > 5 R/hr o R10B > 3500 mR/hr o R2 > 104 mR/hr o Erratic Source Range Monitor indication o ANY unexplained RCS leakage indication, Table C-1 Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Table C-1 RCS Leakage Indications o Rise in Containment sump pump run frequency o Aux Building sump level rise o PRT level rise o RWST level rise o RCDT level rise o Rise in RCS make-up rate 

                       " Observation of RCS leakage that is UNISOLABLE Salem                                          Page 1 of 4                         Rev. 0 (draft E)

EAL#:CS3o2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 Basis: Under the conditions specified by this EAL, continued decrease in RCS level is indicative of a loss of inventory control. Inventory loss may be due to an RCS breach, pressure boundary leakage, or continued boiling in the Reactor Vessel. Thus, declaration of a SITE AREA EMERGENCY is warranted. Escalation to a GENERAL EMERGENCY is via EAL CG3.2 or EAL RG1.1. In the cold shutdown mode, normal RCS level instrumentation systems will usually be available. In the refueling mode, normal means of RCS level indication may not be available. Redundant means of RCS level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to .monitor level will not be interrupted. However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RCS inventory loss was occurring by observing Table C-1 indications. Table C-1 RCS leakage indications must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage. The 30-minute duration allows sufficient time for actions to be performed to recover inventory control equipment. Post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be Used as a tool for making such determinations. Explanation/Discussion/Definitions: - This EAL applies to conditions in which the loss of decay heat removal capability has caused a significant drop in RCS water. level. below the bottom of the RCS hot leg penetration and core uncovery may be challenged. RCS level indication capability does not support detection of RCS levels that low and, consequently; alternate means of assessing RCS inventory loss must be used: o As water level in the Reactor Vessel lowers, the dose rate. above the core will increase. The dose rate due to this core shine should result in up-scaled general area low range containment monitor (1/2R1OB & 1/2R2) and high range containment monitor (1/2R44A) indication and possible alarm. A dose rate setpoint indicative of core uncovery (i.e., level at top of active fuel) is a means to detect theonset of IMMINENT core damage. S-C-ZZ-MDC-2280 documents the basis for the threshold values for the R2, R10B and R44A. values that -indicate RCS level at or approaching the top of active fuel. Data from both Unit. 1 and Unit 2 was reviewed and values rounded off to provide conservative threshold values that cover both Salem units based on how many fuel assemblies are in the Reactor Vessel and includes an appropriate reduction for radioactive decay of short lived radionuclides. As Reactor Vessel level decreases life Salem Page 2 of 4 Rev. 0 (draft E) EAL#:CS3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 threatening levels could exist directly above the core; with water level at top of active fuel dose rates 20 feet above the core will be in excess of 38,000 R/hr. Additionally, post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations. For EAL simplification, the thresholds are representative of a partially defueled core (80 fuel assemblies in the Reactor Vessel). o Erratic source range monitor indication may be identified by: o Source range count rate indicators NI31B and N132B o NIS Recorder NR45 o Audio count rate o SPDS o Process Computer o RCS inventory loss may be detected by the leakage indications listed in Table C-1. Level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the Containment to ensure they are indicative of RCS leakage. Visual observation of leakage from systems connected to the RCS in areas inside or outside the Containment that cannot be isolated could be indicative of a loss of REACTOR VESSEL inventory. Definitions: UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room. IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). Salem Page 3 of 4 Rev. 0 (draft E) EAL#: CS3o2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Basis Reference(s):

1. NEI 99-01, Rev. 05, CS1 Example EAL #3
2. S-C-ZZ-MDC-2280, EAL Dose Rates to Radiation Detectors Following Loss of RPV Level during Refueling Operation
3. Technical Specifications 3.3.1.1 Reactor Trip System Instrumentation
4. UFSAR Table 7.5-2 Main Control Room Indicators and/or Recorders Available to the Operator to Monitor Significant Plant Parameters During Normal Operations
5. SC.IC-CC.NIS-0011(Q) N31 Source Range
6. SC.IC-CC.NIS-0012(Q) N32 Source Range
7. S1(S2).OP-SO.RC-0005(Q) Draining the Reactor Coolant System to ?101 Foot Elevation
8. UFSAR Figure 6.3-2 & 6.3-3 Containment Sump and Drain Trench & Containment Sump Pit
9. UFSAR 6.3.2.2 Equipment and Component Description (ECCS)
10. UFSAR Figure 6.2-17 Containment Isolation Pressurizer Relief Tank Connections 11.31 (S2).OP-AB.RC-0001(Q) Reactor Coolant System Leak Salem Page 4 of 4 Rev. 0 (draft E)

EAL#:CS3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 3 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with Containment challenged Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CG3.2 - GENERAL EMERGENCY EAL: RCS level CANNOT be monitored for _ 30 minutes with core uncovery indicated by ANY of the following (Note 3): o R44A> 5 RPhr o R10B > 3500 mRihr o R2 > 104 mR/hr o Erratic Source Range Monitor indication o ANY unexplained RCS leakage indication, Table C-1 AND ANY Containment Challenge indication, Table C-2 Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Salem Page 1 of 6 Rev. 0 (draft E) EAL#: CG3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 Table C-1 RCS Leakage Indications o Rise in Containment sump pump run frequency o Aux Building sump level rise o PRT level rise o RWST level rise o RCDT level rise o - Rise in RCS make-up rate o Observation of RCS leakage that is UNISOLABLE Table C-2 Containment Challenge Indications o CONTAINMENT CLOSURE NOT established o Indications of > 4% H2 inside'Containment o UNPLANNED rise in Containment pressure Basis: This EAL represents the inabi.lity.to restore and maintain RCS level to above the top of active fuel witih.con.tainme-n[t.challehged. Fuel damage is probable if RCS level cannot be restored, as available decay heat will Cause boiling, further reduing the RCS level. With the Containment breached or challenged then the potential for unmonitored fission product release to the environment is high. This represents a direct path for radioactive inventory to be released to the environment. This is consistent with the definition of a GENERAL EMERGENCY. The GENERAL EMERGENCY is declared on the occurrence of the loss or IMMINENT loss of function of all three barriers. A number of variables can have a significant impact on heat removal capability challenging the fuel clad barrier. Examples include: mid-loop, reduced level/flange level, head in place, cavity flooded, RCS venting strategy, decay heat removal system design, vortexing pre-disposition, steam generator U-tube draining. Analysis indicates that core damage may occur as soon as one hour following continued core uncovery, therefore, 30 minutes was conservatively chosen. Salem Page 2 of 6 Rev. 0 (draft E) EAL#:CG3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 If CONTAINMENT CLOSURE is re-established prior to exceeding the 30 minute core uncovery time limit then escalation to GE would not occur. Table C-1 RCS leakage indications must be evaluated against other potential sources of leakage such as cooling water sources inside the Containment to ensure they are indicative of RCS leakage. In the Cold Shutdown mode, normal RCS level instrumentation systems will usually be available. In the Refueling mode, normal means of RCS level indication may not be available. Redundant means of RCS level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted. However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RCS inventory loss was occurring by observing Table C-1 indications. Table C-1 RCS leakage indications must be evaluated against other potential sources of leakage such as cooling water sources inside the Containment to ensure they are indicative of RCS leakage. Post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations. Explanation/Discussion/Definitions: This EAL applies to conditions in which a significant drop in Reactor Vessel water level below the RCS hot leg penetration has occurred with prolonged core uncovery. RCS level indication capability does not support detection of RCS levels that low and, consequently, alternate means of assessing RCS inventory loss must be used: o As water level in the Reactor Vessel lowers, the dose rate above the core will increase. The dose rate due to this core shine should result in up-scaled general area low range containment monitor (1/2R10B & 1/2R2) and high range containment monitor (1/2R44A) indication and possible alarm. A dose rate setpoint indicative of core uncovery (i.e., level at top of active fuel) is a means to detect the onset of IMMINENT core damage. S-C-ZZ-MDC-2280 documents the basis for the threshold values for the R2, R1 OB and R44A values that indicate RCS level at or approaching the top of active fuel. Data from both Unit 1 and Unit 2 was reviewed and values rounded off to provide conservative threshold values that cover both Salem units based on how many fuel assemblies are in the Reactor Vessel and includes an appropriate reduction for radioactive decay of short lived radionuclides. As Reactor Vessel level decreases life threatening levels could exist directly above the core; with water level at top of active fuel dose rates 20 feet above the core will be in excess of 38,000 R/hr. Additionally, post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations. For EAL simplification, the thresholds are representative of a partially defueled core (80 fuel assemblies in the Reactor Vessel). Salem Page 3 of 6 Rev. 0 (draft E) EAL#:CG3o2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 o Erratic source range monitor indication may be identified by: o Source range count rate indicators NI31B and N132B o NIS Recorder NR45 o Audio count rate o SPDS o Process Computer o RCS inventory loss, may be detected by the leakage indications listed in Table C-1. Level increases must be evaluated against.other potential sources of leakage such as cooling water sources inside the Containment to ensure they are indicative of RCS leakage. Visual observation of leakage from systems connected to the RCS in areas inside or outside the Containment that cannot be isolated could be indicative of a loss of RCS: inventory. Three conditions are associated with a challenge to Containment: o The status of CONTAINMENT CLOSURE indicates the ability to rely on the Containment as a barrier to fission product release. o When hydrogen concentration in the Containment atmosphere exceeds 4%, the possibility of an explosive mixture exists inside Containment. Elevated Containment atmosphere hydrogen concenfration is alarmed at _>2% by Overhead annunciator C-23, CNTMT H2 LVL HI o An UNPLANNED rise in Containment pressure in the Cold Shutdown or Refueling Mode may signify an energy addition'to the Contaihment such that the Containment cannot be relied upon as a barrier io fission product release. Definitions: UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room.. CONTAINMENT CLOSURE: Is the Salem procedurally defined action taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. CONTAWINMENT CLOSURE status is checked and verified using S1(S2).OP-AB.CONT-0001(Q). UNPLANNED: A parameter change or an event that is not the result of an intended e',olution and requires corrective or mitigative actions. Salem Page 4 of 6 Rev. 0 (draft E) EAL#:CG3,2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). EAL Basis Reference(s):

1. NEI 99-01, Rev. 05, CG1 Example EAL #2
2. OU-AA-103 Shutdown Safety Management Program
3. Sl(S2).OP-AB.CONT-0001(Q) Containment Closure
4. S-C-ZZ-MDC-2280, EAL Dose Rates to Radiation Detectors Following Loss of RPV Level during Refueling Operation
5. Technical Specifications 3.3.1.1 Reactor Trip System Instrumentation
6. UFSAR Table 7.5-2 Main Control Room Indicators and/or Recorders Available to the Operator to Monitor Significant Plant Parameters During Normal Operations
7. SC.IC-CC.NIS-0011(Q) N31 Source Range
8. SC.IC-CC.NIS-0012(Q) N32 Source Range
9. S1(S2).OP-SO.RC-0005(Q) Draining the Reactor Coolant System to >101 Foot Elevation
10. UFSAR Figure 6.3-2 & 6.3-3 Containment Sump and Drain Trench & Containment Sump Pit
11. UFSAR 6.3.2.2 Equipment and Component Description (ECCS)
12. UFSAR Figure 6.2-17 Containment Isolation Pressurizer Relief Tank Connections
13. S1 (S2).OP-AB.RC-0001 (Q) Reactor Coolant System Leak
14. 1(2)-EOP-FRCC-1 Response to Inadequate Core Cooling - Basis Document (pg 16)
15. Salem EOP Setpoint Basis Document - Vendor Doc. #320832
16. S1(S2).OP-AR.ZZ-0003(Q) OHA C-23, CNTMT H2 LVL HI Salem Page 5 of 6 Rev. 0 (draft E)

EAL#:CG3.2

SGS ECG - EAL Technical Bases EP-SC-1 11-226 This page intentionally blank Salem Page 6 of 6 Rev. 0 (draft E) EAL#:C(3,2

SGS ECG - EAL Technical Bases EP-SC-1 11-227 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 4 - RCS Temperature Initiating Condition: UNPLANNED loss of decay heat removal capability with irradiated fuel in the Reactor Vessel Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CU4.1 - UNUSUAL EVENT EAL: Basis: This EAL is a precursor of more serious conditions and, as a result, is considered to be a potential degradation of the level of safety of the plant. In cold shutdown, the ability to remove decay heat relies primarily on forced cooling flow. Operation of the systems that provide this forced cooling may be jeopardized due to the unlikely loss of electrical power or RCS inventory. Since the RCS usually remains intact in the Cold Shutdown mode a large inventory of water is available to keep the core covered. During refueling, the level in the Reactor Vessel will normally be maintained above the Reactor Vessel flange. Refueling evolutions that decrease water level below the Reactor Vessel flange are carefully planned and procedurally controlled. Loss of forced decay heat removal at reduced inventory may result in more rapid increases in RCS temperatures depending on the time since shutdown. Escalation to ALERT would be via EAL CA3.1 based on an inventory loss or EAL CA4.1 based on exceeding its temperature criteria. Explanation/Discussion/Definitions: The Technical Specification cold shutdown temperature limit is 200 0 F. RCS coolant temperature may be indicated by the following instrumentation: o Core exit TCs (computer points T0031A, T0022A, T0046A, T0014A) 

    " Hot Leg temperatures (computer points T0419A, T0439A, T0459A, T0479A)

Salem Page 1 of 2 Rev. 0 (draft E) EAL#: CU4o I]

SGS ECG - EAL Technical Bases EP-SC-111-227 o RHR HX inlet temperatures (computer points T0630A and T0631A) o RHR HX outlet temperatures (T0627A, T2360A) o RCS cold leg temperatures (T0406A, T0426A, T0446A, T0466A) Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, CU4 Example EAL #1
2. SGS Technnical Specifications Table 1.1, Operational Modes
3. 1(2)OP-AB.RHR-0001(Q) Loss of RHR
4. 1(2)OP-AB.RHR-0002(Q) Loss of RHR at Reduced Inventory
5. SC.OP-DL.ZZ-0011(Q) Reactor Coolant System Heatup/Cooldown Log Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: CU4o1

SGS ECG - EAL Technical Bases EP-SC-1 11 -227 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 4 - RCS Temperature Initiating Condition: UNPLANNED loss of decay heat removal capability with irradiated fuel in the Reactor Vessel Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CU4.2 - UNUSUAL EVENT EAL: An UNPLANNED Loss of Decay Heat Removal functions AND Loss of BOTH of the following: All RCS Temperature indication

  • All RCS level indication AND

> 15 minutes have elapsed (Note 3) Note 3: The Emergency Coordinator should NOT wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time. Basis: This EAL is be a precursor of more serious conditions and, as a result, is considered to be a potential degradation of the level of safety of the plant. In cold shutdown, the ability to remove decay heat relies primarily on forced cooling flow. Operation of the systems that provide this forced cooling may be jeopardized due to the unlikely loss of electrical power or RCS inventory. Since the RCS usually remains intact in the Cold Shutdown mode a large inventory of water is available to keep the core covered. During refueling, the level in the RCS will normally be maintained above the Reactor Vessel flange. Refueling evolutions that decrease water level below the Reactor Vessel flange are carefully planned and procedurally controlled. Loss of forced decay heat removal at reduced inventory may result in more rapid increases in RCS temperatures depending on the time since shutdown. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CU4.2

SGS ECG - EAL Technical Bases EP-SC-1 11 227 Normal means of RCS temperature indication and RCS level indication may not be available in the refueling mode. Redundant means'of RCS level indication are therefore procedurally installed to assure that the ability to monitor level will not be interrupted. However, if all level and temperature indication were to be lost in either the Cold Shutdown of Refueling modes, this EAL would result in declaration of a UE if both temperature and level indication cannot be restored with~in 15 minutes from the loss of both means of indication. Escalation to ALERT would be via EAL CA3.1 based'on an inventory loss or EAL CA4.1 based on exceeding its temperature criteria. Explanation/Discussion/Definitions: RCS water level is normally monitored using the instrument ranges in Attachment 2, page 10. During refueling, the reactor head and associated RVLIS piping are removed. Visual observation by personnel on the refuel floor in communication with the Control Room may also provide indication of refueling cavity water level and RCS water level. RCS coolant temperature may be indicated by the following instrumentation: o Core exit TCs (computer points T0031A, T0022A, T0046A, T0014A) o Hot Leg temperatures (computer points T0419A, T0439A, T0459A, T0479A) o RHR HX inlet temperatures (computer points T0630A and T0631A)- o RHR HX outlet temperatures (T0627A, T2360A) o RCS cold leg temperatures (T0406A, T0426A, T0446A, T0466A) Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, CU4 Example EAL #2
2. Si (S2).OP-SO.RC-0005(Q) Draining the Reactor Coolant System to > 100 Foot Elevation
3. 51 (S2).OP-SO.RVL-0001 Reactor Vessel Level Instrumentation System
4. UFSAR 5.6.5 Reactor Vessel Water Level
5. UFSAR 7.3.1.1.9 Instrumentation Used During a Loss of Coolant Accident (LOCA)
6. 1(2)OP-AB'.RHR-0001(Q) Loss of RHR
7. 1(2)OP-AB.RHR-0002(Q) Loss of RHR at Reduced Inventory
8. SC.OP-DL.ZZ-001 1(Q) Reactor Coolant System Heatup/Cooldown Log Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: CU4,2

SGS ECG - EAL Technical Bases EP-SC-1 11-227 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 4 - RCS Temperature Initiating Condition: Inability to maintain plant in cold shutdown Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CA4.1 - ALERT EAL: An UNPLANNED event results in RCS temperature > 200'F for > Table C-3 duration OR An UNPLANNED event results in RCS pressure increase > 10 psig due to a loss of RCS cooling (this portion of the EAL does NOT apply in Solid Plant conditions) Table C-3 RCS Heatup Duration Thresholds RCS Integrity CONTAINMENT CLOSURE Duration Threshold Intact AND NOT in reduced NOT Applicable 60 minutes ** inventory status NOT Intact OR Established 20 minutes ** RCS is in a reduced inventory status NOT Established 0 minutes 

      ** IF a Decay Heat Removal System is placed in operation within the duration threshold and RCS Temperature is lowering, THEN this EAL is NOT Applicable Salem                                         Page 1 of 4                            Rev. 0 (draft E)

EAL#:CA4.1

SGS ECG - EAL Technical Bases EP-SC-1 11-227 Basis: 1 st Condition The RCS Heatup Duration Threshold table addresses complete loss of functions required for core cooling for greater than 60 minutes during Refueling and Cold Shutdown modes when RCS integrity is established. RCS integrity should be considered to be in place when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams). The status of CONTAINMENT CLOSURE in this condition is immaterial given that the RCS is providing a high pressure barrier to fission product release to the environment: The 60 minute time frame should allow sufficient time to restore cooling without a substantial degradation in plant safety. The RCS Heatup Duration Threshold table also addresses the complete loss of functions required for core cooling for greater than 20 minutes during Refueling and Cold Shutdown modes when CONTAINMENT CLOSURE is established but RCS integrity is not established or RCS inventory is reduced (e.g., mid-loop operation in PWRs). The allowed 20 minute time frame was included to allow operator action to restore the heat removal function, if possible. Finally, complete loss of functions required for core cooling during Refueling and Cold Shutdown modes when neither CONTAINMENT CLOSURE nor RCS integrity are established. RCS integrity is in place when the RCS pressure boundary is in its, normal condition for the cold shutdown mode of operation. (e.g., no freeze seals or nozzle dams). No delay time is allowed because the. evaporated 'reactor coolant that may be released into the Containment during this heatup con.diti.on could al.so be. directly.released to theenvironment. The note (**) in Table C-3 indicates that this EAL is not applicable if actions are successful in restoring a decay heat removal system to operation and RCS temperature is being reduced within the specified time frame. 2nd Condition . The 10 psig pressure increase addresses situations where, due to high decay heat loads, the time provided to restore temperature control, should be less than 60 minutes. The RCS pressure setpoint chosen should be 10 psig or the lowest pressure that the site can read on installed Control Board instrumentation that is equal. to or greater than 10 psig. Escalation to SITE AREA EMERGENCY would be via EAL CS3.2 should boiling result in significant RCS level loss leading to core uncovery. A loss of Technical Specification components alone is not intended to constitute an ALERT. The same is true of a momentary unplanned excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available. The Emergency Coordinator must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is IMMINENT. If, in the judgment of the Emergency Salem Page 2 of 4 Rev. 0 (draft E) EAL#:CA4o]

SGS ECG - EAL Technical Bases EP-SC-1 11-227 Coordinator, an IMMINENT situation is at hand, the classification should be made as if the threshold has been exceeded. Expla nation/Discussion/Definitions: 200°F is the Technical Specification cold shutdown temperature limit. 10 psig is one-half of the 20 psig minor division on 1(2)PI-403. This instrument has a range of 0 to 600 psig. This RCS pressure indication is also displayed on SPDS Point U1(2)PT0403S and P250 Computer Point P0499A. "Intact" is defined as all RCS penetrations between the core and Containment atmosphere are isolated, and a minimum of two RCS loops with U-tubes not drained and their associated Steam Generators are available as heat sinks for natural circulation. "Available as Heat Sinks" indicates each associated Steam Generator has a feed makeup source available, secondary water level is above the U-tubes, and a Steam Generator vent path exists. A "Reduced Inventory" condition exists when Reactor Vessel level is less than 101 ft. RCS coolant temperature may be indicated by the following instrumentation: o Core exit TCs (computer points T0031A, T0022A, T0046A, T0014A) o Hot Leg temperatures (computer points T0419A, T0439A, T0459A, T0479A) o RHR HX inlet temperatures (computer points T0630A and T0631 A) o RHR HX outlet temperatures (T0627A, T2360A) o RCS cold leg temperatures (T0406A, T0426A, T0446A, T0466A) Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. CONTAINMENT CLOSURE: Is the Salem procedurally defined action taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. CONTAINMENT CLOSURE status is checked and verified using S1(S2).OP-AB.CONT-0001 (Q). IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). Salem Page 3 of 4 Rev. 0 (draft E) EAL#: CA4o II

SGS ECG - EAL Technical Bases EP-SC-1 11-227 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, CA4 Example EAL #1 & #2
2. OU-AA-103 Shutdown Safety Management Program
3. S1 (S2).OP-AB.CONT-0001 (Q) Containment Closure
4. S1(S2).OP-ST.CAN-0007(Q) Refueling Operations - Containment Closure
5. SGS Technical Specifications Table 1.1 Operational Modes
6. S1(S2).IC-CC.RCP-0070(Q) 1(2)PT-403 Reactor Coolant System Hot Leg Pressure Channel II
7. SI(S2).OP-SO.RC-0005(Q) Draining The Reactor Coolant System To >101 Foot Elevation
8. UFSAR 5.6.5 Reactor Vessel Water Level
9. S1(S2).OP-SO.RVL-0001 Reactor Vessel Level Instrumentation System, Note pg 16
10. 1(2)OP-AB.RHR-0001(Q) Loss of RHR
11. 1(2)OP-AB.RHR-0002(Q) Loss of RHR at Reduced Inventory
12. SC.OP-DL.ZZ-001 1(Q) Reactor Coolant System Heatup/Cooldown Log Salem Page 4 of 4 Rev. 0 (draft E)

EAL#: CA4. i

SGS ECG - EAL Technical Bases EP-SC-1 11-228 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 5 - Communications Initiating Condition: Loss of all onsite or offsite communications capabilities Mode Applicability: 5 - Cold Shutdown, 6 - Refueling, D - Defueled EAL# & Classification Level: CU5.1 - UNUSUAL EVENT EAL: Loss of all Table C-4 Onsite communication methods affecting the ability to perform routine operations OR Loss of all Table C-4 Offsite communication methods affecting the ability to perform offsite notifications Table C-4 Communications Systems System Onsite Offsite Direct Inward Dial System (DID) X X Station Page System (Gaitronics) X Station Radio System X Nuclear Emergency Telephone X System (NETS) Centrex Phone System (ESSX) X NRC (ENS) X Salem Page 1 of 4 Rev. 0 (draft E) EAL#: CU 5. l

SGS ECG - EAL Technical Bases EP-SC-1 11-228 Basis: The purpose of this EAL is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate issues with off-site authorities. The loss of off-site communications ability is expected to be significantily more comprehensive than the condition addressed by 10 CFR 50.72, The availability of one method of ordinary off-site .communications is sufficient to inform federal, state, and local authorities of plant issues. This EAL is intended to be used only when extraordinary means (e.g., relaying of information from radio transmissions, individuals being sent to off:site locations; etc.) are being utilized to make communications possible. Explanation/Discussion/Definitions: Onsite and Offsite global communications include one or more of the systems listed in Table C-4. Direct Inward Dial System (DID) Direct Inward Dial (DID) system is named for the dominant feature of the commercial telephone service priovided by the local telephone company for the site. DID allows station telephones to be extensions or tied lines of the same systems. These exchanges can take advantage of backup power.supplies provided to the stations, and may use either PSEG microwave, commercial telephone system microwave, or buried cable transmission systems to maintain external communications. This commercial telephone service is available as an additional backup for the NETS and Centrex/ESSX.1 system. Station Page System (Gaitronics) Gaitronics is a completely transistorized voice communication system with five 'Voice channels: one page and five party. The system is designed for use in extreme environmental conditions such as dust, moisture, heat and noise. The system consists of handsets, speakers and their associated amplifiers. The power for this system is 120 volts AC from an inverted DC source to provide reliable communications during an emergency. Station Radio System The Operations and Fire Protection Department UHF radio system is a multi-frequency system used routinely by both station Operations Departments and the Fire Protection Department. When an emergency event is declared, these radio frequencies serve both station Operations Support Centers (OSC). Salem .. Page 2 of 4 Rev. 0 (draft E) EAL#: C U5.11

SGS ECG - EAL Technical Bases EP-SC-1 11-228 Nuclear Emergency Telephone System (NETS) The Nuclear Emergency Telecommunications System (NETS) is a privately controlled, self-contained telephone exchange that operates as a closed system, not accessible from other phone exchanges. This feature allows the system to be dedicated to emergency response use. The system may use PSEG microwave, commercial telephone system microwave, fiber optics, or buried cable transmission as needed. The exchange switching equipment is maintained at the Environmental & Energy Resource Center (EERC). As an independent system with an uninterruptible power supply, it may operate with or without local phone service or external power. Centrex Phone System (ESSX) The Centrex/Electronic Switch System Exchange 1(Centrex/ESSX 1) is also a privately controlled exchange, which PSEG operates with its own microwave signal system. This system is also independent of local phone service, since each circuit is independently wired. The microwave signal is generated from corporate facilities in Newark, NJ, separated from any local effects of weather or telephone use. The exchange is accessible from other exchanges, but circuits are located only in PSEG facilities. It is considered the primary backup for the NETS system. NRC (ENS) The Emergency Notification System (ENS) is a dedicated communications system with the NRC, which is part of the Federal Telecommunications System (FTS) and consists of direct lines to the NRC. FTS lines are used to provide general accident information. These telephones are installed in the Control Room, TSC, and the EOF. This EAL is the cold condition equivalent of the hot condition EAL SU6.1. EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, CU6 Example EAL #1 and 2
2. PSEG Nuclear Emergency Plan, Section 7 Communications
3. UFSAR 9.5.2 Communications System Salem Page 3 of 4 Rev. 0 (draft E)

EAL#:CU5,

SGS ECG - EAL Technical Bases EP-SC-1 11 -228 This page intentionally blank Salem Page 4 of 4 Rev. 0 (draft E) EAL#: CUM

SGS ECG - EAL Technical Bases EP-SC-1 11-229 EAL Category: C - Cold Shutdown / Refuel System Malfunction EAL Subcategory: 6 - Inadvertent Criticality Initiating Condition: Inadvertent Criticality Mode Applicability: 5 - Cold Shutdown, 6 - Refueling EAL# & Classification Level: CU6.1 - UNUSUAL EVENT EAL: UNPLANNED sustained positive startup rate observed on nuclear instrumentation Basis: This EAL addresses criticality events that occur in Cold Shutdown or Refueling modes such as fuel mis-loading events. This EAL indicates a potential degradation of the level of safety of the plant, warranting a UE classification. Escalation would be by Emergency Coordinator Judgment. Explanation/Discussion/Definitions: The term "sustained" is used in order to allow exclusion of expected short term positive startup rates from planned fuel bundle or control rod movements during core alteration. These short term positive startup rates are the result of the increase in neutron population due to subcritical multiplication. Positive reactor startup rate may be identified by: o Source range startup rate indicators N131 D and N132D o NIS Recorder NR45 o Audio count rate o SPDS o Process Computer This EAL is the cold condition equivalent of the hot condition EAL SU3.1. Definitions: UNPLANNED: A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions. Salem Page 1 of 2 Rev. 0 (draft E) EAL#:CU oi

SGS ECG - EAL Technical Bases EP-SC-111-229 EAL Bases Reference(s):

1. NEI 99-01, Rev. 05, CU8 Example EAL #1
2. Technical Specifications 3.3.1.1 Reactor Trip System Instrumentation
3. UFSAR Table 7.5-2 Main Control Room Indicators
4. SC.IC-CC.NIS-0011(Q) N31 Source Range
5. SC.IC-CC.NIS-0012(Q) N32 Source Range Salem Page 2 of 2 Rev. 0 (draft E)

EAL#: CUJ°*.1

EAL Attachments (Support Materials)

SGS ECG - EAL Technical Bases EP-SC-1 11-230 Attacment Use of Fiso Product Barrier Thb~e Mode Applicability: 1 - Power Operations, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown A point system is used to determine the Emergency Classification Level based on the Fission Product Barrier Table. Each Fission Product Barrier Loss and Potential Loss threshold is assigned a point value as noted below. Perform the following:

1. Review all columns of the Fission Product Barrier Table and identify which need further review.
2. For each of the three barriers, determine the EAL with the highest point value. No more than one EAL should be selected for each barrier.
3. Add the point values for the three barriers.
4. Classify based on the point value sum as follows:

If theIs:sum Classify as: ECG EAL Att# is: At UNUSUAL ANY loss or ANY potential EVENT loss of Containment 1 ANY loss or ANY potential 4, 5 ALERT loss of either Fuel Clad or 2 RCS Loss or potential loss of ANY two barriers 3 6-11 SITE AREA OR EMERGENCY Potential loss of 2 barriers with the loss of the 3rd barrier Loss of ANY two barriers 12,13 GENERAL AND 4 EMERGENCY Loss or potential loss of third barrier

5. Implement the appropriate ECG Attachment.
6. Continue to review the Fission Product Barrier Table for changes that could result in emergency escalation or de-escalation.

Salerr Page 1 of 1 Rev. 0 (draft E) Attaclhmenst I- Use of Tahle

SGS ECG - EAL Technical Bases EP-SC-1 11-231 Attachment 2 - EAL Basis Figures Figures referenced in the basis discussions of the EALs are listed in this Attachment. Title Page No. AC Power Distribution 2 CFST - Core Cooling 4 CFST - Shutdown Margin 5 CFST - Heat Sink 6 CFST - Thermal Shock 7 Thermal Shock Limit A Curve 8 CFST - Containment Environment 9 RCS Level Instrument Ranges 10 Salem Page 1 of 10 Rev. 0 (draft E) Figures

SGS ECG - EAL Technical Bases EP'SC-1 11-231 AC Power Distribution The 500-kV switching station is connected to three 500-kV transmission lines. Two transmission lines go north to two major switching stations: PSE&G New Freedom Switching Station and Atlantic City Electric's Orchard Switching Station. The New Freedom Switching Station is connected to the PSE&G 230-kV bulk power system via four 500/230-kV autotransformers. Orchard Switching Station is also connected to Atlantic City Electric's 230-kV bulk power systerm via a 500/230-kV autotransfornier. In addition, it is connected to the Pennsylvania / New Jersey / Maryland 500-kV interconnected system. The third transmission line serves as a tie line to the adjacent Hope Creek 500-kV switchyard line which is also integrated into the Pennsylvania / New Jersey / Maryland 500-kV interconnected system. The 500-13 kV tation power transformers are connected to different bus sections of the 500-kV switching station: o 13-kV north ring bus: Each 500-13 kV transformer T1 and T2 feeds two (one for each unit) 13-4 kV station power transformers T1 1, T21 and T1 2, T22 associated with group buses. o 13kV south bus: Each 500-13kV transformer T3 and T4 respectively and feeds two (one for each unit) 13 4kV station power transformers T1 3, T24 and T1 4, T23 associated with vital buses and circulating water switchgear. The 13-4kV station power transformers T13 and T14 (Unit 1) share the loads of three vital buses and two C W bus sections while T21 and T22 (Unit 2) share the loads of three vital buses and two CW bus sections. The onsite power sources for each unit consists of the main generator, the emergency diesel generators (one for each vital bus), and the Unit 3 40-MW gas turbine generator (one for both units). Any two EDGs and their associated vital buses can supply sufficient power for operation of the required safeguards equipment for a design basis LOCA coincident with a loss of offsite power. For the purposes of the EAL, availability of EDGs that have not been challenged to start during degradation of AC power sources to the 4KV :vital buses'should be based on meeting Technical Specification action requirements for loss of offsite AC power sources. The gas turbine generator can be manually started and paralleled with normal. sources of plant startup or standby power but is normally used for peaking purposes. Procedure AB.LOOP-0001(Q) provides guidance to use the gas turbine to energize a 13KV ring bus during a blackout if necessary. The gas turbine generator is not controlled by technical specifications, however, and for classification purposes under this EAL cannot be credited as a power source for the 4KV vital buses. Salem Page 2 of 10 Rev. 0 (draft E) FIgures

SGS ECG - EAL Technical Bases EP-SC-1 11-231 AC Power Distribution (cont'd) IqErRw IM.-D 0 W 500KV RING taUS r DEANS' 2T' " 5321 DISC 1-5 

                        -        -   -     -"       -    ---     "=-------

j HOPE CREEK 1.17 iiL iz -",_ ....J , . _f ,/ ,= ........ .......T2_,.* SSALEM IT 1 U2 NT p Cr IU3 3-TG 13KV TS - LOAD DISCO1NNICT B3USFROM GRO)UID FAULT) 

                             'p 3T6"'

4KV GROUP 4KV GROUP 13KV SOUTH BUS Salem Page 3 of 10 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-231 CFST - Core Cooling Salem Page 4 of 10 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-231 CFST - Shutdown Margin G E F4 YELLU 'EEN ~ELL7~f T F q,6T Salem Page 5 of 10 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-231 CFST - Heat Sink YELLCTa  ;,;ELLD rELL~g YELL&M R'-.5H F1;HS-Al FRNS-J RH-Salem Page 6 of 10 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-231 CFST - Thermal Shock Salem Page 7 of 10 Rev. 0 (draft E) Figures

SGS ECG " EAL Technical Bases EP-SC-1 11-231 Thermal Shock Limit A Curve f,-zfTS- PL ANT UPEF ATION AL LIMITS CURVE I *j' TEW&PERATIJRE ý5F Salem Page 8 of 10 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-231 CFST - Containment Environment LE-::'-: THRNA 7E~ YE&S H4D iPCEL Lil Salem Page 9 of 10 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-231 RCS Level Instrument Ranges CAVITY LEVEL 13W; 

 ,CAL MED LOO P WIDE RANGE               GLASS LEVEL               tNDiC:ATION 111' R'I!LS REWU<CFD

[WNViTORY MIfDLOO:O GME LEVEL. MDICATION 97-D Salem Page 10 of 10 Rev. 0 (draft E) Mgiuraz

SGS ECG - EAL Technical Bases EP-SC-1 11-232 Attachment 3 - Definitions Selected words in the ECG Initialting Conditions (ICs) and Emergency Action Levels (EALs) have been set in all capital letters and bolded.These words are defined terms having specific meanings as they relate to this document and the definitions of these terms are provided below and in the basis for the EAL that the word is used in. AIRCRAFT: Includes both small and large AIRCRAFT. Examples of AIRCRAFT include general aviation Cessna, Piper and Lear type private planes, large passenger or freight planes as well as police, medical and media helicopters. A large AIRCRAFT is referred to as an AIRLINER. AIRLINER/LARGE AIRCRAFT: Any size or type of AIRCRAFT with the potential for causing significant damage to the plant (refer to the Security Contingency Plan for a more detailed definition). BOMB: Refers to an explosive device suspected of having sufficient force to damage plant systems or structures. CIVIL DISTURBANCE: A group of persons violently protesting station operations or activities at the site. CONFINEMENT BOUNDARY: Is the barrier(s) between areas containing radioactive substances and the environment and includes the multi-purpose canister (MPC) and, for the purposes of this EAL, the associated cask shielding. CONTAINMENT CLOSURE: Is the Salem procedurally defined action taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. CONTAINMENT CLOSURE status is checked and verified using S(S2).OP-AB.CONT-0001(Q). CREDIBLE / ACTUAL THREAT: Is a threat which poses a likely and serious danger to the safe operation of the facility or to site personnel and public safety. DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability: o Electrical faults on power supplies Salem Page 1 of 4 Rev. 0 (draft E)

SGS ECG EAL Technical Bases EP-SC-1 11-232 o Normally closed breakers in tripped position o System annunciators activated o System warning lights lit.-- o Insufficient system pressure from keep-fill pumps o Elevated area temperatures or radiation levels o Increased sump purnp o'perati6n in areas in' which the system is located EXPLOSION: A rapid, Violent, Uruconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components. FAULTED: (PWRs) In a steam generator, the existence of secondary side leakage that results in an uncontrolled drop in steam generator pressure or the steam generator being completely depressurized. FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NoT required if large quantities of smoke aind heat are observed. HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station". HOSTILE ACTION: An act toward Salem or Hope Creek or its personnel that includes the Use of violent force to destroy equipment, take HOSTAGES, and/or intimidate PSEG to achieve an end. This includes attack by ai'r, larnd, or water using guns,' explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should pot beconstrued to include acts of civil disobedience or felonious acts that are nrotpart of a' concerted attack" on' Salem or Hope Creek. Non-terrorism-based EALs should be used to address such activities (i.e., this may include Violet' acts bet'weenind ivdua in the OCA). HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly. or by stealIth and deception, ecuipped with suitable weapons capable of killing, maiming, or causing destruction. IDENTIFIED LEAKAGE: As defined in T/S, shall be leakage'(except Reactor Coolant Pump Seal Water Injection) into closed systemris, such as pump seal or valve packing leaks that are captured and conducted to a sump or ollecting ta.nk, or, shall be leakage into the containment atmosphere from souirices"that are both spebcificaily'located "and knownh"either not to interfere with the operation of the leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE, or, shall be Reactor coolant system leakage through a' steam geinerator to the secondary system (primary-to-secondary leakage). Salem Page 2 of 4 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-111-232 IMMINENT: Mitigation actions have been ineffective, additional actions are not expected to be successful, and trended information indicates that the event or condition will occur within approximately 2 hours (unless a different time is specified). INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. MALICIOUS ACT: Purposeful malevolent actions directed at compromising reactor safety and thus could directly or indirectly endanger the public health and safety. MINIMUM EXCLUSION AREA (MEA): The closest location just beyond the OWNER CONTROLLED AREA where a member of the general public could gain access. For Salem the MEA is 0.79 miles. NORMAL PLANT OPERATIONS: Activities at the plant site associated with routine testing, maintenance, or equipment operations, in accordance with normal operating or administrative procedures. Entry into abnormal or emergency operating procedures, or deviation from normal security or radiological controls posture, is a departure from NORMAL PLANT OPERATIONS. OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA. PRESSURE BOUNDARY LEAKAGE: As defined in T/S, shall be leakage (except steam generator tube leakage) through a non-isolable fault in a Reactor Coolant System component body, pipe wall or vessel wall. PROJECTILE: An object that impacts Salem and/or Hope Creek that could cause concern for continued operability, reliability, or personnel safety. PROTECTED AREA (PA): A security controlled area within the OWNER-CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center. RUPTURED: (PWRs) In a steam generator, existence of primary-to-secondary leakage of a magnitude sufficient to require or cause a reactor trip and safety injection. SABOTAGE: Deliberate damage, mis-alignment, or mis-operation of plant equipment with the intent to render the equipment inoperable. Equipment found tampered with or damaged due to malicious mischief may not meet the definition of SABOTAGE until this determination is made by security supervision. Salem Page 3 of 4 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-111-232 SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that~constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION. SIGNIFICANT.TRANSIENT: An.UNPLANNED event based on EC judgment, but includes as a minimum any one of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, or (4) Safety Injection Activation. TAMPERING: Means deliberately damaging, disabling, or altering equipment necessary for safe shutdown or security equipment'necessary for the protection of the facility. Confirmed tampering implieS that a criminal activity may have occurred Which requires'a threshold'of proof for a reason to believe that no other possibility exists for the incident other than tampering. UNIDENTIFIED LEAKAGE: As defined in T/S, shall be all leakage which is not IDENTIFIED LEAKAGE.- UNISOLABLE: A breach or leak that cannot be promptly isolated from the Control Room. UNPLANNED: A parameter change. odr an event that is not the result of an intended evolution and requires. corrective .or mitigative actions. VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument. channel check, (2). indications on related or redundant indicators, or (3) by direct observation by plant personnel,- suchthat dbubt'related to the indicator's operability, the: condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment. VALIDATED: AIRCRAFT threat call from the NRC that is confirmed to be authentic.. Calls from the NRC are VALIDATED by use of the NRC provided authentication code or by making a return call to the NRC Headquarter Operations Center and confirming threat information with the NRC Operation Officer. AIRCRAFT threat calls from other agencies, NORAD, FAA, or FBI should' be VALIDATED by callind-the"_ NRC Operations Officer. VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or cbmponent. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, and paint blistering. Surface- blem'ishes (e.g., paint chipping, scratches) should not be included.- VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. Salem-- Page 4 of 4 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-233 Attachment 4 - Glossary of Abbreviations & Acronyms Acronyms and Abbreviations used in the ECG and ECG basis document are listed in this attachment. AAAG - Accident Assessment Advisory Group (Delaware) AB - Auxiliary Building AC - Alternating Current ADMSS - Administrative Support Supervisor - TSC AFST - Auxiliary Feedwater Storage Tank AFW - Auxiliary Feedwater ALARA - As Low As Reasonably Achievable ARM - Area Radiation Monitor ASAP - As Soon As Possible ASM - Administrative Support Manager ATWT - Anticipated Transient Without Trip Aux - Auxiliary BKGD - Background BKR - Breaker (electrical circuit) BLDG - Building BNE - Bureau of Nuclear Engineering (NJDEPE) CAS - Central Alarm Station CCPM - Corrected Counts per Minute CEDE - Committed Effective Dose Equivalent CDE - Committed Dose Equivalent CET - Core Exit Thermocouple CFCU - Containment Fan Coil Unit CFR - Code of Federal Regulations CFST - Critical Safety Function Status Tree CIS - Containment Isolation System CM1 - Primary Communicator (CR) CM2 - Secondary Communicator (CR) CNTMT - Containment (Barrier) CoC - Certificate of Compliance CO 2 Carbon dioxide CP - Control Point CPM - Counts Per Minute CPS - Counts Per Second CR - Control Room CRS - Control Room Supervisor CREF - Control Room Emergency Filter System Salem Page 1 of 6 Rev. 0 (draft E) Abbrevatons & Acronyms

SGS ECG - EAL Technical Bases EP-SC-1 11-233 CVCS Chemical and Volume Control System DC - Direct Current DDE - Deep Dose Equivalent DEI - Dose Equivalent Iodine DEMA -. Delaware Emergency Management Agency DEP - Department of Environmental Protection (NJ) DHS - Department of Homeland Security DID - Direct Inward Dial"(phone system) DOE - Department of Energy DOT - Department of Transportation DPCC/DCR - Discharge Prevention, Containment, & Countermeasures/Discharge Cleanup & Removal Plan DPM Decades per Minute , DPM Disintegrations per Minute DRCF Dose Rate Conversion Factor EACS - Emergency Air Conditioning System. (Control Room) EAL - Emergency Action Level mR EAS - Emergency Alert System (Broadcast) ECCS - Emergency Core Cooling Systems ECG - Event Classification Guide EC - Emergency Coordinator EDG - Emergency Diesel Generator ... EDO - Emergency Duty Officer .. . EERC - Energy & Environmental Resource Center.(Old NTC) EMRAD - Emergency Radio (NJ) ENC - Emergency News Center ENS - Emergency Notification System (NRC) EOC - Emergency Operations Center. (NJ & DE). EOF - Emergency Operations Facility EOP - Emergency Operating Procedures, EPA - Emergency Preparedness Advisor EPA - Environmental Protection Agency EPIP - Emergency Plan Implementing Procedure. EPM - Emergency Preparedness Manager EPZ - Emergency Planning Zone (Plume EPZ = 10 Miles, Ingestion EPZ = 50 miles) ERDS - Emergency Response Data System ERF - Emergency Response Facility ERM - Emergency Response Manager ERO - Emergency Response Organization ESF - Engineered Safety Feature ESSX - Electronic Switch System Exchange (centrex) (Newark 973 Exchange phone system) FAA - Federal Aviation Administration Salem Page 2 of 6 Rev. 0 (draft E) Abbrevo'aUons a Acronyms

SGS ECG - EAL Technical Bases EP-SC-1 11-233 FBI - Federal Bureau of Investigation FC - Fuel Clad (Barrier) FFD - Fitness For Duty FHB - Fuel Handling Building FPB - Fission Product Barrier FRCC - Functional Restoration Core Cooling FRCE - Functional Restoration Containment Environment FRCI - Functional Restoration Coolant Inventory FRERP - Federal Radiological Emergency Response Plan FRHS - Functional Restoration Heat Sink FRSM - Functional Restoration Shutdown Margin FRTS - Functional Restoration Thermal Shock FTS - Federal Telecommunications System (NRC) GE - General Emergency HCGS - Hope Creek Generating Station HEPA - High Efficiency Particulate Absorbers HP - Health Physics HVAC - Heating, Ventilation & Air Conditioning HX - Heat Exchanger lAW - In Accordance With IC - Initiating Condition ICMF - Initial Contact Message Form IDLH - Immediately Dangerous to Life and Health IPEEE - Individual Plant Examination of External Events IR - Intermediate Range ISFSI - Independent Spent Fuel Storage Installation UIS - In Service ISOL - Isolation Keff - Effective Neutron Multiplication Factor KI - Potassium Iodide KV - Kilovolt (1000 volts) LAC - Lower Alloways Creek LCO - Limiting Condition for Operation LDC - Learning Development Center (aka - NAB or TB2) LDE - Lens Dose Equivalent LEL - Lower Explosive Limit LFL - Lower Flammability Limit LLD - Lowest Level Detectable LOCA - Loss of Coolant Accident LOP/LOPA - Loss of Offsite Power/ Loss of Offsite Power Accident Salem Page 3 of 6 Rev. 0 (draft E) Abbrv'Mons& Aronyms

SGS ECG - EAL Technical Bases EP-SC-1 11 -233 LPZ - Low Population Zone MBD - Mixed Bed Demineralizer MDA - Minimum Detectable Amount MEA - Minimum Exclusion Area (Salem = .79 miles, HC = .56 miles) MEES - Major Equipment & Electrical Status (Form) MET - Meteorological MIDAS - Meteorological Information Data Acquisition System MIMS - Metal Impact Monitoring System MOU - Memorandum of Understanding MRO - Medical Review Officer. MSIV - Main Steam Isolation Valve MSLI - Main Steam Lihe Isolation NAB - Nuclear Administration Building (aka - LDC or TB2) NAWAS - National Attack Warning Alert System NCO - Nuclear Control Operator NEI - Nuclear Energy Institute., NEO - Nuclear Equipment Operator NETS - Nuclear Emergen*'cy,Telecommunications System, NFE - Nuclear Fuels Engineer NFPB - Normal Full Power Background NG - Noble Gas NJSP - New Jersey State Police NOAA - National Oceanographic and Atmospheric Administration NOSF - Nuclear Operation's Support Facility NR - Narrow Range NRC - Nuclear Regulatory Commission NSP - Nuclear Site Protection-NUMARC - Nuclear Management and Resources Council: NWS - National Weather Service OBE - Operating Basis Earthquake OCA - Owner Controlled Area ODCM - Offsite Dose Calculation Manual OEM - Office of Emergency Management OHA - Overhead Annunciators OSB - Operational Status Board (Form) OSC - Operations Support Center PAG - Protective Action Guideline PAR - Protective Action Recommendation PIM - Public Information Manager PMP - Pump PORV - Power Operated Relief Valve Salem Page 4 of 6 Rev. 0 (draft E) Abbev'a'o& Acronms

SGS ECG - EAL Technical Bases EP-SC-1 11-233 PRT - Pressurizer Relief Tank PSEG - Public Service Enterprise Group PSIA - Pounds per Square Inch Absolute PSIG - Pounds Square Inch Gauge PWR - Pressurized Water Reactor PWST - Primary Water Storage Tank PZR - Pressurizer RAC - Radiological Assessment Coordinator RAD - Radiation RAL - Reportable Action Level RC - Reactor Coolant RCA - Radiologically Controlled Area RCAM - Repair and Corrective Action Mission RCDT - Reactor Coolant Drain Tank RCP - Reactor Coolant Pump RCS - Reactor Coolant System (Barrier) RHR - Residual Heat Removal RM - Recovery Manager RMO - Recovery Management Organization RMS - Radiation Monitoring System ROIC - Regional Operations & Intelligence Center (NJSP) RPS - Radiation Protection Supervisor RPS - Reactor Protection System RRC - Remote Response Center (in NOSF) RSM - Radiological Support Manager RVLIS - Reactor Vessel Level Instrumentation System RWS.T - Refueling Water Storage Tank SAE - Site Area Emergency SAM - Severe Accident Management SAS - Secondary Alarm Station (Security) SAT - Satisfactory SBO - Station Blackout SCBA - Self Contained Breathing Apparatus SCP - Security Contingency Procedure SDE - Shallow Dose Equivalent SDM - Shutdown Margin SFP - Spent Fuel Pool S/G - Steam Generator SGS - Salem Generating Station SGTR - Steam Generator Tube Rupture SI - Safety Injection SJAE - Steam Jet Air Ejector Salem Page 5 of 6 Rev. 0 (draft E) Abbreaons & Acronyms

SGS ECG - EAL Technical Bases EP-SC-1 11-233 SM - Shift Manager SNM - Special Nuclear Material SOS - Systems Operations Supervisor (Security) SPDS - Safety Parameter Display System SRPT - Shift Radiation Protection Technician SSCL - Station Status Checklist (form) SSE - Safe Shutdown Earthquake SSM - Site Support Manager SSNM - Strategic Special Nuclear Material STA - Shift Technical Advisor SUR - Start-up Rate T-COLD - Temperature Cold (Leg) T-HOT - Temperature Hot (Leg) TAF - Top of Active Fuel- BWR TDR - Technical Document Room TEDE - Total Effective Dose Equivalent TOAF - Top of Active Fuel - PWR TPARD - Total Protective Action Recommendation Dose T/S - Technical Specifications TSC - Technical Support Center TSS - Technical Support Supervisor TSTL - Technical Support Team Leader TSTM - Technical Support Team Member UE Unusual Event UFSAR Updated Final Safety Analysis Report UHS Ultimate Heat Sink - USCG - United States Coast Guard VCT - Volume Control Tank VDC - Volts Direct Current VLV - Valve WB Whole Body WR Wide Range Salem Page 6 of 6 Rev. 0 (draft E) Abbrv~al&n lhroyms

SGS ECG - EAL Technical Bases EP-SC-1 11-234 Attachment 5 - SGS-to-NEI 99-01 EAL Cross-Reference This cross-reference is provided to facilitate association and location of a Salem Generating Station EAL within the NEI 99-01 IC/EAL identification scheme. Further information regarding the development of the SGS EALs based on the NEI guidance can be found in the EAL Comparison Matrix. SGS NED 99-01 EAL IC Example EAL RU1.1 AU1 1 RU1.2 AU1 1 RU1.3 AU1 3 RU2.1 AU2 1 RU2.2 AU2 2 RA1.1 AA1 1 RA1.2 AA1 1 RA1.3 AA1 3 RA2.1 AA2 2 RA2.2 AA2 1 RA3.1 AA3 1 RS1.1 ASI I RS1.2 AS1 2 RS1.3 AS1 4 RG1.1 AG1 1 RG1.2 AG1 2 RG1.3 AG1 4 CU1.1 CU3 I CU2.1 CU7 1 CU3.1 CUl 1 CU3.2 CU2 2 Salem Page I of 6 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-111-234 SGS NED 99-01 EAL C Example EAL e1U3.3 CU2 1 CU4.1 CU4 1 CU4.2 CU4 2 C.U5.1 CU6 1,_2 CU6.1 'CU8 1:: CA!1." CA3 .1. CA3.1 CA1 1-CA3.2 CAM 2 CA4A1 CA74 1,2 cs1i 3. . CS3.2 0G312 ' CG-1I 2. EUiA E-HU1 . 1 HU1.1 HU. 1 HUi.2 HU .2 HU1.3 HU 4 HU1.4 HUI. 3 HU1.5 .H1. 5 HU27.1 HU2 1-HU2 2 . HU2.2 . HU3 1. HU3W1 HU3.2' HU3. 2 HU-4.1 HU4 1,2j 3 HU6.1 HU5- 1 HA1 .1 HAl 1 HA1 .2 HAI, 2:. 

                         -HA1..      HA1,..          4 HA1.4         HA1             3 HA1.6         HAl             5 Salem                                Page 2 of 6                      Rev. 0 (draft E)

CrossoRefere ce

AL Technical Bases EP-SC-l 11-234 SGS NEI 99-01 EAL IC Example EAL HA2.1 HA2 1 HA2.2 HA2 1 HA3.1 HA3 1 HA4.1 HA4 1,2 HA5.1 HA5 1 HA6.1 HA6 1 HS4.1 HS4 1 HS5.1 HS2 1 HS6.1 HS3 1 HG4.1 HG1 1,2 HG6.1 HG2 1 SU1.1 SUl 1 SU3.1 SU8 2 SU4.1 SU2 1 SU5.1 SU3 1 SU6.1 SU6 1,2 SU7.1 SU4 1 SU7.2 SU4 2 SU8.1 SU5 1,2 SA1.1 SA5 1 SA3.1 SA2 1 SA5.1 SA4 1 SS1.1 SS1 1 SS2.1 SS3 1 SS3.1 SS2 1 SS5.1 SS6 { 1 SG1.1 SG1 1 SG3.1 SG2 1 Salem Page 3 of 6 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-111-234 Fission Product Barrier EALs SGS NEI 99-01 EAL Barrier Threshold FB1-L FC Loss 1 FB4-L FC Loss 2 FB2-L FC Loss 3 FB3-L FC Loss 6 FB5-L FC Loss 8 FB1-P FC P-Loss I FB2-P FC P-Loss I FB3-P FC P-Loss 3 FB4-P FC P-Loss 4 FB5-P FC P-Loss 8 RB2-L RCS Loss 2 RB3-L RCS Loss 4 RB1-L RCS Loss 6 RB4-L RCS Loss 8 RB1-P RCS P-Loss 1 RB2-P RCS P-Loss 1 RB3-P RCS P-Loss 2 RB4-P RCS P-Loss 8 CB1-L CNTMT Loss 2 CB2-L CNTMT Loss 2 CB3-L CNTMT Loss 4 CB4-L CNTMT Loss 4 CB5-L CNTMT Loss 5 CB6-L CNTMT Loss 8 CB1-P CNTMT P-Loss 1 CB6-P CNTMT P-Loss 2 CB7-P CNTMT P-Loss 2 Salem Page 4 of 6 Rev. 0 (draft E) Cross-Reference

SGS ECG - EAL Technical Bases EP-SC-111-234 SGS NEI 99-01 EAL Barrier Threshold CB8-P CNTMT P-Loss 2 CB3-P CNTMT P-Loss 3 CB4-P CNTMT P-Loss 3 CB5-P CNTMT P-Loss 6 CB2-P CNTMT P-Loss 7 CB9-P CNTMT P-Loss 8 Salem Page 5 of 6 Rev. 0 (draft E) Cross-Reference

SGS ECG - EAL Technical Bases EP-SC-111 This page intentionally blank Salem Page 6 of 6 Rev. 0 (draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-235 Salem Radiological EAL Setpoint Calculation Document NEf 99-01, Rev. 05 EALs

Purpose:

This is a reference document that contains the methodology and calculations used in developing the thresholds for radiological release based Emergency Action Levels (EALs). The radiological EALs covered under this document are based on EALs AU1, AA1, ASI and AGI in NEI-99-01, Rev. 05, "Methodology for Development of Emergency Action Levels". Reference Materials: o NEI 99-01, Rev. 05 - Methodology for Development of Emergency Action Levels, EALs AU1, AA1, AS! and AGI o NEI 99-01, Rev. 05 -Appendix A: Basis for Radiological Effluent EALs o Salem ODCM Rev. 24 o EPA 400-R-92-001, Manual or Protective Action Guides and Protective Actions for Nuclear Incidents Terms & Calculation Constants and origin: o ODCM - Offsite Dose Calculation Manual o Hours in one year: 365.25 days X 24 h-rs/day = 8766 hours 

,  EDE - Effective Dose Equivalent
  • CDE - Committed Dose Equivalent o CEDE - Committed Effective Dose Equivalent = CDE X Weighting Factor (thyroid per I0CFR20) o TEDE - Total Effective Dose Equivalent = EDE + CEDE o PAG - Protective Action Guideline: Per EPA = 10OOmRem TEDE dose or 5000 lnRem thyroid dose.

Actual or projected values above these guidelines will require offsite protective actions to be implemented. o ODCM Rad Effluent Limit - 500 mRem/year is a total site Noble Gas limit that includes Salem 1, Salem 2 and Hope Creek. Therefore, Salem will have an administratively controlled limit of A/2 the total site limit or 250 mRemlyear for EAL calculation purposes. o Allocation Factor (AF) = .5 - As defined in the Salem ODCM, (page 83) this is an administrative control imposed to ensure that the combined releases from Salem Units 1 and 2 and Hope Creek will not exceed the regulatory limit from the site. The Site AF is only used in the UE and Alert EALs. Salem Page 1 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Teel-inical Bases EP-SC-l 11-235 Salem RadtologcaR EAL Setpoint Calculation Document NEIl 99o019 Rev. 05 EALs " X/Q = Site Specific Atmospheric dispersion to the site boundary. Ul and U2 Value = 2.2E-06 sec/m3 . Origin - Salem ODCM, Rev. 24, Table 2-2.1 and 2-2.2, Parameters for Gaseous Alarnm Setpoint Determinations. o DRCF = Site Specific Dose Rate Conversion Factor. Ul and U2 Value = 4.7E+02 mrern/year per uCi/ In 3 . Origin - Salem ODCM, Rev. 24, Table C-1, Effective Dose Factors, Noble Gases - Total Body and Skin - Total Body Effective Dose Factor. Index: (Radiological Release EAL Calculations) Salem EALS: Page #: Unusual Event EAL AU 1.1 - (Default Release Rate EAL) 4 Unusual Event EAL AU1.2 - (2 time alarm) No Calc needed Unusual Event EAL AU 1.3 - (Sample Analysis Concentration) 5 Unusual Event EAL AU 1.4- (Perimeter Monitoring System - NA) Unusual Event EAL AU 1.5 - (Dose Assessment - NA) Alert EAL AA1.1 - (Default Release Rate EAL) 6 Alert EAL AAI.2 - (200 time alarm) No Calc needed Alert EAL AA1.3 - (Sample Analysis Concentration) 7 Alert EAL AA1.4 - (Perimeter Monitoring System:- NA) Alert EAL AA1.5 - (Dose Assessment- NA) Site Area Emergency EAL AS 1.1 - (Default Release Rate EAL) 8 Site Area Emergency EAL ASI1.2 - (Dose Assessment) , 9 Site Area Emergency EAL ASI1.3 - (Perimeter Monitoring Sys - NA) Site Area Emergency EAL AS1.4 - (PA boundary dose rate) 10 Site Area Emergency EAL AS 1.4 - (1-131 Field Survey Sample Analysis) 11 General Emergency EAL AG1.1 - (Default Release Rate EAL) 12 General Em.ergency EAL AGI.2 - (Dose Assessment), 13 General Emergency EAL AG1.3 - (Perimeter Monitoring Sys - NA) General Emergency EAL AGI.4 - (PA boundary dose rate) 14 General Emergency EAL AG1.4 - (1-131 Field Survey Sample Analysis) 15 Salem Page 2 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-l 11-2.35 Salem Radiological EAL Setpoint Calculation Document NEE 99-01, Rev. 05 EALs Submitted By: Craig Banner Date: 12-15-2009 EP Review By: Gary Youn ,..J. Date: 12-17-2009 Technical Review: Jenny Shelton Date: 06-04-2010 Salem SFAM Review: Phil Quick Date: 06-07-2010 HC SFAM Review: Joln Molner Date: 06-04-2010 CFAM Approval: David Burgin Date: 06-09-2010 Salem Page 3 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-I 11-235 Salem Radioltogical EAL Setpoint Calculation Document NEIE 99-01.9 Rev. 05' EALs Calculation for: Unusual Event EAL AUI.1 - (Default Release Rate EAL) Objective of Calculation: Provide a Salem Radiological Release Rate value that equates to a Release that is > 2 times the ODCM limit of 500 mrReml/year. Discussion: The ODCM limit of 500 mrRem/year is a total site limit that includes Salem 1, Salem 2 and Hope Creek. Therefore, Salem 1 &2 will have an administratively controlled limit of 1A the total site limit or 250 toRerm/year for EAL calculation purposes. This EAL does not include Iodine Release Rates, since the Plant Vent does not have an Iodine detector. Release Rate = Total Noble Gas Release Rate from Salem (Unit 1 & Unit 2) which would result in a TEDE Dose Rate of 250 mRemr/year, The EAL value will be 2 times this release rate. Derivation / Calculation: Radiological ODCM Limit Calculation for Noble Gas: Release Rate (uCi/Sec) = ODGMLimit(n Re m/year) * (SiteAliocationFactor) (ODCMX /0) * (ODCMDRCF) ODCM Limit = 500 toRerN/Year 3 Salem ODCM X/Q = 2.20E-06 sec/m 3 Salem ODCM DRCF = 4.70E+02 mRemlyr/uCi/m Site Allocation Factor = 5.OOE-01 Release Rate (uCi/Sec) = (5007 Re M!/yr) * (5.00E - 01) 

                                                          +02mRen./yr.T/ kCi/1 3 )

(2. 2 0E - 06sec/In 3 ) * (4.70E+/- Release Rate = 2.42E+05 uCi/Sec (Also the ODCM Limit Release Rate Value) EAL Value = 2 times the Release Rate UE EAL Vahue: (EAL # RU1.) Total (S I & S2) Noble Gas Release Rate > 4.84E+05 jtCi/sec Salem Page 4 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11-235 Salem Radiologicali EAL Setpoint Cailcullation Document NEI 99-019 Rev. 05 EALs Calculation for: Unusual Event EAL AU1.3 - (Sample Analysis Concentration) Objective of Calculation: Provide a Radiological Release Noble Gas and Iodine Sample Concentration that equates to a Release that is > 2 times the ODCM limit of 500 itRero/year. Discussion: The ODCM limit of 500 mRernyear (Noble Gas/Total Body) and 1500mRe!Olyear (1-131/Child Thyroid) is a total site limit that includes Salem 1, Salem 2 and Hope Creek. Therefore, Salem 1&2 will have an administratively controlled limit (allocation factor) of '. the total site limit or 250 mRero/year (Noble Gas/Total Body) and 750 mRemo/year (I-131/Child Thyroid) for EAL calculation purposes. This allocation factor is used in the calculation that derived the Noble Gas and Iodine release rates. Derivation / Calculation: Calculation of the threshold sample concentrations are as follows: Formula: Concentration (uCi/cc) = SingleUnit ReleaseRate

  • 2 ConversionFactor* VentFlowR ate 1.2 1E + 05p/Ci / see* 2 Noble Gas Sample Concentration = l.21E+/-OOkci/c = 6.4E-03 .Ci/cc 472x8SOOOcfin 1-13] Sample Concentration -=05+/-0,~/e* = 5.6E-07 ltCi~cc 472xSOOO0cfim Where:

o Single Unit (Ul or U2) Release Rate (-Noble Gas) = Total Noble Gas Release Rate from Salem (Unit 1 & Unit 2) as derived for EAL AUI.1 split between Unit 1 and 2 (divided by 2) = 2.42E+05 uCi/Sec/2 = 1.21E+05 uCi/Sec per Unit. o Single Unit (UI or U2) Release Rate (Thyroid/I- 131) = 10.5 uCi/Sec per unit as per ODCM, Rev. 24, Section 2.3 ) o 2 = EAL criteria of 2X ODCM value o 472 = conversion factor (28,317 cc/ft3 x 1 min/60 sec) o 80000 cfin = Plant Vent Flow (normal) UE EAL Values: (EAL# RU1.3) Noble Gas Sample Concentration > 6.4E-03 jiCi/cc M-131 Sample Concentration > 5.6E-07 ýiCi/cc Salem Page 5 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC- 111-235 Salem Radlological EAL Setpoint Caicuelation Document NEU 99-04 9Rev. 05 EALs Calculation for: ALERT EAL AA.1 - (Default Release Rate EAL) Objective of Calculation: Provide a Radiological Release Rate value that equates to a Release that is > 200 times the ODCM limit of 500 roRem/year. Discussion: The ODCM limit of 500 toRem/year is a total site limit that includes Salem 1, Salem 2 and Hope Creek. Therefore, Salem 1 &2 will have an administratively controlled limit of 1/2 the total site limit or 250 mRelm/year for EAL calculation purposes. This EAL does not include Iodine Release Rates, since the Plant Vent does not have an Iodine detector. Release Rate = Total Noble Gas Release Rate from Salem (Unit 1 & Unit 2) which would result in a TEDE Dose Rate of 250 mRern/year. The EAL Value will be > 200 times the release rate. Derivation / Calculation: ODCM Limit Calculation for Noble Gas: Release Rate (uCi/Sec) = (ODCAMmiit--m Re in / year) * (SiteAllocatieiFacior) (ODCMX / 0) * (ODCMDRCF) ODCM Limit = 500 mRerlmYear 3 Salem ODCM X/Q = 2.20E-06 sec/mi Salem ODCM DRCF = 4.70E+02 mnRem/yr/uCi/m*- Site Allocation Factor 5.OOE-01 Release Rate (uCi/Sec) =(500iReni/yr)I (5.0OE-0l) (2.20E - 06sec/n ) * (4.70E + 02n Re m / vr //kCi/m. 3 ) 3 Release Rate = 2.42E+05 uCi/Sec EAL Value = > 200 times the Release Rate Alert EAL Value: (EAL# RAIL!) Total (Si1 & S2) Noble Gas Release Rate > 4.84E+07 jgtCisec Salem Page 6 of 15 Rev. 0 (Draft E)

SGS FCG - EAL Technical Bases EP-SC-1 11-235 Salem Radiological EAL Setpoint Calculation Document NEEl 99-01, Rev. 05 EALs Calculation for: ALERT EAL AA1.3 - (Sample Analysis Concentration) Objective of Calculation: Provide a Radiological Release Noble Gas and Iodine Sample Concentration that equates to a Release that is > 200 times the ODCM linmiit of 500 nmReni/year. Discussion: The ODCM limit of 500 mRern/year (Noble Gas/Total Body) and 1500mRex-nyear (1-13 1/Child Thyroid) is a total site limit that includes Salem 1, Salem 2 and Hope Creek. Therefore, Salem 1&2 will have an administratively controlled limit (allocation factor) of 1/2 the total site limit or 250 mRemnlyear (Noble Gas/Total Body) and 750 mRern/year (1-13 l/Child Thyroid) for EAL calculation purposes. This allocation factor is used in the calculation that derived the Noble Gas and Iodine release rates. Derivation / Calculation: Calculation of the threshold sample concentrations are as follows: Formula: Concentration (uCi/cc) = Single Unit ReleaseRate

  • 200 ConversionFactor* VentFlowRate Noble Gas Sample Concentration 1.2 IE+O0kPi/sec*200 = 6.4E-01 .CLi/cc 472x80000cfn 1-131 Sample Con0centration -

10.5E lO=E ++ OOpaCi 00, / sec* qi/ 200 5.6E-05 jtCi/cc 472x80000cfin Where: o Single Unit (U1 or U2) Release Rate (-Noble Gas) = Total Noble Gas Release Rate from Salem (Unit 1 & Unit 2) as derived for EAL AULI.1 split between Unit 1 and 2 (divided by 2) = 2.42E+05 uCi/Sec/2 = 1.2 1E+05 uCi/Sec per Unit. o Single Unit (UI and U2) Release Rate (Thyroid/I-131) = 10.5 uCi/Sec per unit as per ODCM, Rev. 24, Section 2.3.2 o 200 = EAL criteria of > 200X ODCM value o 472 = conversion factor (28,317 cc/ft3 x 1 min/60 sec) o 80000 cfin = Plant Vent Flow (normal) Alert EAL Values: (EAL# RA1.3) Noble Gas Sample Concentration > 604E-01 jiCi/cc 1-131 Sample Concentration > 506E-05 jtCi/cc Salem Page 7 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC- I 11-23-15 Salem RadiologicaI EAL Setpoint Catcuilation Document NEE 99-019 Rev. 05 EALs Calculation for: SITE AREA EMERGENCY - EAL AS1.1 - (Default Release Rate EAL) Objective of Calculation: Provide a Radiological Release Rate value that equates to a Release resulting in an offsite dose of> 100 mrem EDE at'or beyond the-site boundary. Discussion: This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed 10% of the EPA Prte'ctive Action Guides ,(PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. The monitor reading EALs should be determined using a dose assessment method that back calculates from the dose values specified in.the IC. Since doses are generally not monitored in real-time, it is suggested that a release duration of one hour be assumed, and that the EALs be based on a site specific boundary (or beyond) dose of >100 lnrem whole body. Iodine Release Rates for this EAL are excluded since the Plant Vent. .. Radiation Monitoring System does not include an Iodine detector. The meteorology and source term used are the same as used for determning AU1 and AA1 monitor reading EALs. Release Rate = Total Noble Gas Release Rate from Salem (Unit 1 & Uni]t 2) which would result in a EDE Dose Rate of> 100mRemilhr at the site boundary or.beyond. Derivation / Calculation: Radiological Limit Calculation for Noble.Gas: Release Rate (uCi/Sec) = (10%ofPAG)m Re m(accumulatedinlhour) 

        .. ..... ".'                 (ODCMX / Q) * (ODCMDRCF).

10% of PAG 100 mRem dose accumulated 3 in 1 hour Salem5 ODCM-X/Q = 2.20E-06 sec "/m Salem ODCM DRCF = 5.36E-02 mRem/hr/uCi/m3 (4.70E+02 mRem/yr/uCi/m 3 / 8766 hrs/yr) Site Allocation Factor = not used for SAE and GE EALs Release Rate (uCi/Sec.) 1007m Re 7(doseaccuMulatedinlhr) (2.20E - 06sec/ 777,)(5.36E - 027 Re m/ hr/Ci/ 3) SAE EAL Value: (EAL# RSL°J) TotaR (Si & S2) Noi~e Gas Re]ease Rate > 8.48E+08 uCi/Sec Salem Page 8 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-1 11 -235 Salem Radiological EAL Setpoint Calculation Document NEEi 99-01, Rev. 0(5 EALs Calculation for: SITE AREA EMERGENCY - EAL AS1.2 - (Dose Assessment) Objective of Calculation: Using actual meteorology, provide a dose assessment SSCL threshold TEDE 4-Day Dose value that is equivalent to a TEDE dose of >100 mRem and a Thyroid-CDE Dose of 500 mRem. Discussion: This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed 10% of the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and involve fuel damage. Derivation / Calculation: The dose assessment output on the SSCL is reported at varying distances from the plant as a TEDE 4-Day dose. This TEDE 4-day dose assumes a 4 hr release duration. To obtain the approximate dose for a projected release condition of 1 hour, the TEDE 4-day dose value would need to be divided by 4. A TEDE 4-Day Dose > 4.0E+02 nmRem correspond directly to an EDE dose rate value of 100 mRenihr and exceeds 10% of the EPA Protective Actions Guides (PAGs). The Thyroid-CDE Dose > 2.OE+03 mRem correspond directly to an CDE dose rate value of 500 mRemfhrit and exceeds 10% of the EPA Protective Actions Guides (PAGs) which was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.. Dose Assessment using actual meteorological data provides an accurate indication of release magnitude. The use of dose assessment based EALs is therefore preferred over the use of Release Rate based EALs which utilize calculations which have built-in inaccuracies because ODCM default Meteorological data is used. SAE EALs Values: (EAL# RS1.2) Dose Assessment TEDE 4-Day Dose > 4.0 E+02 mRem Dose Assessment CDE Dose > 2 00E+03 mRem - based on Dose Assessment using Plant Vent effluent isotopic sample analysis as input to MIDAS and NOT based on a default Noble Gas to Iodine Ratio Salem Page 9 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Techtical Bases EP-SC- 111-2-3 5 Salem RadiotogicaIR EAL Setpoint Cakicuilafion Document NE~R 99-019 Rev. 05 EALs Calculation for: SITE AREA EMERGENCY - EAL AS1.4 - (PA boundary dose rate) Objective of Calculation: Provide a PROTECTED AREA Boundary dose rate that equates to an offsite dose of > 100 mRem EDE. Discussion: This IC addresses radioactivity releases that result in field survey results (closed window) dose rates greater than 100 mR/hr expected to continue for 60 minutes or longer at or beyond the site boundary. This value exceeds 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the pro{ectior of the public. Derivation / Calculation: A Field Measured Dose Rate of> 1.OE+02 rmRem/hr corresponds directly to a dose values that exceed 10% of the EPA Protective Actions Guides (PAGs). SAE EAL Value: (EA.L# RSL 3 Rate 

         .Dose>          mRem/hr
                              ,0 Salem                                            Page 10 of 15                                         Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC-I 11 -235 Salem Radiologica1l EAL Setpoint Calculation Document NEI 99-01, Rev. 05 EALs Calculation for: SITE AREA EMERGENCY - EAL AS1.4 - (1-131 Field Survey Sample Analysis) Objective of Calculation: Provide a Field Survey Sample Analysis value that equates to an offsite release that would result in a dose of > 500 mRem Thyroid CDE at or beyond the PROTECTED AREA Boundary. Discussion: This EAL addresses a radioactivity release field survey I-131 sample concentration or count rate that would result in a Thyroid CDE dose of greater than 500 mRem for one hour of inhalation at or beyond the site boundary. This value exceeds 10% of the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. The Iodine-131 field survey sample concentration and count rate threshold is based on 1-13 1 dose conversion factors (DCFs) from EPA-400. The thresholds are based on a Thyroid-CDE Dose Rate of> 500 mRemrhr for 1-131. Field Survey 1-131 Sample Analysis results are provided as a sample concentration in units of uCi/cc for field samples counted in a Multi-Channel-Analyzer (MCA). Derivation / Calculation: The release sample concentration calculations are as follows. The sample concentration is calculated using the 1-13 1 Dose Conversion Factor firom EPA-400: Solving the following equation for [iCi/cc: mRem/tu = (ýtCi/cc)(Dose Conversion Factor) Then; 1-131 Sample Concenltration7 (pICi/cc) = ( 7 eCicc = 3.85E-07( 1.30E + 09o Remo / /Ci / cc / hr Where 1.30E+09 mRen-i/tCi/cc/hr is the Dose Conversion Factor from EPA-400, Table 5-4, Thyroid Dose, and includes the EPA breathing rate. SAE EAL Values: (EAL# RSL3) R-131 Concentration > 3.85E-07 ýtCi/cc Salem Page 11 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Tecitmical Bases EP-SC-l 11-235 Saliem Radiologicali EAL Setpoint Cakuilation Document NER 99=0-9 Rev. 05 EALs Calculation for: GENERAL EMERGENCY - EAL AG1.1 - (Default Release Rate EAL) Objective of Calculation: Provide a Radiological Release Rate value that equates to a Release resulting in an offsite dose of > 1000 mrem EDE at or beyond the site boundary. Discussion: This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and likely involve fuel damage. The monitor reading EALs should be determined using a dose assessment method that back calculates from the dose values specified in~the IC. Since doses are generally not monitored in real-time, it is suggested that a release duration of one hour be assumed, and that the EALs be based on a site specific boundary (or beyond) dose of> 1000 mrem whole body. Iodine Release Rates for this EAL are excluded since the Plant Vent Radiation Monitoring System does not include an Iodine detector. The meteorology and source term used are the same as used for detennining AU1 and AA1 monitor reading EALs. Release Rate = Total Noble Gas Release Rate from Salem (Unit I & Unit 2) which would result in a TEDE Dose Rate of > 1000 rnRem/hr at the site boundary or beyond. Derivation / Calculation: Radiological Effluent Techniical Specifications/ODCM Limit Calculation for Noble Gas: Release Rate (uCi/Sec) = 100%PA4 G(in Re 7n)Accuhlulatedinlhr (ODCMX / 0) * (ODCMDR CF) 100% of PAG = 1000 mRem accumulated in 1 hour Salem ODCM X/Q = 2.20E-06 sec/in 3 Salem ODCM DRCF = 5.36E-02 nmRem/hr/uCi/m 3 (4.70Eý-02 mRem/yr/uCi/m 3 / 8766 hrs/yr) Site Allocation Factor = not used for SAE and GE EALs Release Rate (uCi/Sec) 1000n Re in(doseaccuiuzulatedinl1h7r) (2.20E - 06sec/77)3 * (5.36E - 027n Re m / hr /pCi / 7n3 ) GE EAL Value: (EAL# RGW) Total (SI & S2) Noble Gas Release Rate > 8.48E+09 uCi/Sec Salem Page 12 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Techmical Bases EP-SC-1 11 -2135 Salem Radiological EAL Setpoint Calculation Document NEI 99-01, Rev. 05 EALs Calculation for: GENERAL EMERGENCY - EAL AG1.2 - (Dose Assessment) Objective of Calculation: Using actual meteorology, provide a dose assessment SSCL threshold TEDE 4-Day Dose value that is equivalent to a TEDE dose of> 1000 mRem and a Thyroid-CDE Dose of> 5000 rnRem. Discussion: This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed the EPA Protective Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and involve fuel damage. Derivation / Calculation: The dose assessment output on the SSCL is reported at varying distances from the plant as a TEDE 4-Day dose. This TEDE 4-day dose assumes a 4 hr release duration. To obtain the approximate dose for a projected release condition of 1 hour, the TEDE 4-day dose value would need to be divided by 4. A TEDE 4-Day Dose > 4.0E+03 lmRem correspond directly to an EDE dose rate value of >1000 mRem/hr and exceeds the EPA Protective Actions Guides (PAGs). The Thyroid-CDE Dose > 2.OE+04 mRem correspond directly to an CDE dose rate value of> 5000 mRem/lhr and exceeds the EPA Protective Actions Guides (PAGs) which was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.. Dose Assessment using actual meteorological data provides an accurate indication of release magnitude. The use of dose assessment based EALs is therefore preferred over the use of Release Rate based EALs which utilize calculations which have built-in inaccuracies because ODCM default Meteorological data is used. GE EAL Values: (EAL# RGl.2) Dose Assessment]TEDE 4-Day Dose > 4.0 E+03 mRem Dose Assessment CDE Dose > 2o0 E+04 mRem - based on Dose Assessment using Plant Vent effluent isotopic sample analysis as input to MIDAS and NOT based on a default Noble Gas to Iodine Ratio Salem Page 13 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Technical Bases EP-SC- 111 -23 5 Salem RadioIogk.al EAL Setpoint Cakculation Document NER'.99-01, Rev. 05 EALs Calculation for: GENERAL EMERGENCY - EAL AG1.4 - (PA boundarv dose rate) Objective of Calculation: Provide a PROTECTED AREA Boundary dose rate that equates to an offsite dose of > 1000 rnRem EDE. Discussion: This IC addresses radioactivity releases that result in doses at or beyond the site boundary that exceed the EPA Protective 'Action Guides (PAGs). Public protective actions will be necessary. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public and involves fuel damage. Derivation / Calculation: A Field Measured Dose Rate of> 1.OE+03 rnRem/hr corresponds directly to a dose values that exceed the EPA Prote'ctive Actions Guides (PAGs). GE EAL Value: (EAL# RG}Z 3) Dose Rate > 1000 mRemh/hr Salem Page 14 of 15 Rev. 0 (Draft E)

SGS ECG - EAL Techmical Bases EP-SC- 111-235 Salem RadiologicaR EAL Setpoint Calculation Document NEE 99-01, Rev. 05 EALs Calculation for: GENERAL EMERGENCY - EAL AG1.4 - (1-131 Field Survey Sample Analhsis) Objective of Calculation: Provide a Field Survey Sample Analysis value that equates to an offsite release that would result in a dose of > 5000 mRem Thyroid CDE at or beyond the PROTECTED AREA Boundary. Discussion: This EAL addresses a radioactivity release field survey 1-131 sample concentration or count rate that would result in a Thyroid CDE dose of greater than 5000 mRem for one hour of irhalation at or beyond the site boundary. This value exceeds the EPA Protective Action Guides (PAGs). Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. The Iodine-131 field survey sample concentration and count rate threshold is based on 1-131 dose conversion factors (DCFs) from EPA-400. The thresholds are based on a Thyroid-CDE Dose Rate of > 5000 mnRen/"lh for 1-13 1. Field Survey 1-131 Sample Analysis results are provided as sample concentration in units of uCi/cc for field samples counted in a Multi-Channel-Analyzer (MCA). Derivation / Calculation: The release sample concentration calculations are as follows. The sample concentration is calculated using the I-13 1 Dose Conversion Factor from EPA-400: Solving the following equation for pCi/cc: mRem/hr = (jtCi/cc)(Dose Conversion Factor) Then; 1-131 Sample Concentration(iCi/cc) = (0CRc/ ( ) = 3.85E-06 1.30E + 09m Re m //Ci / cc /hc 

  -here 1.30E+09 inRern/gCi/cc/hr is the Dose Conversion Factor from EPA-400, Table 5-4, Thyroid Dose, and includes the EPA breathing rate.

GE EAL Values: (EAL# RGGl 3) Eo131 Concentration > 3.85E-06 /tCi/cc Salem Page 15 of 15 Rev. 0 (Draft F'

Q. Salem and Hope Creek Generating Stations EAL Review Supporting Document THREAT ASSESSMENT Procedure SY-AA-101-132

SY-AA-101-132 Revision 11 Page 1 of 12 LeveG 3 - Information Use PSEG NUCLEAR SECURFTY SY-AA-101-132 Revision I I THREAT ASSESSMENT REVISION

SUMMARY

1. Step 4.5.2 was revised to add greater detail to the reference to SY-AA-101-108. This change specifically address the requirements of 10 CFR 73.55 (g)(4) - In response to a site-specific credible threat or other credible information, implement a two-person (line-of-sight) rule for all personnel in vital areas so that no one individual is permitted access to a vital area. (Order 80099993 - 0930)
2. As a result of this review, Step 6.1 was changed from "Commitments" to "Regulatory References" to align with the terms and definitions of LS-AA-1 10, Commitment Management. Step 6.3.6, previously listed as a writer reference, was moved to Step 6.1.1 and reference to 10 CFR 73.55 (g)(4) was added at Step 6.1.2.

IMPLEMENTATION REQUIREMENTS None

SY-AA-101-132 Revision 11 Page 2 of 12 LeveI 3 - Information Use THREAT ASSESSMENT TABLE OF CONTENT SECTION TITLE PAGE

1. P u rp o s e ............................................................................................................................... 3
2. TERMS AND DEFINITIO NS ........................................................................................... 3
3. RESPONSIBILITIES .................................................................................................. 4
4. MA IN B O D Y ........................................................................................................................ 4 4.1. General Information .................................................................................................... 4 4.2. Discovery or Receipt of a threat .................................................................................. 5 4 .3 . In v e stig a tio n .................................................................................................................... 6 4.4. Threat Disposition ..................................................................................................... 6 4.5. Follow-up Actions ..................................................................................................... 7
5. DOCUM ENTATION .................................................................................................... 8
6. R E F E R E NC ES ................................................................................................................... 8
7. ATTACHM ENTS ................................................................................................................. 9 ATTACHMENTS Attachm ent 1, Threat Probability and Risk Logic ....................................................... 10 , Identification, Assessment and Handling of Potential Security Threats ........... 12

SY-AA-101-132 Revision 11 Page 3 of 12 THREAT ASSESSMENT

1. PURPOSE 1.1. This procedure sets forth the model to be used as a tool to consider, analyze, and respond to various levels of threats specifically focused toward Salem /Hope Creek Generating Station.

1.2. This procedure delineates the responsibilities of the Nuclear Security Director, Security Operations Manager, and the Shift Manager.

2. TERMS AND DEFINITIONS 2.1. Threat - an expression of intent to do harm or act out violently against someone or something. A threat can be spoken, written, symbolic, or observed.

2.1.1. Non-Credible Threat - a threat which poses a minimal or no risk to the safe operation of the facility or to personal and public safety. 2.1.2. Credible / Possible Threat - a threat which poses some risk to the safe operation of the facility or to personal and public safety. 2.1.3. Credible / Actual Threat - a threat which poses a likely and serious danger to the safe operation of the facility or to personal and public safety. 2.2. Threat Assessment - an evaluation of a threat, based on physical evidence, observation, the receipt of information however obtained, and its interpretation. 2.3. Direct Information - identifies a specific act against specific target(s) and is delivered in a straightforward and explicit manner (usually with precise details). 2.4. Indirect Information - tends to be vague, unclear, and ambiguous. The plan, the intended target(s), motivation, and other aspects tend to be masked or unknown. 2.5. Veiled Information - strongly implies, but does not explicitly threaten an act of violence against target(s); usually a verbal or written hint that "something" will happen. 2.6. Conditional Information - is often used for extortion and warns of a violent act that will occur unless certain terms or conditions are met. 2.7. Cyber-Security Threats related to electrical rotating equipment. o The vulnerability that pertains to Digital Protection Control Devices (DPCD) such as protective relays, programmable logic controllers, bay controllers, and other devices that can control breaker closure operations has been mitigated both on-site and off-site in accordance with PSEG's response to NRC letter "Control Systems Vulnerability," dated June 22, 2007. o Because these types of threat have been mitigated, no additional Nuclear Power Plant Operator actions are required.

SY-AA-101-132 Revision 11 Page 4 of 12

3. RESPONSIBILITIES 3.1. Security Operations Manager 3.1.1. Security Operations Manager and/or designated alternates shall conduct and disposition threat assessment while notifying and working in coordination with appropriate Station personnel.

3.1.2. Security Operations Manager and/or designated alternates shall conduct threat assessment in coordination with applicable Federal, State, and Local Law Enforcement Agencies, when necessary. 3.2. Shift Manager 3.2.1. Shift Manager or designated alternate shall assist Security with any ongoing threat assessment. Responsible for contacting NRC Operations Center when applicable.

4. MAIN BODY 4.1. General Information 4.1.1. Examples of possible threats:
      -       Attack threat (against facility)
      -       Attack threat (against personnel)
      -       Vehicular bomb threat
      -       Water borne threat
      -        Bomb threat
      -       Chemical / biological threat 4.1.2. ENSURE every threat is taken seriously until analysis and/or investigation determines threat is non-credible, of limited impact, or has been resolved.

4.1.3. NOTIFY Security Operations Manager and Shift Manager of the potential threat and that a threat assessment is being performed. NOTE: All threats are not equal in the level of seriousness. 4.1.4. CONDUCT threat assessment in a timely manner to assure appropriate classification, disposition and response. 4.1.5. ENSURE an effective threat assessment considers all of the information (symptoms) to evaluate threat (similar to how a doctor would approach a medical diagnosis). NOTE: Assessment must be based on the collective analysis of all factors relating to the threat. Do not use only certain details of the threat to drive the outcome.

1. EVALUATE all available information of threat.

4.1.6. MAINTAIN all materials, documents, or messages relating to a threat.

SY-AA-101-132 Revision 11 Page 5 of 12 NOTE: Whenever threat information is received directly via a telephone message, attempt, if possible, to validate the reliability of the source providing the information (i.e., contact the organization for which the caller asserted affiliation). Response actions should not be delayed-they should be performed in parallel with the validation. 4.2. Discovery or Receipt of a threat 4.2.1. If a threat has been received from NRC and is classified as credible by them, then do not conduct an additional threat assessment:

1. ENSURE the following notifications are made:
              -       NOTIFY Shift Manager
              -       Shift Manager shall CONTACT NRC Operations Center.
2. PROCEED to section 4.5.

4.2.2. If threat has been received from one of the following, then CONTACT NRC to assist in validating threat: 

       -      Department of Homeland Security (DHS)
       -      Federal Bureau of Investigation (FBI)
       -      Federal Aviation Administration (FAA)
       -      North American Aerospace Defense Command (NORAD)
1. If NRC validates the information as credible, then do not conduct additional threat assessment.

A. ENSURE the following notifications are made: 

                      -     NOTIFY Shift Manager.
                      -     Shift Manager shall CONTACT NRC Operations Center.

B. PROCEED to section 4.5.

2. If NRC does not validate the information as credible, then CONDUCT a threat assessment.
              -   PROCEED to section 4.3.

4.2.3. If threat is received from a source other than NRC, FBI, FAA, DHS, or NORAD, then Security shall INITIATE threat assessment process upon discovery and/or receipt of a potential threat.

1. NOTIFY Security Operations Manager or Designee.
2. NOTIFY Shift Manager.
3. CONTACT NRC, via Emergency Notification System (ENS) phone and REQUEST assistance in verifying credibility of threat.
4. NOTIFY Nuclear Security Director.

SY-AA-101-132 Revision 11 Page 6 of 12 4.3. Investigation NOTE: Specific detail, plans, or preparation usually suggest a higher risk that the threat will occur--whereas a lack of detail, plans or preparation suggest a lower risk that the threat may occur. 4.3.1. GATHER and DOCUMENT all information, details, and evidence regarding threat.

1. Specific and plausible details are critical factors in evaluating threat.
2. Details can include, but are not limited to:

A. Source of the threat. 

                      -      Who made the threat?
                      -      To who was the threat made?
                      -       How was the threat communicated?

B. Weapons, explosives, other contraband, or suspicious material. C. Impact of threat to equipment or personnel. 

                      -      What will happen or what will be the result if the threat is carried out?

D. Reason(s) or motivation for making threat. E. Means or method proposed to carry out threat. F. Date, time, and location threatened act is supposed to occur. G. Information regarding plans or preparations for carrying out threat. 

                      -      Where did, or will it happen?

H. Indication or information regarding similar threats. 

                      -       CONSIDER recent, known, or publicized situations or events that have been carried out either inside or outside of nuclear power industry.

4.4. Threat Disposition 4.4.1. DISPOSITION as non-credible, credible/possible, or credible/actual (refer to Attachment 1, Threat Probability and Risk Logic for additional information).

1. NON-CREDIBLE THREAT - a threat which poses minimal or no risk to safe operation of facility or to personal and public safety.
              -       Threat is vague and indirect.
              -       Information is inconsistent, implausible, or lacks sufficient details.
              -       There may be a general indication of a possible time and location (but no exact details).

SY-AA-101-132 Revision 11 Page 7 of 12 

              -       Threat lacks realism based on comparison to other events inside or outside the nuclear industry.
              -       There is no strong indication that the preparation to carry out the threat has been taken.
2. CREDIBLE / POSSIBLE THREAT - threat which could pose some risk to safe operation of the facility or to personal and public safety.
               -      Threat is direct and specific.
               -      Threat suggests that definite steps have been taken toward carrying out threat.
               -      Threat may compare closely to other events inside or outside of nuclear industry.
               -      Evidence substantiating threat may have been discovered.
               -      NRC or DHS (Department of Homeland Security) has confirmed a valid threat regarding cyber-security issues.
3. CREDIBLE / ACTUAL THREAT - a threat which poses a likely and serious danger to safe operation of the facility or to personal and public safety.
               -      Evidence clearly substantiating threat has been discovered.
               -      Threat has occurred, is approaching, or is impending within a short time period.
               -      NRC or DHS (Department of Homeland Security) has confirmed a valid threat regarding cyber-security issues.

4.5. Follow-up Actions 4.5.1. If credible threat information is received from the NRC or threat information received from the FBI, FAA, DHS, or NORAD has been validated as credible by the NRC or if information is received from any source and all of the conditions (listed below) are met, then CLASSIFY threat as CREDIBLE / ACTUAL THREAT. 

      -        Threat is focused at Salem/Hope Creek.
      -        Threat is considered credible.
      -        Threat is specific.
      -        Threat is impending [< 2 hours].
1. ENSURE the following actions are taken:
             -     IMPLEMENT Emergency Plan.
             -     IMPLEMENT Operation's Special Event / Abnormal procedures.
             -     REFER to Attachment 2, Identification Assessment and Handling of Potential Security Threat, for further actions and notifications.

SY-AA- 101-132 Revision 11 Page 8 of 12 4.5.2. If conditions listed in Section 4.5.1 have not been met, but threat has still been dispositioned as CREDIBLE / POSSIBLE, then Shift Manager to perform the following: 

      -        IMPLEMENT OP-AA-106-101-1002.
      -        NOTIFY PSEG Senior Management.
      -        IMPLEMENT SY-AA-101-108, Section for Existence of Specific, Credible Insider Threat (Implementing a two person (line-of-sight) rule in vital areas).
      -        REFER to Attachment 2, Identification Assessment and Handling of Potential Security Threat, for further actions and notifications.

4.5.3. In all cases, IMPLEMENT appropriate actions in accordance with:

1. Station Security Plan
2. Security Contingency procedures
3. Safeguards Event Report 4.5.4. CONTACT the following off-site agencies as appropriate in accordance with phone list in SY-AA-101-121-1001, Security Communication Network:
1. Local Law Enforcement Agency
2. State Police
3. Regional Operations & Intelligence Center (ROIC)
4. Federal Bureau of Investigation
5. Nuclear Regulatory Commission 4.5.5. INITIATE notification of appropriate personnel (refer to Attachment 2, Identification, Assessment and Handling of Potential Security Threats).
5. DOCUMENTATION 5.1. As data is collected throughout threat assessment process, it is important that all documents be maintained in an organized and controlled manner at the site.

5.2. All follow-up actions should be documented and formally tracked.

6. REFERENCES 6.1. Regulatory References 6.1.1. Item B.3.c. of NRC Order for Interim Safeguards and Security Measures dated February 25, 2002 (Attachment 2) 6.1.2. 10 CFR 73.55 (g)(4) - In response to a site-specific credible threat or other credible information, implement a two-person (line-of-sight) rule for all personnel in vital areas so that no one individual is permitted access to a vital area.

SY-AA-101-132 Revision 11 Page 9 of 12 6.2. User References 6.2.1. SY-AA-1 01-108, Response to Suspicious Activity and Events Maliciously Directed at Plant or Security 6.2.2. SY-AA-1 01-109, Response to Contingency Events 6.2.3. SY-AA-1 01-111, Threat Advisory Protective Measures System 6.2.4. SY-AA-1 01-121-1001, Security Communication Network 6.2.5. OP-AA-106-101, Significant Event Reporting 6.2.6. OP-AA-1 06-101-1002, PSEG Nuclear Issues Management 6.2.7. Emergency Plan 6.2.8. Emergency Plan Annexes (to include Emergency Activation Levels) 6.2.9. SY-AA-1 002, Safeguards Event Report (SER) 6.2.10. Letter from U.S. NRC to Wm. Levis, "Control Systems Vulnerability," dated June 22, 2007 6.3. Writer's References 6.3.1. Fein, R.A., & Vossekuil, B. (1998). Protective Intelligence Threat Assessment Investigations: A Guide for State and Local Law Enforcement Officials. 6.3.2. National Center for the Analysis of Violent Crime, FBI Academy (1998). The School Shooter: A Threat Assessment Perspective. 6.3.3. Van Zandt & Associates (2001). Guidelines for Threat Assessment Decision Making 6.3.4. NRC Order for Interim Safeguards and Security Measures (dated February 25, 2002) 6.3.5. Safeguards Advisory for Operating Power Reactors, SA-04-07 (dated June 18, 2004); this document is classifiedas Safeguard Information

7. ATTACHMENTS 7.1. Attachment 1, Threat Probability and Risk Logic 7.2. Attachment 2, Identification, Assessment and Handling of Potential Security Threats

SY-AA-101-132 Revision 11 Page 10 of 12 ATTACHMENT 1 Threat Probability and Risk Logic Page 1 of 2 THREAT PROBABILITY: 13 High Probability - strong belief the threat is both credible and is likely to occur based as threatened o Moderate Probability - threat is deemed possible, but there is no indication of actual credibility or time/date of occurrence is vague Low Probability - no information to confirm threat and information and assessment made does not support possibility of threat being carried out as threatened Probability Considerations: 

      -   Use of technical acronyms or jargon or indication the person making threat is technically trained merits close attention.
      -   The more specific details contained in threat, the more likely threat is to be credible.

[Moderate to High probability] 

      -   If details are vague, less likely threat is to be credible. [Moderate to Low probability]
      -   If a written threat is lengthy (1 or more pages) or appears to be have been carefully planned or invokes religious or group affiliation, then the threat tends to be credible

[Moderate to High probability]. 

      -   If a written threat is simply a few sentences with vague information, then the threat tends to be less credible [Moderate to Low probability].
      -   If technical terms are used (*For Example, if there is a technical term for threatened device or substance, or for its effects), then it is a [Moderate to High probability].
          *This includes the size of the device, the power, or in the case of chemical or biological agents, any reference to the lethal dose, incubation period, etc.

SY-AA-101-132 Revision 11 Page 11 of 12 ATTACHMENT I Threat Probability and Risk Logic Page 2 of 2 RISK LOGIC EXAMPLES Situation A: A bomb threat is received from an organization that is claiming responsibility for placing the device. The message indicates the type of bomb, what type of equipment will be destroyed, how the bomb was introduced to the facility, and the time it is intended to explode. Logic: Based on this information, the risk logic would indicate a MODERATE probability because this threat contains specific details and suggests that planning and preparation took place. If a search of the area resulted in the discovery of an explosive device, then the probability would escalate to HIGH in accordance with a credible/actual threat. Situation B: A powdered substance is discovered on the floor of an area of the plant and two employees are concerned that it may be a type of biological threat. The investigation revealed that grinding was being performed in an area adjacent to where the powdered substance was found. It appears that the substance, created by the grinding process, was transferred to the plant by personnel passing through the work area. Logic: Based on this information, the risk logic would indicate LOW equivalent to a non-credible threat. This is due to a logical explanation for the presence of the substance, and the lack of detail, motivation, and a substantiated threat.

SY-AA-101 0132 Revision 11 Page 12 of 12 ATTACHMENT 2-Identification, Assessment, and Handling of Potential Security Threats Page 1 of 1 CAS SAS S/HC: xxx-xxx- xxxx xxxx ENGAGE Shift - ------ ------ ----- Manager in Threat Assessment process

  • CredilUe Threat
        '                         Shift ACTIVATE                   Manager to Contingency Plan               CONTACT NRC j* Operations                                                                         CONTACT:

S CONTACT Shift C~e'nter o Shift Manager FManager. Shift/Plant _/_L 

                                                                                                             " Shift/Plant Personnel o Station Duty Manager Personnel, & Station                                        -    0   D   0
                                                                                                             " Site NRC Residents Duty Manager                          NRC classifies the threat as credible                           " Reqion I Security or I                               NRC validates threat information received IMPLEMENT                             from FBI, FAA, DHS or NORAD as credible NRC validates threat info received from DHS of an "unmitigated Cyber Sec. threat" as credible (Ref Step 2.7 for description of Cyber Sec. related to electrical rotating equipment) or Threat IS focused at Salem/HC Nuc.

Threat IS credible Threat IS specific 

                                               , Threat TS impending [< 2 hours]

I ~II Shift Manager to CONTACT I& NRC NOTIFY / Involve CONTACT Shift Manager Operations Offsite Agencies Center I IMPLEMENT procedure For an insider threat: OP-AA-106-101-1002 I I IMPLEMENT a two-CONSIDER implementation of person (line of sight) Operation's Special Event / rule for all personnel in Abnormal procedures (except for I1 o the Vital Area mitigated cyber-security threat) K EOF / TSC / ENC NOTIFY PSEG Senior INITIATE communications o This includes all Departments/Groups and Security I Management plan AUGMENT site resources IMPLEMENT procedure as necessary SY-AA-101-108}}

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